**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | *  | File No. EB-03-TC-121        |
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| CenturyTel, Inc.                 | ** | NAL Acct. No. 200632170001   |
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| Compliance with the Commission's | *  | FRN: 0003740651              |
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| Rules and Regulations Governing  | ** |                              |
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| Advertising the Availability of  | *  |                              |
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| Link-Up                          |    |                              |
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**ORDER**

**Adopted: November 17, 2005 Released: November 22, 2005**

By the Chief, Enforcement Bureau:

1.  In this Order, we adopt the attached Consent Decree entered into
    between the Enforcement Bureau and CenturyTel, Inc. ("CenturyTel").
    The Consent Decree terminates an investigation initiated by the
    Enforcement Bureau regarding CenturyTel's compliance with section
    214(e)(1)(B) of the Communications Act of 1934, as amended (the
    "Act"), and sections 54.405(b) and 54.411(d) of the Commission's
    rules,[^1] as it relates to the duty to publicize Lifeline and
    Link-Up programs to low-income residents on tribal lands.

2.  The Enforcement Bureau and CenturyTel have negotiated the terms of a
    Consent Decree that would resolve this matter and terminate the
    investigation. A copy of the Consent Decree is attached hereto and
    incorporated by reference.

3.  After reviewing the terms of the Consent Decree, we find that the
    public interest would be served by adopting the Consent Decree and
    terminating the investigation. We also conclude that, in the absence
    of material new information not previously disclosed to the Bureau,
    the matters raised in the investigation do not raise any substantial
    and material questions of fact regarding CenturyTel's qualifications
    to be a Commission licensee.

4.  Accordingly, **IT IS ORDERED**, pursuant to Section 4(i) of the
    Communications Act of 1934, as amended,[^2] and the authority
    delegated by sections 0.111 and 0.311 of the Commission's rules,[^3]
    that the attached Consent Decree **IS ADOPTED**.

5.  **IT IS FURTHER ORDERED** that the above-captioned investigation
    **IS TERMINATED**.

FEDERAL COMMUNICATIONS COMMISSION

Kris Anne Monteith

Chief, Enforcement Bureau

**Before the**

**FEDERAL COMMUNICATIONS COMMISSION**

**Washington, D.C. 20554**

In the Matter of )

)

CenturyTel, Inc. ) File No. EB-03-TC-121

) NAL Acct. No. 200632170001

Compliance with the Commission's ) FRN: 0003740651

Rules and Regulations Governing )

Advertising the Availability of Lifeline and )

Link-Up )

**CONSENT DECREE**

**I. INTRODUCTION**

1.  The Enforcement Bureau ("Bureau") of the Federal Communications
    Commission (the "FCC" or "Commission") and CenturyTel, Inc.
    ("CenturyTel"), by their authorized representatives, hereby enter
    into this Consent Decree for the purpose of terminating the Bureau's
    investigation (the "Investigation") regarding CenturyTel's
    compliance with section 214(e)(1)(B) of the Communications Act of
    1934, as amended (the "Act"), and sections 54.405(b) and 54.411(d)
    of the Commission's rules,[^4] as it relates to the duty to
    publicize Lifeline and Link-Up programs to low-income residents on
    tribal lands.

**II. BACKGROUND**

2\. CenturyTel is an eligible telecommunications carrier ("ETC"),
*i.e.,* a telephone company eligible to receive universal service
support under section 214 of the Act.[^5] CenturyTel serves numerous
tribal lands in the 22-state area in which it operates as an incumbent
Local Exchange Carrier.

3\. The Bureau sent a Letter of Inquiry ("LOI") to CenturyTel on October
7, 2003,[^6] stating that it was investigating whether CenturyTel was
satisfying its obligations under sections 54.405(b) and 54.411(d) of the
Commission's rules to publicize the availability of Lifeline and Link-Up
services to low-income residents on tribal lands "in a manner reasonably
designed to reach those likely to qualify" for those services. The
Bureau sent a supplemental LOI on April 6, 2004.[^7] The LOIs directed
CenturyTel to describe actions it had taken to satisfy sections
54.405(b) and 54.411(d) of the Commission's rules and to support its
responses with pertinent documentation and affidavits.

4\. During the course of the Investigation, CenturyTel provided written
responses to the LOIs on November 17, 2003,[^8] and April 26, 2004.[^9]
After meeting with representatives of CenturyTel on October 28, 2004,
the Bureau sent a follow-up letter on November 9, 2004.[^10] CenturyTel
provided supplemental responses on November 19, 2004,[^11] January 14,
2005,[^12] and January 26, 2005.[^13] In recent meetings with the
Bureau, CenturyTel stated that it provides Lifeline and Link-Up services
to low-income residents on tribal lands in 12 states within its 22-state
incumbent region. CenturyTel asserted that it conducted outreach to
low-income residents on tribal lands within its region and provided some
evidence to support its contention.[^14]

**III. DEFINITIONS**

5\. For purposes of this Consent Decree, the following definitions shall
apply:

a.  "Act" means the Communications Act of 1934, as amended.

b.  "Bureau" means the Enforcement Bureau of the Federal Communications
    Commission.

c.  "CenturyTel" means CenturyTel, Inc. and any affiliate, d/b/a,
    predecessor-in-interest, parent companies and any direct or indirect
    subsidiaries of such parent companies, or other affiliated companies
    or businesses and their successors and assigns.

d.  "CenturyTel Tribal Land" means that portion of the tribal land
    described in the Commission's report, "Telephone Subscribership on
    American Indian Reservations and Off-Reservation Trust Lands,"
    released May 2003, and any subsequent such report, for which
    CenturyTel is an ETC.

e.  "Commission" means the Federal Communications Commission.

f.  "Effective Date" means fourteen (14) days from the date on which the
    Bureau releases the Adopting Order.

g.  "Investigation" means the investigation commenced by the Bureau's
    Letter of Inquiry, dated October 7, 2003, to CenturyTel regarding
    CenturyTel's possible noncompliance with section 214(e)(1)(B) of the
    Act and sections 54.405(b) and 54.411(d) of the Commission's rules
    and possible noncompliance with the Bureau's directives in the
    October 7, 2003 and April 6, 2004 LOIs.

h.  "Order" or "Adopting Order" means an Order of the Bureau adopting
    the terms and conditions of this Consent Decree without change,
    addition, or modification, and formally terminating the
    above-captioned Investigation.

i.  "Parties" means CenturyTel and the Bureau.

j.  "CenturyTel's Field Team" means Area Supervisors, Public Relations
    Managers and Area Operations Managers responsible for Lifeline and
    Link-Up outreach to their respective CenturyTel Tribal Land. Each
    CenturyTel Field Team member will report directly to CenturyTel's
    External Communications Manager regarding all Lifeline and Link-Up
    outreach efforts.

**IV. AGREEMENT**

6.  CenturyTel agrees that the Commission and its delegated authority,
    the Bureau, have jurisdiction over it and the subject matter
    contained in this Consent Decree and the authority to enter into and
    adopt this Consent Decree.

7\. The Parties agree and acknowledge that this Consent Decree shall
constitute a final settlement of the Investigation. In express reliance
on the covenants and representations contained herein, and to avoid the
potential expenditure of additional public resources, the Bureau agrees
to terminate the Investigation. In consideration for the termination of
this Investigation and in accordance with the terms of this Consent
Decree, CenturyTel agrees to the terms, conditions, and procedures
contained herein.

8\. The Parties agree that this Consent Decree does not constitute
either an adjudication on the merits or a factual or legal finding or
determination regarding any compliance or noncompliance by CenturyTel
with the requirements of the Act or the Commission's rules or orders.
The Parties agree that this Consent Decree is for settlement purposes
only.

9\. In consideration for the termination of the Investigation in
accordance with the terms of this Consent Decree, CenturyTel agrees to
make a voluntary contribution to the United States Treasury, without
further protest or recourse to a trial *de novo*, in the amount of
seventy-five thousand dollars (\$75,000) within thirty (30) days after
the Effective Date. The payment must be made by check or similar
instrument, payable to the order of the Federal Communications
Commission. The payment must include the Acct. No. and FRN No.
referenced above. Payment by check or money order may be mailed to
Forfeiture Collection Section, Finance Branch, Federal Communications
Commission, P.O. Box 73482, Chicago, IL, 60673-7482. Payment by
overnight mail may be sent to Bank One/LB 73482, 525 West Monroe, 8th
Floor Mailroom, Chicago, IL 60661. Payment by wire transfer may be made
to ABA Number 071000013, receiving bank Bank One, and account number
1165259.

10\. To resolve and terminate the Investigation, and to ensure
compliance with the Commission's Lifeline and Link-Up outreach rules,
CenturyTel agrees to implement a Lifeline and Link-Up Outreach Plan to
low-income residents on CenturyTel Tribal Lands, that CenturyTel has
identified in submissions to the Bureau, consisting of the components
delineated below in paragraphs 10 through 13. In the event that, after
the Effective Date, CenturyTel becomes an ETC on at least a portion of a
tribal land appearing in the Commission's report, "Telephone
Subscribership on American Indian Reservations and Off-Reservation Trust
Lands," released May 2003, and any subsequent such report, it shall
extend the outreach programs described herein to those portions of the
newly served tribal lands and such areas shall become CenturyTel Tribal
Lands for the remainder of the duration of this Consent Decree. In the
event that, after the Effective Date, CenturyTel ceases to be an ETC in
any portion of the CenturyTel Tribal Lands, such areas shall cease to be
CenturyTel Tribal Lands as of the date on which CenturyTel\'s ETC
designation ceased to be effective. In either case, CenturyTel will
notify the Bureau of the addition to or deletion from the CenturyTel
Tribal Lands, and provide a map or other description of such area and
the affected American Indian Reservations or Off-Reservation Trust Lands
affected.

A. [Individual Tribal Outreach]{.underline}

i)  [Individualized Tribal Plans]{.underline}. CenturyTel will develop
    and submit to the Bureau an individualized Lifeline and Link-Up
    outreach plan for each CenturyTel Tribal Land not later than three
    months after the Effective Date. These individualized outreach plans
    will incorporate various types of outreach efforts designed to reach
    that specific tribe in the most effective manner and will consist of
    at least some of the specific outreach efforts, in CenturyTel's
    judgment most likely to be effective, described in paragraphs
    10(A)(iii) through 10(A)(vii) below. The outreach efforts to be
    incorporated into the individualized tribal plans will be determined
    by CenturyTel personnel within the state who have experience with
    the specific tribes. CenturyTel will also make good faith efforts to
    work in conjunction with tribal liaisons, described in paragraph
    10(A)(ii) below, to develop the outreach plan for their particular
    tribe.

ii) [Tribal Liaisons]{.underline}. CenturyTel will make good faith
    efforts to identify and contact tribal liaisons for all CenturyTel
    Tribal Lands not later than thirty days after the Effective Date.
    Efforts to contact the various tribal liaisons may include in-person
    visits, direct mail, and/or telephone contact. CenturyTel's Field
    Team will confer with the tribal liaisons in order to determine the
    most effective outreach efforts to publicize Lifeline and Link-Up to
    their particular tribe. CenturyTel will also provide tribal liaisons
    with Lifeline and Link-Up posters, flyers, and applications that
    they can distribute to members of their tribe. CenturyTel will
    notify the FCC's Enforcement Bureau and the Consumer and
    Governmental Affairs Bureau of any CenturyTel Tribal Land that
    CenturyTel is unsuccessful in contacting.

iii) [Distribution of Individualized Materials]{.underline}. CenturyTel
     will conduct personal outreach to inform residents living on
     CenturyTel Tribal Lands about the availability of Lifeline and
     Link-Up. CenturyTel will work with tribal liaisons to obtain the
     names and/or location information for tribal residents for tribes
     that provide a list of residents. CenturyTel will distribute
     individualized materials directly to the identified residents on
     CenturyTel Tribal Lands once a year. These materials will clearly
     explain the application procedures and eligibility criteria to
     receive Lifeline and Link-Up services. Where tribal liaisons do not
     provide specific names of tribal members and how they can be
     reached, CenturyTel will not be responsible for making personal
     contact. The personal outreach will be conducted within thirty days
     of receiving a list from the tribal liaisons.

iv) [Public Service Announcements]{.underline}. CenturyTel will
    distribute public service announcements ("PSAs") to radio stations
    that reach CenturyTel Tribal Lands. The PSAs will include a
    CenturyTel customer service telephone number staffed by trained
    customer service representatives who can help interested customers
    apply for the Lifeline and Link-Up programs. These PSAs will be
    disseminated four times a year and will clearly describe both the
    Enhanced and the non-Enhanced Lifeline and Link-Up programs and the
    availability of such programs to those living on tribal lands.

v)  [Newspaper Advertisements]{.underline}. CenturyTel will identify
    tribal newspapers serving CenturyTel Tribal Lands. CenturyTel will
    place paid advertisements in these tribal newspapers twice yearly.
    All advertisements will specifically mention both the Enhanced and
    the non-Enhanced Lifeline and Link-Up programs and provide further
    information on eligibility criteria and application instructions.

vi) [Press Releases]{.underline}. CenturyTel will send newspapers
    in-depth press releases that contain information about both the
    Enhanced and the non-Enhanced Lifeline and Link-Up services offered
    by CenturyTel, eligibility criteria and application instructions.
    These press releases will be sent to the tribal newspapers
    identified in 10 (A)(v) above two times a year.

vii) [Social Service Agencies]{.underline}. CenturyTel will make good
     faith efforts to identify social service agencies that provide
     outreach to tribal residents on CenturyTel Tribal Lands not later
     than two months after the Effective Date. Not later than three
     months after the Effective Date, CenturyTel will provide printed
     posters, flyers, and applications to these social service agencies
     for dissemination to those interested in learning more about both
     the Enhanced and the non-Enhanced Lifeline and Link-Up programs.
     Twice yearly, the social service agencies will receive either a
     personal visit, telephone call or an explanatory letter that
     describes the programs in detail, including eligibility criteria
     and applications instructions.

B. [Service-Area Wide Outreach]{.underline}

In addition to the outreach efforts described in paragraph 10(A) above,
CenturyTel will take each of the following steps to publicize the
Lifeline and Link-Up programs to all CenturyTel Tribal Lands.

> i\) [Training]{.underline}. CenturyTel will provide training materials
> to all appropriate employees, as determined by the CenturyTel Field
> Team, in CenturyTel Tribal Lands at least once yearly. The training
> materials will clearly explain the importance of the programs,
> eligibility criteria and application instructions. These training
> materials will also be integrated into present Lifeline and Link-Up
> information in all customer service representatives' handbooks.
>
> ii\) [Bill Messages]{.underline}. CenturyTel will continue to publish
> Lifeline and Link-Up bill messages on a twice yearly basis. The bill
> messages will alert existing customers about the opportunity to
> receive help with their phone bills if they meet the eligibility
> requirements. The bill messages will also promote "word of mouth"
> advertising aimed at reaching those residents without telephone
> service. This "word of mouth" advertising should encourage existing
> customers to tell a friend, neighbor or family member without
> telephone service about Lifeline and Link-Up. CenturyTel will also
> publish similar "word of mouth" ads or messages in all of the
> telephone directories it distributes within CenturyTel Tribal Lands.
>
> iii\) [Website]{.underline}. Within 60 days of the Effective Date,
> CenturyTel will include an informative page on its website,
> [www.centurytel.com](http://www.centurytel.com/), which explains the
> Lifeline and Link-Up programs. The page will include information on
> the eligibility requirements, the sign-up procedures, and a phone
> number by which interested customers can receive further information.
> Existing customers will be able to request an application be mailed to
> them using the MyAccount function on the site. Those who are not
> customers will be offered a toll-free (8YY) number through which they
> will be able to request an application. This page will provide a link
> to the appropriate state website, where state law requires. CenturyTel
> will also offer to work with the tribal liaisons for those tribes with
> websites to include a link to CenturyTel's Lifeline and Link-Up
> information page on the tribal websites, providing such tribal
> liaisons are willing to participate. CenturyTel will include the URL
> address for the Lifeline and Link-Up information page in its outreach
> advertising.
>
> iv\) [State and Local Officials]{.underline}. CenturyTel will provide
> outreach information about Lifeline and Link-Up service to state and
> local officials and a contact person to whom such officials can refer
> individuals with questions about Lifeline and Link-Up. This effort
> will be undertaken twice yearly.
>
> v\) [Other]{.underline}. CenturyTel will make good faith efforts to
> promote Lifeline and Link-Up to all tribes within its service areas.
> When CenturyTel encounters a tribe that is particularly hard to reach
> or receives a request for service from a customer on CenturyTel Tribal
> Land to which CenturyTel cannot get access, CenturyTel will notify the
> FCC's Enforcement Bureau and Consumer and Governmental Affairs Bureau.

11\. CenturyTel will assess its outreach efforts periodically to
determine whether they are effective, as follows:

(a) CenturyTel will conduct a survey of tribal liaisons once a year to
    determine whether the outreach efforts for the past year have been
    effective in reaching the residents of CenturyTel Tribal Lands and
    informing them of the Lifeline and Link-Up programs.

(b) CenturyTel will assess whether any CenturyTel Tribal Land is within
    the coverage area of any newspaper, radio, or other media outlet
    (that CenturyTel is not already using pursuant to paragraph 10
    above) that CenturyTel can use to promote Lifeline and Link-Up.

(c) CenturyTel will track Lifeline and Link-Up applications and chart
    increases in Lifeline and Link-Up customers over time, by CenturyTel
    Tribal Land. This assessment will be done relative to October
    1, 2005. This assessment will occur twice during the period covered
    by this Plan, the first assessment to be completed not later than
    twelve months after October 1, 2005 and the second not later than
    eighteen months from October 1, 2005.

(d) If CenturyTel learns that certain outreach efforts are ineffective
    to reach a particular tribe, CenturyTel will adjust the outreach
    effort in response to the assessment. In such cases, CenturyTel will
    also provide the Bureau with a revised individualized tribal
    outreach plan to reflect the adjustment in the outreach effort for
    the particular tribe.

12\. CenturyTel will implement the following record-keeping mechanisms
to document each outreach effort undertaken to promote Lifeline and
Link-Up.

a.  CenturyTel will maintain a record of all individuals trained.

b.  CenturyTel will maintain logs of all radio PSAs and press releases
    that it distributes to radio stations and newspapers for a period of
    two years. CenturyTel will also request confirmation from both
    broadcasters and newspapers of when PSAs and press releases were
    aired or printed.

c.  Each of CenturyTel's Field Team members will keep a log of all of
    the efforts undertaken within their service areas to promote
    Lifeline and Link-Up to those living on CenturyTel Tribal Lands.
    CenturyTel will submit the logs for each state to the Bureau with
    its written report of compliance (described in paragraph 13 below)
    as supporting documentation. The logs will show the contact date,
    contact person, the outreach method used, the targeted tribe, and
    the targeted tribal land.

d.  CenturyTel will retain copies of all written material used in
    newspaper advertisements, press releases, posters, flyers, and other
    outreach efforts for two years. The field logs will contain
    documentation of when and where these materials were distributed.
    For newspaper advertisements, CenturyTel will require confirmation
    from the media sources of when they were published. Dated copies of
    the published newspaper advertisements may serve as such
    confirmation.

e.  CenturyTel will maintain records of all invoices for advertisements
    as well as any other expenditure that CenturyTel incurs for the
    promotion of Lifeline and Link-Up to those living on CenturyTel
    Tribal Lands for two years.

f.  CenturyTel will retain copies of all bill messages sent out to
    customers on CenturyTel Tribal Lands for two years. CenturyTel will
    also maintain copies of directory pages that contain printed
    information about the Lifeline and Link-Up programs for two years.

13\. CenturyTel will submit written reports to the Bureau describing its
compliance with this Consent Decree twelve and eighteen months after the
Effective Date. The reports shall address in detail CenturyTel's
compliance with each separate term and provision of this Consent Decree.
CenturyTel must mail its reports to Colleen Heitkamp, Chief,
Telecommunications Consumers Division, Enforcement Bureau, Federal
Communications Commission, 445 12^th^ Street, S.W. Room 4-C244,
Washington, D.C. 20554, and must include the file number listed above.
CenturyTel will also send an electronic copy of its reports to Mark
Stone, Deputy Chief, Telecommunications Consumers Division, at
<Mark.Stone@fcc.gov> and Donna Cyrus, Senior Attorney Advisor,
Telecommunications Consumers Division, at <Donna.Cyrus@fcc.gov>.

14\. The Bureau agrees that, in the absence of new material evidence
related to this matter, it will not use the facts developed in this
Investigation through the Effective Date or the existence of this
Consent Decree to initiate, on its own motion, any new proceeding,
formal or informal, or take any action on its own motion against
CenturyTel, including any other enforcement action, nor will the Bureau
seek on its own motion any administrative or other penalties from
CenturyTel, concerning the matters that were the subject of the
Investigation. The Bureau also agrees that it will not use the facts
developed in the Investigation through the Effective Date or the
existence of this Consent Decree to initiate, on its own motion, any
proceeding, formal or informal, or take any action on its own motion
against CenturyTel with respect to CenturyTel's basic qualifications,
including its character qualifications, to be a Commission licensee or
authorized common carrier. Consistent with the foregoing, nothing in
this Consent Decree limits the Commission's authority to consider and
adjudicate any complaint that may be filed pursuant to section 208 of
the Act, 47 U.S.C. § 208, and to take any action in response to such
complaint. The Commission's adjudication of any such complaint will be
based solely on the record developed in that proceeding. The Bureau
agrees that, to the extent consistent with paragraph 21, CenturyTel's
compliance with all the terms of this Consent Decree constitutes
compliance with the Commission's Lifeline and Link-Up outreach rules
during the period in which the Consent Decree is effective.

15\. CenturyTel's decision to enter into this Consent Decree is
expressly contingent upon the Bureau's issuance of an Adopting Order.

16\. Provided the Bureau issues an Adopting Order, CenturyTel waives any
and all rights it may have to seek administrative or judicial
reconsideration, review, appeal or stay, or to otherwise challenge or
contest the validity of this Consent Decree and the Adopting Order.

17\. If either Party (or the United States on behalf of the Commission)
brings a judicial action to enforce the terms of the Adopting Order,
neither CenturyTel nor the Commission shall contest the validity of the
Consent Decree or the Adopting Order, and CenturyTel and the Commission
will waive any statutory right to a trial *de novo* with respect to the
issuance of the Adopting Order and shall consent to a judgment
incorporating the terms of this Consent Decree.

18\. In the event that this Consent Decree is rendered invalid by a
court of competent jurisdiction, it shall become null and void and may
not be used in any manner in any legal proceeding.

19\. By this Consent Decree, CenturyTel neither waives nor alters its
right to assert and seek protection from disclosure of any privileged or
otherwise confidential and protected documents and information, or to
seek appropriate safeguards of confidentiality for any competitively
sensitive or proprietary information.

20\. CenturyTel agrees that any violation of the Order or of this
Consent Decree shall constitute a separate violation of a Commission
order, entitling the Commission to exercise any rights and remedies
attendant to the enforcement of a Commission order.

21\. The Parties agree that if any provision of this Consent Decree
conflicts with any subsequent rule or order adopted by the Commission
(except an order specifically intended to revise the terms of this
Consent Decree to which CenturyTel does not consent), that provision
will be superseded by such Commission rule or order.

22\. The Parties agree that the requirements of this Consent Decree
shall expire eighteen (18) months from the Effective Date.

23\. This Consent Decree may be signed in counterparts.

For: CenturyTel, Inc. For: Enforcement Bureau Federal Communications
Commission

\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date (CenturyTel Signature) Date Kris Anne Monteith

Chief, Enforcement Bureau

[^1]: 47 U.S.C. § 214(e)(1)(B); 47 C.F.R. §§ 54.405(b), 54.411(d).

[^2]: 47 U.S.C. § 154(i).

[^3]: 47 C.F.R. §§ 0.111, 0.311.

[^4]: 47 U.S.C. § 214(e)(1)(B); 47 C.F.R. §§ 54.405(b), 54.411(d).

[^5]: 47 U.S.C. § 214.

[^6]: *See* Letter of Inquiry from Colleen Heitkamp, Chief,
    Telecommunications Consumers Division, Enforcement Bureau, to John
    F. Jones, Vice President, Federal Government Relations, CenturyTel,
    Inc. (October 7, 2003).

[^7]: *See* Letter of Inquiry from Colleen Heitkamp, Chief,
    Telecommunications Consumers Division, Enforcement Bureau, to John
    F. Jones, Vice President, Federal Government Relations, CenturyTel,
    Inc. (April 6, 2004).

[^8]: *See* Letter from Terrance Hinkston, Compliance Specialist,
    CenturyTel, Inc., to Lynn Vermillera, Attorney, Telecommunications
    Consumers Division, Enforcement Bureau (November 17, 2003)
    ("November 17, 2003 Response").

[^9]: *See* Letter from Robert D. Shannon, Federal Government Relations,
    CenturyTel, Inc. to Cynthia Bryant, Attorney, Telecommunications
    Consumers Division, Enforcement Bureau (April 26, 2004) ("April 26,
    2004 Response").

[^10]: *See* Letter from Mark Stone, Deputy Chief, Telecommunications
    Consumers Division, Enforcement Bureau, to Karen Brinkmann, Latham
    and Watkins, LLP, and John F. Jones, Vice President, Federal
    Government Relations, CenturyTel, Inc. (November 9, 2004).

[^11]: *See* Letter from Karen Brinkmann and Manu Gayatrinath, Latham &
    Watkins, LLP, and John F. Jones, Director, Federal Government
    Relations, CenturyTel, Inc., to Mark Stone and Donna Cyrus,
    Telecommunications Consumers Division, Enforcement Bureau (November
    19, 2004) ("November 19, 2004 Response").

[^12]: *See* Letter from Karen Brinkmann and Manu Gayatrinath, Latham &
    Watkins, LLP, and John F. Jones, Director, Federal Government
    Relations, CenturyTel, Inc. to Mark Stone and Donna Cyrus,
    Telecommunications Consumers Division, Enforcement Bureau (January
    14, 2005) ("January 14, 2005 Response").

[^13]: *See* Letter from Karen Brinkmann and Manu Gayatrinath, Latham &
    Watkins, LLP, and John F. Jones, Director, Federal Government
    Relations, CenturyTel, Inc. to Mark Stone and Donna Cyrus,
    Telecommunications Consumers Division, Enforcement Bureau (January
    26, 2005) ("January 26, 2005 Response").

[^14]: *See* the November 17, 2003 Response, April 26, 2004 Response,
    November 19, 2004 Response, January 14, 2005 Response, and the
    January 26, 2005 Response.