The FCC’s Wireline Competition Bureau (“WCB”) set December 15, 2014, as the deadline for responding to the special access mandatory data collection. The WCB also revised the mandatory data collection based on concerns raised by the Office of Management and Budget (“OMB”).
The Data Collection remains mandatory for “Providers” and “Purchasers” of Dedicated Services that hold licenses, authorizations or registrations under the FCC’s rules. The instructions include interconnected and non-interconnected VoIP providers in the list of Purchasers that are required to respond to the data collection. OMB approval, however, adds an exemption for Purchasers who procured less than $5 million of Dedicated Services in 2013 in price cap ILEC territories.
Dedicated Services transport data between two or more points at a rate of at least 1.5 Mbps in both directions with prescribed performance requirements. Examples of Dedicated Services include DS1, DS3, and OCn services; Multi-Protocol Label Switched (MPLS) services; permanent virtual circuits, virtual private lines and similar services; ATM and Frame Relay service; (Gigabit) Ethernet Services and Metro Ethernet Virtual Connections; and Virtual Private Networks (VPN).
While Purchasers above the $5 million threshold must respond to certain questions about Dedicated Services (both circuit- and packet-based) they purchased from competitive and incumbent providers in 2013, the OMB approval converts some questions from mandatory to optional.