20161221CenturyLink CAF Update.pdf

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December 21 , 2016
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
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James B. Farr
Regulatory Affairs Director -Idaho and Utah
Room 1601
250 Bell Plaza
Salt Lake City, Utah 84111
Office: 801 -238-0240
jam [e-mail]
RE: FCC Rule 54.312(c)(4) & (5) Certification of Centurylink; Connect America Fund,
WC Docket No. 10-90
Dear Ms. Jewell:
On September 13, 2016 pursuant to Federal Communications Commission (FCC) rules, 1 Centurylink, on
behalf of its incumbent local exchange carriers receiving 2013 Connect America Fund Phase I incremental
support (CAF I Round 2 support) provided notice to the FCC of its intent to use that support for broadband
deployment in census blocks that it had not previously identified.2
Since that time, certain parties asserted that they serve all or a portion of 4 of the newly identified census
blocks in Idaho. Centurylink has now removed these census blocks from its CAF I Round 2 deployment
plans. Centurylink provided a full list of removed census blocks and the required certification in a letter to
the FCC on December 19, 2016.
By this letter, Centurylink is providing the Idaho Public Utilities Commission a copy of the letter and
certification from its FCC filing and a list of the removed census blocks in Idaho.
If you have any questions, please let me know.
Sincerel y,
1 47 C.F.R. § 54.312(c)(4).
2 Centurylink also provided notice of these additional census blocks to the Commission in a letter dated
September 15, 2016.
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ViaECFS
December 19, 2016
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 lih Street, S.W.
Washington, DC 20554
Jeffrey S. Lanning
Vice President -Federal Regulatory Affairs
1099 New York Avenue NW
Suite 250
Washington, DC 20001
202-429-3113
[e-mail]
Re: Rule 54.312(c)(4) & (5) Certification of CenturyLink; Connect
America Fund, WC Docket No.10-90
Dear Ms. Dortch:
On September 13, 2016, pursuant to Commission Rule 54.312(c)(4), 1 CenturyLink, on behalf of
its incumbent local exchange carriers receiving 2013 Connect America Fund Phase I incremental
support (CAF I Round 2 support) provided notice of its intent to use that support for broadband
deployment in 9703 census blocks that it had not previously identified.2
Since filing that notice, 44 parties asserted that they serve all or a portion of 1849 of the newly
identified census blocks. CenturyLink has removed these census blocks from its CAF I Round 2
3 deployment plans.
1 47 C.F.R. §54.312(c)(4). This rule may not be in effect in so far as it seems the FCC has
neither sought nor obtained Paperwork Reduction Act (PRA) approval for the rule or announced
an effective date for the rule. See 79 Fed. Reg. 34639 (June 18, 2014) (announcing PRA
approval and an effective date for certain information collection requirements including those
contained in 47 C.F.R. §54.312(b)(3) which addresses the notice requirement for CAF I
incremental support awarded in 2012 (Round I support), but without referencing the similar
information collection requirements contained in 47 C.F.R. §54.312(c)(4) for Round 2 support).
CenturyLink is providing this certification without conceding that the rule is in effect or that the
certification is required.
2 See letter from Jeffrey S. Lanning (CenturyLink), to Marlene H. Dortch (FCC), WC Docket
No. 10-90 (Sep. 13, 2016). A copy of the submission to the FCC was also served on USAC on
Sep. 13, 2016.
3 Attachment 2 to this letter is a complete list of the census blocks that CenturyLink is removing
from its CAF I Round 2 census blocks as a result of the served census block notifications.
Ms. Marlene H. Dortch
December 19, 2016
Page 2
In accord with Rule 54.312( c )( 4 ), Century Link is providing the attached certification.4
CenturyLink is uploading this letter, certification and the list in PDF format in WC Docket No.
10-90 via ECFS, and also providing a copy of the cover letter and certification (PDF format), and
the list (Excel format) via electronic mail to the Wireline Competition Bureau staff persons
identified below.
Copies of this letter and its attachments are also being sent to the Universal Service
Administrative Company (with the list in both PDF and Excel formats), relevant state
commissions, and affected Tribal governments.
Please contact me with any questions regarding this filing.
Sincerely,
Isl Jeffrey S. Lanning
Enclosures
cc (via e-mail): Heidi Lankau
Carol Mattey
Alex Minard
4 The certification is Attachment 1 to this letter. The certification language has been modified
from the precise language of Rule 54.312(c)(5) to accommodate the timing of the certification
and the manner in which CenturyLink develops its capital deployment activities generally, and
has done so for this program in particular.
Attachment I
Certification for CcnturyLink's Rule 54.312(c)(4) Notice
Connect America Fuml, WC Docket No. 10-90
In accord with 47 C.F.R. § 54.312(c)(4) & (5), with respect to CenturyLink's broadband
deployment activity in the additional census blocks identified by CenturyLink on September 13,
2016, for CAF I Round 2 deployment, and as modified by removal of the census blocks
subsequently identified by other broadband providers as served, the undersigned certifies that
(1) the locations to be served to satisfy the CAF I Round 2 deployment obligation are not
shown as served by fixed broadband at either 768/200 kbps or 3 Mbps/768kbps as appropriate
other than by Century Link entities on the June 30, 2014 version of the National Broadband Map;
(2) to the best of Century Link's knowledge, the locations were as of its acceptance of Round
2 support, in fact, unserved by fixed Internet access with speeds of at Least 3 Mbps downstream
and 768 kbps upstream, or 768 kbps downstream and 200 kbps upstream, as appropriate;
(3) CentmyLink did not have pre-existing investment plans to complete broadband
deployment during the term of the CAF I Round 2 program to the locations to be counted to
satisfy the CAF I Round 2 deployment obligation, and CenturyLink would not be deploying or
have deployed service at 4/1 Mbps to these locations were it not for its participation in the CAF I
Round 2 program;
(4) the CAF I Round 2 support has not and will not be used to satisfy any merger
commitment or similar regulatory obligation; and
(5) Century Link has undertaken due diligence to determine that the locations in question are
not within the service area of either Broadband Initiatives Program or the Broadband Technology
Opportunities Program projects that will provide Internet access with speeds of at least 3 Mbps
downstream and 768 upstream.
Sincerely,
Brian Butram
Vice President, Network Planning
Century Link
Census Blocks Removed From Centurylink CAF I Round 2 Census Blocks
State Census Block $550 Locations $775 Locations
ID 160399601003093 0 1
ID 160399601003217 1 0
ID 160399601003242 1 0
ID 160399601003248 3 0
ID Total 4 5 1