Rural Cellular Ass'n v. Federal Communications Commission

685 F.3d 1083, 401 U.S. App. D.C. 459, 56 Communications Reg. (P&F) 458, 2012 WL 2866314, 2012 U.S. App. LEXIS 14349
CourtCourt of Appeals for the D.C. Circuit
DecidedJuly 13, 2012
Docket11-1094
StatusPublished
Cited by9 cases

This text of 685 F.3d 1083 (Rural Cellular Ass'n v. Federal Communications Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rural Cellular Ass'n v. Federal Communications Commission, 685 F.3d 1083, 401 U.S. App. D.C. 459, 56 Communications Reg. (P&F) 458, 2012 WL 2866314, 2012 U.S. App. LEXIS 14349 (D.C. Cir. 2012).

Opinion

Opinion for the Court filed by Senior Circuit Judge GINSBURG.

GINSBURG, Senior Circuit Judge:

The Rural Cellular Association and the Universal Service for America Coalition (together the RCA) petition for review of an Order of the Federal Communications Commission amending the “interim cap rule,” which limits at 2008 levels the amount of support available to competitive eligible telecommunications carriers (CETCs) through the High-Cost Universal Service Support Program. In the order under review, the Commission amended the interim cap rule to provide that when a carrier relinquishes its status as an eligible communications carrier, the cap on the support available in that carrier’s state is reduced by the amount the relinquishing carrier would have received had it retained its status. The RCA argues the Order violates the Communications Act of 1934 as amended by the Telecommunications Act of 1996 (together the Act), violates the Commission’s regulations, and is arbitrary and capricious for failure to explain how it ensures the “sufficient” level of support for CETCs required by the Act. For the reasons set out in Part II, we deny the petition for review.

I. Background

Prior to the passage of the Telecommunications Act of 1996, the Commission used implicit subsidies to implement the mandate in the Communications Act of 1934 to “make available, so far as possible ... a rapid, efficient, Nation-wide, and world-wide wire and radio communication service with adequate facilities at reasonable charges,” 47 U.S.C. § 151. The Commission and state telephone regulators effected an implicit cross-subsidy by setting rates in rural areas below cost and setting rates in urban areas above cost. This system was unsustainable, however, in the competitive environment ushered in by the Telecommunications Act of 1996. The Congress therefore directed the Commission to replace the system of implicit subsidies with explicit ones, euphemistically referred to as “specific, predictable, and sufficient ... mechanisms to preserve and advance universal service.” 47 U.S.C. § 254(b)(5). The Commission established several such “mechanisms,” including the High-Cost Program at issue in this case. 47 C.F.R. § 54.101.

In order to fund the new explicit subsidies, the Congress required “every telecommunications carrier that provides interstate telecommunication services” to “contribute, on an equitable and nondiscriminatory basis” to those mechanisms. 47 U.S.C. § 254(d). The Commission has promulgated a series of regulations to implement this statutory mandate.

First, in order to calculate the costs of the High-Cost Program, the regulations require the Universal Service Administration Company (USAC), which runs the Program, to submit each quarter “its projections of demand for the federal universal support mechanisms” and “its projections of administrative expenses.” 47 C.F.R. § 54.709(a)(3). The Commission may approve or, within 14 days, may set aside the USAC’s projections and “set projections of demand and administrative expenses at amounts that the Commission determines will serve the public interest.” Id.

Second, in order to determine the aggregate amount to be collected from all telecommunications carriers, the regulations require the USAC to “calculate the quarterly contribution factor” based upon “the ratio of total projected quarterly expenses of the universal service support mechanisms to the total projected collected end- *1086 user interstate and international telecommunications revenues.” Id. § 54.709(a)(2). Each telecommunications carrier’s quarterly assessment is then determined by applying this contribution factor to that carrier’s end-user revenue. Should contributions for a particular quarter exceed the disbursements plus the USAC’s administrative costs for that quarter, the “excess payments will be carried forward,” thereby reducing the contribution factor for the subsequent quarter. Id. § 54.709(b).

Section 254(e) of the Act provides universal service support may be disbursed only to an “eligible telecommunications carrier.” 47 U.S.C. § 254(e). Both an incumbent local exchange carrier (ILEC) and a new market entrant may receive universal service support upon being designated an ETC by the Commission or by a state regulator. The amount of support going to an ILEC is indexed to a portion of its total costs of serving the relevant area. 47 C.F.R. § 54.301. The amount of support available to a CETC, before the changes at issue in this case, was calculated according to the “identical support rule”: The per-line costs of the ILEC in the area were multiplied by the number of lines the CETC had in service. 47 C.F.R. § 54.307(a)(1).

The Commission adopted the identical support rule for ease of administration, Fed.-State Joint Bd. on Universal Serv., 17 FCC Red. 22,642, ¶7 (2002), but the result was an explosive growth in universal support disbursements to CETCs through the High-Cost Program. Total disbursements through the Program increased to $4.3 billion in 2007 from $2.6 billion in 2001, while disbursements to CETCs alone increased to $1.18 billion from a mere $17 million.

Several factors contributed to this dramatic increase. First, to the extent consumers kept their wireline service provided by the ILEC when they purchased wireless service from a CETC, the increase in support to the CETC was not offset by a decrease in support to the ILEC. Second, although many consumers did give up their wireline service, a decrease in the number of lines serviced by an ILEC does not decrease the ILEC’s cost proportionally because the provision of wireline services involves very large fixed and relatively small variable per-line costs; hence, the ILEC’s cost-per-line increases as it loses customers. Under the identical support rule, this increased the support-per-line for a CETC even as the number of lines it had in service increased and its costs per-line went down. Third, because the identical support rule provided support to CETCs on the basis of the number of lines they had in service, regardless of the cost of providing those lines, the rule amplified a CETC’s incentive to increase the number of its lines in areas it could serve at the least cost rather than to expand service into the more costly and therefore more needful areas.

In May 2008 the Commission adopted an “interim, emergency cap” on universal service support payments to CETCs through the High-Cost Program. High Cost Universal Support, 23 FCC Red. 8834, 8834 (2008) (hereinafter the Interim Cap Order ). The Interim Cap Order limited “total annual [CETC] support for each state ...

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Bluebook (online)
685 F.3d 1083, 401 U.S. App. D.C. 459, 56 Communications Reg. (P&F) 458, 2012 WL 2866314, 2012 U.S. App. LEXIS 14349, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rural-cellular-assn-v-federal-communications-commission-cadc-2012.