Step 5 File Line Counts

Line count data is used in the High Cost Program to calculate support amounts for both incumbent carriers and competitive carriers. USAC received quarterly line count filings from carriers via the FCC Form 525. As of January 1, 2012, carriers are no longer required to file line counts due to FCC 11-161, effective December 29, 2011.

For price cap carriers (and their rate-of-return affiliates), High Cost Program support amounts were frozen  at December 31, 2011, levels. High Cost Model support, Interstate Access Support, and frozen-rate Interstate Common Line Support (ICLS) are eliminated.

Legacy Line Count Filing

Competitive eligible telecommunications carriers (CETCs) previously filed line count data quarterly, as indicated in the table below.

Component	Line Counts Due	For Period Covering
HCL, SNA, SVS, LSS, HCM, ICLS	March 30 Quarterly line counts as of September 30 of the previous year July 31 Quarterly line counts as of December 31 of the previous year September 30 Quarterly line counts as of March 31 of the same year December 30 Quarterly line counts as of June 30 of the same year
IAS (due on last business day)	March Quarterly line counts as of December 31 of the previous year June Quarterly line counts as of March 31 of the same year September Quarterly line counts as of June 30 of the same year December Quarterly line counts as of September 30 of the same year

Rural Carriers
With the exception of Interstate Access Support (IAS), rural ILECs must submit line count information at the study area level or consistent with the Disaggregation Plan that was adopted pursuant to the FCC's Rural Task Force Order. Rural ILECs located in service areas where a competitive ETC has initiated service and reported line count data must update the line count data on a quarterly basis. Rural ILECs without competition may voluntarily submit updated quarterly information.

Non-Rural Carriers
Non-rural ILECs are required to submit updated line count data at the wire center-level on a quarterly basis. High Cost Model support is calculated and distributed at the wire center-level.

Competitive Carriers
Competitive eligible telecommunications carriers (CETCs) must file line count data in the same manner as the ILEC in whose service area the CETC competes.

IAS Line Count Information
A carrier must file the number of lines served within each price cap local exchange carrier study area that it serves. The line counts must be submitted at the Unbundled Network Element (UNE) zone level if UNE zones have been established within the study area. Residential/single-line business and multi-line business line counts must be shown separately.

ICLS Line Count Information
CETCs must file line count information for each ILEC study area by customer class (residential/single-line business and multi-line business) on a quarterly basis. CETCs must file line counts as of:

• September 30 of the preceding year by March 30,
• March 31 of the present year by September 30,
• June 30 of the present year by December 30, and
• December 31 by July 31.

Rate-of-return incumbent carriers located in study areas where a CETC has initiated service and reported line count data have additional line count filing requirements. These incumbent carriers must also file line counts as of September 30 of the preceding year on March 30 − as of March 31 of the present year on September 30, and as of June 30 of the present year on December 30. Rate-of-return incumbent carriers located in study areas where there is not a CETC that has initiated service and reported line count data may voluntarily elect to submit updated quarterly line counts in accordance with the schedule above. CETCs must file quarterly line count reports according to the same schedule.

FCC Requirements

In FCC Report and Order 07-150, the Commission clarified document retention requirements for High Cost Program beneficiaries. Recipients of universal service support for high-cost providers and their agents to retain all records that demonstrate to auditors the support they received was consistent with the Commission's rules, assuming that audits are conducted within five years of disbursement of such support.

These records should include without limitation, the following; data supporting line count filings, historical customer records, fixed asset property accounting records, general ledgers, invoice copies for the purchase and maintenance of equipment, maintenance contracts for the upgrade or equipment, and any other relevant documentation.

The Order states, "Beneficiaries must make available all such documents and records that pertain to them, including those of NECA, contractors, and consultants working on behalf of the beneficiaries to the Commission's OIG, to the USF Administrator, and to their auditors."

Please note that the Order also states, "[...] To the extent other rules or any other law require or necessitate documents be kept for longer periods of time (e.g., to support the account balances in the Part 32 Uniform System of Accounts, continuing property records, pole attachment calculations, plant equipment age, cost, or useful life, depreciation rates)," the Commission "[did] not alter, amend, or supplant such rule or law. High Cost Program recipients must keep documents for such longer periods of time as required or necessary under such other rules or law and make such documents available to the Commission and USAC."

This Report and Order became effective 30 days after it was published in the Federal Register, January 31, 2008, pp. 5843-5.