20160630Direct Communications Rockland REDACTED Form 481.pdf

June 29, 2016 VIA ELECTRONIC FILING
REDACTED – FOR PUBLIC INSPECTION Ms. Jean Jewell, Commission Secretary Idaho Public Utilities Commission 472 W. Washington Street Boise, Idaho 83720-0074 Re: Direct Communications Rockland, LLC FCC Form 481 – Carrier Annual Reporting Data Collection Form, in Compliance with 47 C.F.R. §§ 54.313 and 54.422 Dear Ms. Jewell: On behalf of Direct Communications Rockland, LLC (the Company), attached is a copy of the Company’s FCC Form 481 – Carrier Annual Reporting Data Collection Form, in compliance with 47 C.F.R. §§ 54.313 and 54.422. The attached report is provided to the Idaho Public Utilities Commission (PUC) in accordance with 47 C.F.R. §§ 54.313(i) and 54.422(c). The signed and notarized affidavit is included with this filing. Following this filing, a paper copy of the confidential version on yellow paper and in a sealed envelope will be mailed via FedEx to the Idaho PUC. If you have any questions or need additional information, please contact me at 209-955-6116 or via e-mail at [e-mail]. Sincerely,
Eric N. Votaw, Senior Manager For Moss Adams Enclosures cc: Jeremy Smith – Direct Communications Rockland

REDACTED – FOR PUBLIC INSPECTION

VIA ECFS June 27, 2016 Ms. Marlene H. Dortch, Secretary Federal Communications Commission Office of the Secretary 445 12th Street, S.W. Washington, D.C. 20554 RE: REQUEST FOR CONFIDENTIAL TREATMENT
WC Docket No. 14-58 - ETC Annual Reports and Certifications Request that Information Submitted to the Commission be Withheld from Public Inspection Pursuant to 47 C.F.R. §0.459 and 5 U.S.C. §552(b)(4): Five-Year Service Quality Improvement Plan Progress Report included in FCC Form 481 Confidential Information – Subject to Protective Order Before the Federal Communications Commission Dear Ms. Dortch: In accordance with the annual reporting requirements of 47 C.F.R. §§54.313 and 54.422, Direct Communications Rockland, LLC (the Company), Study Area Code 472232 is submitting a completed FCC Form 481 to the Commission via its Electronic Comment Filing System (ECFS) in WC Docket No. 14-58. The version of the Company’s FCC Form 481
submitted via ECFS is a redacted version of the filing that contains no confidential
information. The Company, by its authorized representative, hereby requests confidential treatment of two attachments to its FCC Form 481: (1) the five-year service quality improvement plan progress report and (2) the financial annual report, both of which were redacted in the ECFS submission. The request for confidential treatment of the five-year plan progress report is being made pursuant to Section 0.459 of the Commission’s rules and Exemption 4 of the Freedom of Information Act (FOIA). The request for confidential
Ms. Marlene Dortch Page 2 treatment of the financial annual report is being made pursuant to the FCC’s March 22, 2016 Protective Order in WC Docket Nos. 10-90 and 14-58. These attachments contain competitively sensitive data that Direct Communications Rockland, LLC maintains as confidential and does not normally make available to the public. Release of this information would have a substantial negative impact on the Company.
Five-Year Service Quality Improvement Plan Progress Report Pursuant to Section 0.459 of the Commission’s rules and Exemption 4 of FOIA, Direct Communications Rockland, LLC requests that the text and data extracted from its five-year service quality improvement plan progress report be withheld from public inspection because it contains competitively sensitive commercial and financial information that the Company maintains as confidential. Public availability of this information would have a substantial negative impact on the Company. In accordance with Section 0.459 of the Commission’s rules, the following information is provided in support of this request: (1) Identification of the specific information for which confidential treatment is sought: Attachment to Line 112 of FCC Form 481 – Five-Year Service Quality Improvement Plan Progress Report. Specifically, confidential treatment is sought for all information in the five-year plan progress report related to the Company’s access line counts, existing broadband capabilities, and current and planned financial investments in its network that will improve service quality, service coverage, and/or service capacity for its customers. (2) Identification of the Commission proceeding in which the information was submitted or a description of the circumstances giving rise to the submission: The information was submitted in WC Docket No. 14-58 as an attachment to FCC Form 481- the Carrier Annual Reporting Data Collection Form. Section 100 of FCC Form 481 requires incumbent local exchange carriers receiving high cost support to attach a progress report on its five-year service quality improvement plan, pursuant to 47 C.F.R. §54.313(a)(1). (3) Explanation of the degree to which the information is commercial or financial, or contains a trade secret or is privileged: The five-year service quality improvement plan progress report contains granular information on the Company’s access line counts and/or existing broadband capabilities as well as recent and planned capital investments in its network to
Ms. Marlene Dortch Page 3 improve service quality, service coverage, and/or service capacity. It also contains a map of the Company’s service area detailing progress toward meeting broadband deployment targets at the wire center level. This is closely guarded, privileged information that the Company does not make publicly available. (4) Explanation of the degree to which the information concerns a service that is subject to competition: Broadband is subject to increasing competition in the areas served by rural, rate-of-return incumbent local exchange carriers (RLECs). Virtually all RLECs face competition from one or more wireless Internet service providers. Most RLECs also face competition from at least one other wireline broadband provider, such as a larger cable company, who will typically seek to “cherry pick” the lower cost portions of the study area. In addition, all RLECs face competition throughout their territories from satellite broadband providers. (5) Explanation of how disclosure of the information could result in substantial competitive harm: Disclosure of the information contained in the five-year plan progress report would provide competitors with detailed, granular information regarding the Company’s access line count, its existing broadband capabilities, and its recent and planned network investments that improve service quality, coverage, and/or capacity for subscribers. This would give competitors valuable confidential information with which to develop their own strategies for investing in the service area, thereby bringing substantial competitive harm to the Company. (6) Identification of any measures taken by the submitting party to prevent unauthorized disclosure: The Company has continually treated the extracted information in its five-year plan progress report as confidential and carefully controls the information to protect it from competitors. Access to the information is limited to employees that require it and to non-employees with confidentiality obligations such as lenders, consultants, auditors, and attorneys. In addition, when such information is required to be submitted to a state regulatory authority it has been filed as confidential information, not available to the public.
Ms. Marlene Dortch Page 4 (7) Identification of whether the information is available to the public and the extent of any previous disclosure of the information to third parties: The redacted information in the five-year plan progress report is not available to the public, and third-party access is limited as described in (6) above. (8) Justification of the period during which the submitting party asserts that material should not be available for public disclosure: The Company requests that the extracted information be withheld from public inspection indefinitely. The information in the five-year plan progress report details the Company’s most recent network upgrades in relation to its previously submitted service quality improvement plan. It may also contain upcoming planned network improvements during the five-year period ending 2019. This information would provide a very useful baseline for competitors for several years beyond that period. (9) Any other information that the party seeking confidential information treatment believes may be useful in assessing whether its request for confidentiality should be granted: Exemption 4 of FOIA shields from public disclosure commercial or financial information obtained from a person that is privileged or confidential. Based on the responses provided above, the information in question satisfies this test.
Financial Annual Report Section 3005 of FCC Form 481 requires a privately-held rate-of-return carrier receiving high cost support to attach a full and complete annual report of the company’s financial condition and operations pursuant to 47 C.F.R. §54.313(f)(2). Direct Communications Rockland, LLC seeks confidential treatment of its financial annual report pursuant to the March 22, 2016 Protective Order in WC Docket Nos. 10-90 and 14-58.1 The Protective Order specifically covers information filed pursuant to 47 C.F.R. §54.313(f)(2). Direct Communications Rockland, LLC is providing to the Office of the Secretary, under seal, this cover letter and the Form 481 filing which includes the confidential information that is being requested to be withheld from public inspection. Each page of the five-year service quality improvement plan progress report confidential submission bears the legend, “CONFIDENTIAL – NOT FOR PUBLIC DISCLOSURE.”
1 Connect America Fund, ETC Annual Reports and Certifications, WC Docket Nos. 10-90 and 14-58, Protective Order, DA 16-296 (rel. Mar. 22, 2016).
Ms. Marlene Dortch Page 5 Each page of the financial annual report confidential submission bears the legend, “CONFIDENTIAL INFORMATION – SUBJECT TO PROTECTIVE ORDER BEFORE THE FEDERAL COMMUNICATIONS COMMISSION.” The confidential information has also been submitted to the Universal Service Administrative Company through its E-File system as attachments to the FCC Form 481. In the filing submitted via ECFS, all pages containing confidential information bear the legend “REDACTED – FOR PUBLIC INSPECTION.” This cover letter includes no confidential information and the text is the same in both the non-redacted and redacted versions except for the confidentiality markings. Please contact me if you have any questions. Sincerely, Eric Votaw, Senior Manager for Moss Adams LLP EV/ch Enclosures cc: Jeremy Smith – Direct Communications Rockland
Page 1
Page 1
FCC Form 481FCC Form 481 - Carrier Annual Reporting OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name: Person USAC should contact

<035>Contact Telephone Number:
<039>Contact Email Address:

Data Collection Form

Form Type

54.313 and 54.422
Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
Page 2
Page 2
<110>Has your company received its ETC certification from the FCC?(yes / no )
<111>(yes / no )
If your answer to Line <111> is yes, please file a progress report, on line
<112> delineating the status of your company's existing § 54.202(a) "5 year
plan" on file with the FCC, as it relates to your provision of voice telephony
service.
<112>Attach Five-Year Service Quality Improvement Plan or, in subsequent years,
your annual progress report filed pursuant to 47 C.F.R. § 54.313(a)(1). If your company is a
CETC which only receives frozen support, your progress report is only
<113>Maps detailing progress towards meeting plan targets
<114>Report how much universal service (USF) support was received
<115>
<116>
<117>
<118>
(100) Service Quality Improvement Reporting FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>
Brian Lee
Yes
2017
[e-mail]
Yes
Not Applicable
DIRECT COMM-ROCKLAND
2085482345 ext.
Yes
Yes
472232
472232id112.pdf, Word Doc Maps of DCR coverage.docx
Yes
REDACTED - FOR PUBLIC INSPECTION
Page 3
Page 3
(200) Service Outage Reporting (Voice)FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>
<220>
NORS
Reference
Number
Outage Start
Date
Outage Start
Time
Outage End
Date
Outage End
Time
Number of
Customers Affected Total Number of
911 Facilities Service Outage Affect Multiple
Service Outage Preventative

<210> For the prior calendar year, were there any reportable voice service outages?
Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
No
REDACTED - FOR PUBLIC INSPECTION
(300) Unfulfilled Service Request FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

<300> Unfulfilled service request (voice)
<310> Detail on attempts (voice)
<320> Unfulfilled service request (broadband)
<330> Detail on attempts (broadband)

Name of Attached Document

Name of Attached Document
Page 4
Page 4
Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
0
0
472232
REDACTED - FOR PUBLIC INSPECTION

<010> Study Area Code

<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line
<030>

<039> Contact Email Address - Email Address of person identified in data line
<030>

<400>
Select from the drop-down list to indicate how you would like to report
voice complaints (zero or greater) for voice telephony service in the prior
calendar year for each service area in which you are designated an ETC for
any facilities you own, operate, lease, or otherwise utilize.
<410> Complaints per 1000 customers for fixed voice
<420> Complaints per 1000 customers for mobile voice
<430>
Select from the drop-down list to indicate how you would like to report
end-user customer complaints (zero or greater) for broadband service in
the prior calendar year for each service area in which you are designated
an ETC for any facilities you own, operate, lease, or otherwise utilize.

<440>
<450>
Complaints per 1000 customers for fixed broadband
Complaints per 1000 customers for mobile broadband

Page 5
Page 5
(400) Number of Complaints per 1,000 customers FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
Brian Lee
2017
[e-mail]
0.0
Offered only fixed broadband
DIRECT COMM-ROCKLAND
2085482345 ext.
0.0
Offered only fixed voice
472232
REDACTED - FOR PUBLIC INSPECTION
(500) Compliance With Service Quality Standards and Consumer Protection Rules FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

Page 6
Page 6
<500> Certify compliance with applicable service quality standards and consumer protection rules

<510> Descriptive document for Service Quality Standards & Consumer Protection Rules Compliance
Brian Lee
4722232id510.pdf
Yes
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
<010>
<015>
<020>
<030>
<035>
<039>
Study Area Code
Study Area Name
Program Year
Contact Name - Person USAC should contact regarding this data
Contact Telephone Number - Number of person identified in data line <030>
Contact Email Address - Email Address of person identified in data line <030>
(600) Functionality in Emergency Situations FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013

<600> Certify compliance regarding ability to function in emergency situations
Page 7

<610> Descriptive document for Functionality in Emergency Situations
Page 7
Brian Lee
2017
Yes
[e-mail]
4722232id610.pdf
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
Page 8
Page 8
<701>Residential Local Service Charge Effective Date
<702>Single State-wide Residential Local Service Charge

<703>
State Exchange (ILEC)SAC (CETC)Rate Type
Residential Local
Service Rate

Total per line Rates and Fees
Mandatory Extended Area
Service ChargeState Universal Service FeeState Subscriber Line Charge
(700) Price Offerings including Voice Rate Data FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>
<015>
<020>
<030>
<035>
<039>
Study Area Code
Study Area Name
Program Year
Contact Name - Person USAC should contact regarding this data
Contact Telephone Number - Number of person identified in data line <030>
Contact Email Address - Email Address of person identified in data line <030>

Brian Lee
1/1/2016
2017
-- See attached worksheet
--
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
25.76
REDACTED - FOR PUBLIC INSPECTION
Page 9
Page 9
<711>
Exchange (ILEC)Residential Rate
State Regulated
Broadband Service -
Download Speed Broadband Service -
Usage Allowance
Action Taken When
select}

Usage Allowance

(710) Broadbrand Price Offerings FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
-- See attached
worksheet --
472232
REDACTED - FOR PUBLIC INSPECTION
Page 10
Page 10
(800) Operating Companies FCC Form 481
Data Collection Form OMB Control No. 3060-0986
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>
<810>Reporting Carrier
<811>
<812>

<813>

Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
<813>

Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
<813>

Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
<813>

Doing Business As Company or Brand Designation
<a1>
Affiliates
<a2>
SAC
/OMB Control No. 3060-0819

Not Applicable
Brian Lee
Direct Communications Rockland
2017
[e-mail]
Direct Communications Rockland
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
Page 11
<910>Tribal Land(s) on which ETC Serves

<920>Tribal Government Engagement Obligation
<921>
<922>
<923>
<924>
<925>
<926>
<927>
<928>
<929>

(900) Tribal Lands Reporting FCC Form 481
Data Collection Form OMB Control No. 3060-0986
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

/OMB Control No. 3060-0819

Page 11
<900>Does the filing entity offer tribal land services? (Y/N)
Brian Lee
472232id920.pdf
Not Applicable
2017
[e-mail]
Not Applicable
Not Applicable
Yes
Not Applicable
Not Applicable
Shoshone - Bannock
Not Applicable
DIRECT COMM-ROCKLAND
Not Applicable
Not Applicable
2085482345 ext.
Not Applicable
472232
REDACTED - FOR PUBLIC INSPECTION

Page 12
(1000) Voice and Broadband Service Rate Comparability FCC Form 481
Data Collection Form OMB Control No. 3060-0986
July 2013

/OMB Control No. 3060-0819

<1000> Voice services rate comparability certification
<1010> Attach detailed description for voice services rate
comparability compliance

Name of Attached Document

<1020> Broadband comparability certification
<1030> Attach detailed description for broadband
comparability compliance

Name of Attached Document
Page 12
Brian Lee
472232id1010.pdf
472232id1030.pdf
2017
[e-mail]
Yes - Pricing is no more than the most recent applicable benchmark announced by
the Wireline Competition Bureau
DIRECT COMM-ROCKLAND
2085482345 ext.
Yes
472232
REDACTED - FOR PUBLIC INSPECTION
Page 13
Page 13
(1100) No Terrestrial Backhaul Reporting FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013

<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

<1130>
Certify whether terrestrial backhaul options exist (Y/N)

<1100>
Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
Yes
472232
REDACTED - FOR PUBLIC INSPECTION
Page 14
Page 14
(1200) Terms and Condition for Lifeline Customers FCC Form 481LifelineOMB Control No. 3060-0986/OMB Control No. 3060-0819Data Collection Form July 2013

<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>
<1210>Terms & Conditions of Voice Telephony Lifeline Plans
<1221>
<1222>
<1223>
<1220>Link to Public Website HTTP
telephony service plans offered to Lifeline subscribers,
Details on the number of minutes provided as part of the plan,

http://www.directcom.com
Brian Lee
2017
[e-mail]
4722232id1210.pdf
DIRECT COMM-ROCKLAND
2085482345 ext.
4
4
4
472232
REDACTED - FOR PUBLIC INSPECTION
Page 15
Page 15
(2000) Price Cap Carrier Additional Documentation FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
Including Rate-of-Return Carriers affiliated with Price Cap Local Exchange Carriers July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

Incremental Connect America Phase I reporting
<2010> 2nd Year Certification 47 CFR § 54.313(b)(1)(i) - Note that for the July 1
2016 certification, this applies to Round 2 recipients of Incremental
Support

<2011> 3rd Year Certification 47 CFR § 54.313(b)(1)(ii) - Note that for the July 1
2016 certification, this applies to Round 1 recipients of Incremental
Support

<2022> Recipient certifies, representing year two after filing a notice of
acceptance of funding pursuant to 54.312(c), that the locations in
question are not receiving support under the Broadband Initiatives
Program or the Broadband Technology Opportunities Program for
projects that will provide broadband with speeds of at least 4
Mbps/1Mbps - 54.313(b)(2)(i). Round 2 recipients only.

<2023> The attachment on line 2024 includes a statement of the total amount of
capital funding expended in the previous year in meeting Connect
America Phase I deployment obligations, accompanied by a list of census
blocks indicating where funding was spent. This covers year two -
54.313(b)(2)(ii). Round 2 recipients only.

<2024A> Round 2 Recipient of Incremental Support?

<2024B> Attach list of census blocks indicating where funding was spent in year
two - 54.313(b)(2)(ii). Round 2 recipients only.
Name of Attached Document Listing
Required Information
<2025A> Round 1 or Round 2 Recipient of Incremental Support?
<2025B> Attach geocoded Information for Phase I milestone reports (Round 1 for
year three and Round 2 for year two) - Connect America Fund , WC Required Information
<2015> 2016 and future Frozen Support Certification 47 CFR § 54.313(c)(4)
Select the appropriate responses below (Yes, No, Not Applicable) to note compliance as a recipient of Incremental High Cost support, High Cost support to offset access charge reductions,
and Connect America Phase II support as set forth in 47 CFR § 54.313(b),(c),(d),(e). The information reported on this form and in the documents attached below is accurate.
Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
Page 16
(2000) Price Cap Carrier Additional Documentation (Continued)FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
Including Rate-of-Return Carriers affiliated with Price Cap Local Exchange Carriers July 2013
Price Cap Carrier Connect America ICC Support {47 CFR § 54.313(d)}
<2016> Certification support used to build broadband
Page 16
Connect America Phase II Reporting {47 CFR § 54.313(e)}
<2017A> Connect America Fund Phase II recipient?
<2017B> Attach information for Phase II - 54.313(e)(1) - list of geocoded locations
already meeting the 54.309 public interest obligations at the end of
calendar year 2015 and total amount of Phase II support, if any, the price
Required Information
institutions to which the carrier newly began providing access to Required Information

<2019> Recipient certifies that it bid on category one telecommunications and
Internet access services in response to all FCC Form 470 postings seeking
broadband service that meets the connectivity targets for the schools and
libraries universal service support program for eligible schools and
libraries located within any area in a census block where the carrier is
receiving Phase II model-based support, and that such bids were at rates
reasonably comparable to rates charged to eligible schools and libraries in
urban areas for comparable offerings - 54.313(e)(2)(v)

<2020> Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 40% of its supported locations
in the state on December 31, 2017 - 54.313(e)(3)

<2021> Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 60% of its supported locations
in the state on December 31, 2018 - 54.313(e)(4)

<2026>Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 80% of its supported locations
in the state on December 31, 2019 - 54.313(e)(5)

<2027>Recipient certifies that it offered broadband meeting the requisite public
interest obligations specified in §54.309 to 100% of its supported locations
in the state on December 31, 2020 - 54.313(e)(6)
REDACTED - FOR PUBLIC INSPECTION
<010> Study Area Code
<015> Study Area Name
<020> Program Year
<030> Contact Name - Person USAC should contact regarding this data
<035> Contact Telephone Number - Number of person identified in data line <030>
<039> Contact Email Address - Email Address of person identified in data line <030>

compliance with the financial reporting requirements set forth in 47 CFR § 54.313(f)(2). I further certify that the information reported on this form and in

§ 54.313(f)(2)}

Please check these boxes to confirm that the
attached PDF, on line 3017, contains the required
information pursuant to § 54.313(f)(2) compliance

(Operating Report for Telecommunications
and Statement of Cash Flows
If the response is yes on line 3014, attach your
company's RUS annual report and all required
documentation
Information
If the response is no on line 3014, is your company
audited?
If the response is yes on line 3018, please check the
boxes below to confirm your submission on line
3026 pursuant to § 54.313(f)(2), contains:

Either a copy of their audited financial statement; or
(2) a financial report in a format comparable to RUS
Operating Report for Telecommunications Borrowers
Document(s) for Balance Sheet, Income Statement
and Statement of Cash Flows
Management letter and/or audit opinion issued by
the independent certified public accountant that
performed the company’s financial audit.
If the response is no on line 3018, please check the
boxes below to confirm your submission on line
3026 pursuant to § 54.313(f)(2), contains:

Copy of their financial statement which has been
subject to review by an independent certified public
accountant; or 2) a financial report in a format
comparable to RUS Operating Report for
Telecommunications Borrowers

Underlying information subjected to a review by an
independent certified public accountant
certification.
and Statement of Cash Flows

page 17
(3005) Rate Of Return Carrier Additional Documentation FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
Page 17
4
Brian Lee
4
2017
[e-mail]
Yes - Attach Certification
472232id3010.pdf
DIRECT COMM-ROCKLAND
2085482345 ext.
472232id3017.pdf
472232
Not Applicable - No Attachment Required
REDACTED - FOR PUBLIC INSPECTION
LINE 3005 RATE OF RETURN DATA 

REDACTED FOR PUBLIC INSPECTION 

REDACTED - FOR PUBLIC INSPECTION

4005 Rural Broadband Experiment

community anchor institutions, and provide a list of locations where broadband has been deployed.
Public Interest Obligations – FCC 14-98 (paragraphs 26-29, 78)
4001
interest obligations consistent with the category for which they were selected, including broadband speed,
latency, usage capacity, and rates that are reasonably comparable to rates for comparable offerings in urban

Community Anchor Institutions – FCC 14-98 (paragraph 79)
4003a
which they newly deployed broadband service in the preceding calendar year. On this line, please respond
If yes to 4003A, please provide a response for 4003B.
4003b
of community anchor institutions to which the
recipient newly began providing access to

Broadband Deployment Locations – FCC 14-98 (paragraph 80)
4004a
which broadband has been deployed as of the
June 1st immediately preceding the July 1st filing

Name of Attached Document Listing Required Information

4004b
recipient is meeting the relevant public service
obligations for the identified locations. Materials
must at least detail the pricing, offered broadband
speed and data usage allowances available in the

Name of Attached Document Listing Required Information

FCC Form 481 (4005) Rural Broadband Experiment Additional Documentation OMB Control No. 3060-0986/OMB Control No. 3060-0819

Data Collection Form
July 2013

page 19
Page 19
Brian Lee
2017
[e-mail]
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
Page 20
Page 20
Certification - Reporting Carrier FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>
TO BE COMPLETED BY THE REPORTING CARRIER, IF THE REPORTING CARRIER IS FILING ANNUAL REPORTING ON ITS OWN BEHALF:
Printed name of Authorized Officer:
Certification of Officer as to the Accuracy of the Data Reported for the Annual Reporting for CAF or LI Recipients
Name of Reporting Carrier:
Signature of Authorized Officer:Date
I certify that I am an officer of the reporting carrier; my responsibilities include ensuring the accuracy of the annual reporting requirements for universal service support
recipients; and, to the best of my knowledge, the information reported on this form and in any attachments is accurate.
Title or position of Authorized Officer:
Telephone number of Authorized Officer:
Study Area Code of Reporting Carrier:Filing Due Date for this form:

Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C. § 1001.

CERTIFIED ONLINE
07/01/2016
2085482345 ext.
Brian Lee
Jeremy Smith
2017
06/21/2016
[e-mail]
DIRECT COMM-ROCKLAND
General Manager
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
472232
REDACTED - FOR PUBLIC INSPECTION
Page 21
Page 21
Certification - Agent / Carrier FCC Form 481Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

Certification of Agent Authorized to File Annual Reports for CAF or LI Recipients on Behalf of Reporting Carrier
TO BE COMPLETED BY THE AUTHORIZED AGENT:
Telephone number of Authorized Agent or Employee of Agent:
Signature of Authorized Agent or Employee of Agent:
Name of Authorized Agent Firm:
I, as agent for the reporting carrier, certify that I am authorized to submit the annual reports for universal service support recipients on behalf of the reporting carrier; I have provided
the data reported herein based on data provided by the reporting carrier; and, to the best of my knowledge, the information reported herein is accurate.
Date:
Name of Authorized Agent Employee:
TO BE COMPLETED BY THE REPORTING CARRIER, IF AN AGENT IS FILING ANNUAL REPORTS ON THE CARRIER'S BEHALF:
Certification of Officer to Authorize an Agent to File Annual Reports for CAF or LI Recipients on Behalf of Reporting Carrier
I certify that (Name of Agent)_______________________________________________________ is authorized to submit the information reported on behalf of the reporting carrier. I
also certify that I am an officer of the reporting carrier; my responsibilities include ensuring the accuracy of the annual data reporting requirements provided to the authorized
agent; and, to the best of my knowledge, the reports and data provided to the authorized agent is accurate.
Date:
Name of Authorized Agent:
Signature of Authorized Officer:

Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C. § 1001.
Persons willfully making false statements on this form can be punished by fine or forfeiture under the Communications Act of 1934, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment under Title
18 of the United States Code, 18 U.S.C. § 1001.

Brian Lee
2017
[e-mail]
ext.
ext.
DIRECT COMM-ROCKLAND
2085482345 ext.
472232
REDACTED - FOR PUBLIC INSPECTION
Attachments
REDACTED - FOR PUBLIC INSPECTION
LINE 112 – Five Year Service Quality Improvement Progress Report 
REDACTED FOR PUBLIC INSPECTION 
REDACTED - FOR PUBLIC INSPECTION
REDACTED - FOR PUBLIC INSPECTION
(700) Price Offerings including Voice Rate Data FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>
<701>Residential Local Service Charge Effective Date
<702>Single State-wide Residential Local Service Charge
<703>

State Exchange (ILEC)SAC (CETC)Rate Type
Residential Local
Service Rate

Total per line Rates and Fees
Mandatory Extended Area
Service ChargeState Universal Service FeeState Subscriber Line Charge

Brian Lee
1/1/2016
32.42
2017
[e-mail]
0.0208
DIRECT COMM-ROCKLAND
ID
2085482345 ext.
FR 6.525.76
472232
0.16
25.76
REDACTED - FOR PUBLIC INSPECTION
(710) Broadband Price Offerings FCC Form 481
Data Collection Form OMB Control No. 3060-0986/OMB Control No. 3060-0819
July 2013
<010>Study Area Code
<015>Study Area Name
<020>Program Year
<030>Contact Name - Person USAC should contact regarding this data
<035>Contact Telephone Number - Number of person identified in data line <030>
<039>Contact Email Address - Email Address of person identified in data line <030>

<711>
State Exchange Residential State Regulated Broadband Service -
Download Speed
(Mbps)

Other, No Rate Limit
Other, No Rate Limit
Other, No Rate Limit
Other, No Rate Limit
Other, No Rate Limit
Other, No Rate Limit
Other, No Rate Limit
Other, No Rate Limit
Brian Lee
ID
ID
ID
ID
ID
2017
ID
ID
ID
[e-mail]
999999
999999
999999
999999
999999
999999
999999
999999
208
208
208
208
208
208
208
208
DIRECT COMM-ROCKLAND
2085482345 ext.
99.95
199.95
49.95
39.95
79.95
69.95
69.95
59.95
100.0
39.95
1000.0
49.95
25.0
50.0
15.0
20.0
6.0
10.0
99.95
199.95
69.95
79.95
59.95
69.95
472232
100.0
50.0
25.0
5.0
2.0
1.0
1.0
1.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
REDACTED - FOR PUBLIC INSPECTION
REDACTED - FOR PUBLIC INSPECTION
REDACTED - FOR PUBLIC INSPECTION
REDACTED - FOR PUBLIC INSPECTION
REDACTED - FOR PUBLIC INSPECTION
LINE 3017– RUS Annual Report 
REDACTED FOR PUBLIC INSPECTION