[Federal Register Volume 70, Number 49 (Tuesday, March 15, 2005)]
[Rules and Regulations]
[Pages 12601-12605]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 05-5058]


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FEDERAL COMMUNICATIONS COMMISSION

47 CFR Chapter I

[CC Docket No. 02-53, FCC 05-32]


Presubscribed Interexchange Carrier Charges

AGENCY: Federal Communications Commission.

ACTION: Final rule.

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SUMMARY: This document revises the Commission's presubscribed 
interexchange carrier (PIC)-change charge policies. PIC-change charges 
are federally-tariffed charges imposed by incumbent local exchange 
carriers on end-user subscribers when these subscribers change their 
long distance carriers. The report and order requires incumbent local 
exchange carriers to

[[Page 12602]]

create separate PIC-change charges based on the method used to process 
the request. Based on cost information submitted in the record of the 
proceeding, the report and order adopts safe harbors below which PIC 
change charges will be considered reasonable. These safe harbors are 
$1.25 for electronically-processed PIC changes and $5.50 for manually-
processed PIC changes.

DATES: Effective April 14, 2005.

FOR FURTHER INFORMATION CONTACT: Jennifer McKee, Wireline Competition 
Bureau, Pricing Policy Division, (202) 418-1530, 
[email protected].

SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Report 
and Order in CC Docket No. 02-53 released on February 17, 2005. The 
full text of this document is available on the Commission's Electronic 
Comment Filing System Web site and for public inspection during regular 
business hours in the FCC Reference Center, Room CY-A257, 445 Twelfth 
Street, SW., Washington, DC 20554.

Paperwork Reduction Act Analysis

    This document does not contain new or modified information 
collection requirements subject to the Paperwork Reduction Act of 1995 
(PRA), Public Law 104-13. In addition, therefore, it does not contain 
any new or modified ``information collection burden for small business 
concerns with fewer than 25 employees,'' pursuant to the Small Business 
Paperwork Relief Act of 2002, Public Law 107-198. 44 U.S.C. 3506(c)(4).

Background

    In this Report and Order, adopted February 10, 2005 and released 
February 17, 2005 in CC Docket No. 02-53, FCC 05-32, the Commission 
revises its policies regarding the charge incumbent local exchange 
carriers (LECs) impose on customers when the customers change their 
long distance service provider. For incumbent LECs, these charges 
currently are subject to a $5 safe harbor within which a PIC change 
charge is considered reasonable. Significant industry and market 
changes have occurred since the implementation of the $5 safe harbor in 
1984; therefore, the Commission initiated this proceeding to reexamine 
the existing safe harbor for incumbent LEC PIC change charges. Based on 
the record in this proceeding, the Commission requires incumbent LECs 
to adopt separate PIC change charges for changes that are processed 
electronically and manually. The Commission adopts a safe harbor of 
$1.25 for electronically processed PIC changes, and a safe harbor of 
$5.50 for manually processed PIC changes.

Discussion

    As a threshold matter, we consider whether regulation of incumbent 
LEC PIC change charges is necessary at the current time. As discussed 
above, incumbent LECs assess PIC change charges on their end user 
customers that switch long distance service providers. Under the 
Commission's existing domestic common carrier regulations, incumbent 
LECs generally are treated as dominant carriers because the Commission 
has found that these carriers possess and are likely to be able to 
exercise market power. While we do believe that residential competition 
is growing, competition is not yet so ubiquitous to serve as a reliable 
constraint on PIC change charge rates. Thus, we find that, at this 
time, market forces cannot be relied upon to limit incumbent LEC PIC 
change charge rates.

PIC Change Charge Safe Harbors

    We do not require incumbent LECs to tariff PIC change charges based 
on individual incumbent LEC actual costs. Such a requirement would be 
unduly burdensome, both to the incumbent LECs that would now be 
required to compile and submit detailed cost information related to PIC 
changes, and to the Commission, which would have to expend scarce 
resources evaluating the multiple cost submissions. Instead, we find 
that adopting a safe harbor for the incumbent LEC PIC change charge has 
been a reasonable method of regulating the charge in the past, and use 
of this method continues to be a reasonable practice going forward. 
Under the safe harbor approach, incumbent LECs may tariff PIC change 
charge rates that are equal to or less than the safe harbor without 
having to provide detailed cost filings in support of the rates. 
Incumbent LECs are free, however, to submit cost showings if their 
costs exceed the safe harbor limit. We find that adoption of a safe 
harbor in this instance provides a reasonable proxy for incumbent LECs' 
PIC change costs, while allowing carriers the option of foregoing the 
submission of cost support if their rates are within the safe harbor 
limits.
    An examination of PIC change costs reveals a substantial difference 
between the costs of electronically processed PIC changes and PIC 
changes that require manual processing. The record in this proceeding 
further confirms that the costs of an electronically processed PIC 
change are substantially lower than the costs of PIC changes that must 
be processed manually. By allowing carriers to impose a single, blended 
PIC change charge, customers whose PIC changes are processed through 
the less costly electronic system are realizing no benefit from the use 
of these more efficient systems. They will be assessed the same charge 
as a customer whose PIC change is more complicated and requires costly 
manual processing. With no distinction in the rates between 
electronically processed and manually processed changes, long distance 
carriers lack an incentive to invest in the more efficient electronic 
systems, as there is no competitive benefit to doing so. Instead, we 
believe that both customers and long distance providers should reap the 
benefit of the long distance providers' investments in more efficient 
electronic processing capabilities. We therefore adopt separate safe 
harbors for incumbent LEC PIC changes that are processed manually and 
electronically. Adopting a two-tiered approach will provide an 
incentive for long distance providers to invest in electronic 
processing capabilities to gain the competitive advantage of lower 
incumbent LEC PIC change charges for customers switching to these long 
distance providers' services.
    We find that small and rural incumbent LECs should be subject to 
the same safe harbors for electronic and manual processing applicable 
to larger incumbent LECs. There is no evidence on the record that the 
costs for processing electronically submitted PIC changes are greater 
for small and rural incumbent LECs than for larger and non-rural 
incumbent LECs. Therefore we have no basis on which to establish a 
separate electronic PIC change safe harbor rate for these carriers. One 
carrier submitted cursory cost information regarding its costs to 
process manually submitted PIC changes, but this information from a 
single carrier was not sufficient evidence on which to base a separate 
small and rural incumbent LEC manual PIC change charge safe harbor. In 
any event, we note that, as discussed below, we are raising the current 
manual safe harbor rate for all incumbent LECs, including small and 
rural carriers. Finally, we note that prior to our decision in this 
report and order small and rural incumbent LECs have been subject to 
the same $5.00 safe harbor applicable to all other incumbent LECs. No 
small or rural carrier has submitted cost information seeking to 
increase this $5.00 charge. As has been the case since 1984, all 
carriers remain free to submit cost studies to justify a higher rate to 
the extent these

[[Page 12603]]

companies' costs exceed the safe harbors.
    We find that incumbent LECs without electronic PIC change 
capabilities may rely solely on a manual rate, subject to the manual 
safe harbor. We do not require any small or rural carrier to implement 
electronic PIC change processing systems if doing so would not be 
economically rational. To the extent small and rural incumbent LECs 
have electronic PIC change processing systems in place, we find that 
the separate electronic PIC change rate will provide an incentive for 
long distance providers to use this less costly manner of PIC change 
submission. Customers selecting long distance providers that employ 
electronic PIC change processing will be charged the incumbent LECs' 
tariffed lower electronic PIC change charge rates.

Costs Recovered in the PIC Change Charge

    We find that incumbent LECs should not recover PIC freeze or third-
party verification (TPV) costs through the PIC change charge. PIC 
freeze services are optional services offered by LECs to their 
customers. If LECs choose to offer a PIC freeze service, they should 
recover the costs from those customers requesting and using the 
service. If LECs are allowed to recover the costs of PIC freezes 
through the PIC change charge, customers that pay the PIC change charge 
are paying for the PIC freeze service for other customers. Customers 
that do not subscribe to the PIC freeze service are more likely to 
change their long distance providers and to pay the PIC change charge. 
It is unreasonable to require these customers to pay the costs of a PIC 
freeze service utilized by other customers. Therefore, we find that the 
costs associated with administering PIC freeze services cannot be 
recovered through the PIC change charge.
    We also find that the costs of TPV cannot be recovered through the 
PIC change charge. LECs are not required to conduct TPV under our rules 
unless a customer is switching to the service of the LECs' long 
distance affiliates (or from a competitive LEC to the LECs themselves 
for local service). To the extent TPV is used to verify a change to a 
LEC-affiliated carrier, LECs should not be allowed to recover these 
costs from customers switching to competing long distance providers. 
Instead, these costs should be recovered by the LEC from its affiliate. 
Similarly, LECs should not be allowed to increase the costs of PIC 
changes by including the costs of TPV processes that are voluntarily 
undertaken by the LECs. For example, a cost study submitted by Verizon 
in the record of this proceeding demonstrates that TPV costs represent 
approximately 12 percent of its manual processing costs. Allowing LECs 
to inflate the PIC change charge by recovering these voluntarily 
incurred costs may reduce customers' willingness to switch long 
distance providers, thereby hindering competition. Therefore, we find 
that incumbent LECs may not recover voluntarily-incurred TPV costs 
through the PIC change charge, and may recover mandatorily-incurred TPV 
costs only from customers that switch to the incumbent LECs' long 
distance affiliates.
    Some commenters also argue that costs related to ``slamming,'' 
which is an unauthorized change in a customer's long distance provider, 
should not be recovered through the PIC change charge. They contend 
that incumbent LECs have no legitimate role in investigating slamming 
complaints so there are no costs to be recovered. These commenters 
overlook the fact that customers may not be aware of the Commission's 
slamming complaint procedures and may contact the LECs for information 
about the process. Under the Commission's rules, if a customer notifies 
its LEC of an unauthorized change of its long distance provider, the 
LEC must notify both the authorized and the unauthorized long distance 
provider, and must also refer the customer to the appropriate 
regulatory authority for resolution of the complaint. Incumbent LECs do 
incur some small costs in carrying out these duties. In Verizon's cost 
study, for example, slamming inquiry costs represented only 
approximately $0.09 per PIC change, or approximately two percent of the 
total costs included in Verizon's PIC change costs. Because these costs 
are incurred legitimately by the LECs as part of implementation of 
customers' PIC selections; because, as represented by Verizon's cost 
study, these costs are slight; and because all customers benefit 
directly or indirectly from the LECs' diligence in investigating 
slamming complaints, we will allow incumbent LECs to spread these costs 
over all PIC change requests and recover them through the PIC change 
charge.
    We also find that incumbent LECs may recover a reasonable 
percentage of their common costs through the PIC change charge. SBC and 
Verizon argue that common costs, such as legal, executive, marketing, 
and other costs, are not incurred in relation to any specific service, 
but are required for LECs to provide all of the services they offer, 
including the PIC change service. Commenters have offered no 
justification for treating the PIC change service differently from 
other incumbent LEC services with respect to the inclusion of 
reasonable common costs.

Establishing Safe Harbor Rates

    To set the incumbent LEC electronic and manual PIC change charge 
safe harbors, we look to the cost information submitted in the record 
of this proceeding. There are three cost studies in the record: one 
filed by BellSouth in support of a change to its tariffed PIC change 
charge rate in November 2003; one filed by Verizon on June 15, 2004, in 
response to the Further Notice of Proposed Rulemaking in this 
proceeding; and one filed by SBC more than four months after the record 
closed, on November 4, 2004. BellSouth's cost information was not 
promulgated in response to the issues raised in this proceeding, and it 
does not provide as much detail in certain areas, such as PIC freeze 
costs, as does Verizon's cost study. Verizon's cost study provides the 
most detailed analysis of the costs it includes in its PIC change 
charge, including costs associated with PIC freezes and the TPV 
process. Commenters objecting to Verizon's cost study focus on costs 
that should be excluded from the PIC change charge and do not contest 
the actual amounts of the costs. SBC's cost study was submitted after 
the record closed and parties have not had an opportunity to comment on 
it. Furthermore, SBC's cost study does not provide a detailed analysis 
of the costs attributable to electronically processed PIC changes. We 
therefore rely on Verizon's cost study as the best record evidence to 
establish revised safe harbor rates.
    After removing costs that Verizon identifies as associated with PIC 
freezes and TPV, we adopt a safe harbor rate of $1.25 for 
electronically processed PIC changes and a safe harbor rate of $5.50 
for manually processed PIC changes. Verizon's cost study on which we 
base these safe harbor rates includes in its electronically processed 
PIC change costs the costs associated with electronically submitted 
change requests that ``fall out'' of the electronic system and require 
some manual handling. We therefore clarify that all PIC change requests 
that are submitted electronically by the long distance carrier will 
result in the incumbent LEC charging the end user the electronic PIC 
change charge rate, regardless of whether some manual processing is 
required.
    Incumbent LECs that process PIC change requests through electronic 
and manual methods must amend their tariffs to reflect separate rates 
for electronic and manual processing of PIC

[[Page 12604]]

changes. If an incumbent LEC's rates are at or below these safe 
harbors, the incumbent LEC is not required to file cost support for the 
rates. If an incumbent LEC wishes to demonstrate costs in excess of the 
safe harbor rates, it must file detailed cost support for its proposed 
rates. If at the time it filed its currently tariffed PIC change charge 
rate an incumbent LEC relied on cost data demonstrating that its costs 
are lower than the new safe harbor rates, the incumbent LEC may not 
increase its PIC change charge rates unless it files new cost support 
justifying the higher rates.

Multiple PIC Change Charges for Simultaneous Changes in Services

    Some commenters in the proceeding argue that LECs should not be 
able to assess multiple PIC change charges when customers change both 
their PIC and their intraLATA primary interexchange carrier (LPIC) at 
the same time. Two incumbent LEC commenters confirm that, when the 
changes are requested simultaneously, the costs are equal to the costs 
of a single change. Generally, incumbent LECs' PIC change charges are 
contained in their federal tariffs and LPIC change charges are 
contained in state tariffs. For purposes of the federally-tariffed PIC 
change charge, when customers change their PICs in conjunction with 
changing their LPICs, incumbent LECs should assess half of the 
applicable federally-tariffed PIC change charge. Carriers may recover 
their remaining costs through the state-tariffed LPIC change charges. 
We require incumbent LECs to amend their federal tariffs to include a 
rate that is 50 percent of the manual PIC change charge rate, and 
another rate that is 50 percent of the electronic PIC change charge 
rate, and the respective 50 percent rate will apply when a customer 
requests a PIC change simultaneously with an LPIC change.

Conclusion

    As discussed above, we require all incumbent LECs that process PIC 
change requests through electronic and manual methods to revise their 
tariffs to include one rate for PIC changes that are processed 
electronically and a separate rate for PIC changes that are processed 
manually. Rates that are within the safe harbors of $1.25 for 
electronically processed PIC changes and $5.50 for manually processed 
PIC changes may be filed without separate cost support. Rates in excess 
of these safe harbors must include appropriately detailed cost support 
justifying the rates. Incumbent LECs must also revise their tariffs to 
reflect a rate that is equal to 50 percent of the full PIC change 
charge rate when a customer requests a PIC change in conjunction with 
an LPIC change. These tariff revisions are to be filed on or before 
April 14, 2005.

Procedural Matters

Final Regulatory Flexibility Analysis

    As required by the Regulatory Flexibility Act of 1980, as amended 
(RFA), 5 U.S.C. 603, an Initial Regulatory Flexibility Analysis (IRFA) 
was incorporated in the Notice of Proposed Rulemaking, 67 FR 34665, May 
15, 2002, and the Further Notice of Proposed Rulemaking, 69 FR 29913, 
May 26, 2004. The Commission sought written public comment on the 
proposals in the Notice of Proposed Rulemaking and Further Notice of 
Proposed Rulemaking, including comment on the IRFA. This present Final 
Regulatory Flexibility Analysis (FRFA) conforms to the RFA. 5 U.S.C. 
604.
Need for, and Objectives of, the Report and Order
    PIC change charges are federally tariffed charges imposed by LECs 
on end user subscribers when these subscribers change their 
presubscribed long distance providers. The Commission in 1984 
established a safe harbor of $5 for PIC change charges of incumbent 
LECs, allowing carriers to set rates at or below the $5 safe harbor 
without the need for filing detailed cost support for the rates. 
Significant industry and market changes have occurred since the 
implementation of the $5 safe harbor in 1984; therefore, the Commission 
initiated this proceeding to reexamine the existing safe harbor for 
incumbent LEC PIC change charges. As discussed in paragraphs 0-0 of the 
report and order, incumbent LECs are required to adopt separate PIC 
change charges for changes that are processed electronically and 
manually. We adopt a safe harbor of $1.25 for electronically processed 
PIC changes, and a safe harbor of $5.50 for manually processed PIC 
changes. Also as discussed in paragraph 0, incumbent LECs must include 
in their federal tariffs a rate equal to 50 percent of the full PIC 
change charge rate when a customer requests a PIC change in conjunction 
with a change in its intraLATA presubscribed interexchange carrier 
(LPIC).
Summary of Significant Issues Raised by Public Comments in Response to 
the IRFA
    There were no comments filed that specifically addressed the rules 
and policies proposed in the IRFA.
Description and Estimate of the Number of Small Entities to Which the 
Proposed Rules Will Apply
    The RFA directs agencies to provide a description of, and, where 
feasible, an estimate of the number of small entities that may be 
affected by rules adopted herein. 5 U.S.C. 604(a)(3). The RFA generally 
defines the term ``small entity'' as having the same meaning as the 
terms ``small business,'' ``small organization,'' and ``small 
governmental jurisdiction.'' 5 U.S.C. 601(6). In addition, the term 
``small business'' has the same meaning as the term ``small business 
concern'' under the Small Business Act. 5 U.S.C. 601(3) (incorporating 
by reference the definition of ``small business concern'' in the Small 
Business Act, 15 U.S.C. 632). Pursuant to 5 U.S.C. 601(3), the 
statutory definition of a small business applies ``unless an agency, 
after consultation with the Office of Advocacy of the Small Business 
Administration and after opportunity for public comment, establishes 
one or more definitions of such term which are appropriate to the 
activities of the agency and publishes such definition(s) in the 
Federal Register.'' A ``small business concern'' is one that: (1) Is 
independently owned and operated; (2) is not dominant in its field of 
operation; and (3) satisfies any additional criteria established by the 
Small Business Administration (SBA). 15 U.S.C. 632.
    We have included small incumbent LECs in this present RFA analysis. 
As noted above, a ``small business'' under the RFA is one that, inter 
alia, meets the pertinent small business size standard (e.g., a 
telephone communications business having 1,500 or fewer employees), and 
``is not dominant in its field of operation.'' 15 U.S.C. 632. The SBA's 
Office of Advocacy contends that, for RFA purposes, small incumbent 
LECs are not dominant in their field of operation because any such 
dominance is not ``national'' in scope. Letter from Jere W. Glover, 
Chief Counsel for Advocacy, SBA, to William E. Kennard, Chairman, FCC 
(May 27, 1999). The Small Business Act contains a definition of ``small 
business concern,'' which the RFA incorporates into its own definition 
of ``small business.'' See 15 U.S.C. 632(a); 5 U.S.C. 601(3). SBA 
regulations interpret ``small business concern'' to include the concept 
of dominance on a national basis. 13 CFR 121.102(b). We have therefore 
included small incumbent LECs in this RFA analysis, although we 
emphasize that this RFA action has no effect on Commission analyses and 
determinations in other, non-RFA contexts.

[[Page 12605]]

    Wired Telecommunications Carriers. The SBA has developed a small 
business size standard for Wired Telecommunications Carriers, which 
consists of all such companies having 1,500 or fewer employees. 13 CFR 
121.201, NAICS code 517110. According to Census Bureau data for 1997, 
there were 2,225 firms in this category, total, that operated for the 
entire year. Of this total, 2,201 firms had employment of 999 or fewer 
employees, and an additional 24 firms had employment of 1,000 employees 
or more. Thus, under this size standard, the majority of firms can be 
considered small.
    Incumbent Local Exchange Carriers. Neither the Commission nor the 
SBA has developed a size standard for small businesses specifically 
applicable to incumbent local exchange carriers. The closest applicable 
size standard under SBA rules is for Wired Telecommunications Carriers. 
Under that size standard, such a business is small if it has 1,500 or 
fewer employees. 13 CFR 121.201, NAICS code 517110. According to 
Commission data, 1,310 carriers reported that they were incumbent local 
exchange service providers. Of these 1,310 carriers, an estimated 1,025 
have 1,500 or fewer employees and 285 have more than 1,500 employees. 
Consequently, the Commission estimates that most incumbent local 
exchange carriers are small entities that may be affected by the rules 
and policies adopted herein.
Description of Projected Reporting, Recordkeeping and Other Compliance 
Requirements for Small Entities
    All incumbent LECs, including those that are small entities, are 
now required to make revisions to their federal tariffs to implement 
our revised PIC change charge policies. To the extent their federal 
tariffs do not already reflect this, all incumbent LECs must file rates 
equal to 50 percent of the full PIC change charge rate when an end user 
customer requests a PIC change in conjunction with an LPIC change. 
Also, all incumbent LEC that are able to process PIC changes 
electronically must file separate rates for PIC changes that are 
processed manually and electronically. If the rates are within the safe 
harbor rates of $5.50 for manually processed changes and $1.25 for 
electronically processed changes, no cost support is required. For 
rates in excess of the safe harbor rates, incumbent LECs must file 
detailed cost information justifying the higher rates.
Steps Taken To Minimize Significant Economic Impact on Small Entities, 
and Significant Alternatives Considered
    The RFA requires an agency to describe any significant alternatives 
that it has considered in developing its approach, which may include 
the following four alternatives (among others): ``(1) The establishment 
of differing compliance or reporting requirements or timetables that 
take into account the resources available to small entities; (2) the 
clarification, consolidation, or simplification of compliance or 
reporting requirements under the rule for small entities; (3) the use 
of performance rather than design standards; and (4) an exemption from 
coverage of the rule, or any part thereof, for small entities.'' 5 
U.S.C. 603(c)(1)-(c)(4).
    Some commenters in this proceeding argue that incumbent LECs should 
be required to base their PIC change charges on their individual costs. 
As discussed in paragraph 10 of the report and order, we reject this 
approach as unduly burdensome on incumbent LECs, including any that may 
be small entities. Instead, adopting safe harbors for PIC change 
charges allows incumbent LECs to file rates without the burden of 
filing detailed cost support. Incumbent LECs still have the option of 
filing cost support if their PIC change costs exceed the safe harbor 
rates. As discussed in paragraphs 9-10 of the report and order, we 
decline to adopt a separate safe harbor rate for small and rural 
incumbent LECs. We note that prior to our decision in this order small 
and rural carriers have been subject to the same $5.00 safe harbor 
applicable to all other carriers. No small or rural carrier has 
submitted cost information seeking to increase this $5.00 charge. As 
has been the case since 1984, all carriers remain free to submit cost 
studies to justify a higher rate to the extent these companies' costs 
exceed the safe harbors. As discussed in paragraph 0, we do not require 
any small or rural carrier to implement electronic PIC change 
processing systems if doing so would not be economically rational.

Report to Congress

    The Commission will send a copy of this Report and Order, including 
this FRFA, in a report to be sent to Congress and the General 
Accounting Office pursuant to the Congressional Review Act. 5 U.S.C. 
801(a)(1)(A). In addition, the Commission will send a copy of the 
Report and Order, including the FRFA, to the Chief Counsel for Advocacy 
of the SBA. A copy of the Report and Order and FRFA (or summaries 
thereof) will also be published in the Federal Register. 5 U.S.C. 
604(b).

Ordering Clauses

    Accordingly, it is ordered that, pursuant to 4(i), 4(j), 201(b), 
203(a), 205, and 403 of the Communications Act of 1934, as amended, 47 
U.S.C. 154(i), 154(j), 201(b), 203(a), 205, and 403, all incumbent LECs 
that process PIC change requests through electronic and manual methods 
shall file revised rates, to include one rate for PIC changes that are 
processed electronically and a separate rate for PIC changes that are 
processed manually, and all incumbent LECs shall file revised rates 
equal to 50 percent of the full PIC change charge rate when a customer 
requests a PIC change in conjunction with an LPIC change, no later than 
April 14, 2005. These rates shall be effective on fifteen (15) days' 
notice.
    It is further ordered that the Commission's Consumer and 
Governmental Affairs Bureau, Reference Information Center, shall send a 
copy of this Report and Order, including the Final Regulatory 
Flexibility Analysis, to the Chief Counsel for Advocacy of the Small 
Business Administration.

Federal Communications Commission.
Marlene H. Dortch,
Secretary.
[FR Doc. 05-5058 Filed 3-14-05; 8:45 am]
BILLING CODE 6712-01-P