**WHAT YOU OWE -- INTERSTATE TELECOMMUNICATIONS**

**SERVICE PROVIDERS (ITSPs) FOR FY 2004**

This *Fact Sheet* provides information for interstate telecommunications
service providers (ITSPs) to help them prepare and pay their ITSP
regulatory fees. Telecommunications providers typically identify
themselves on FCC Form 499-A filings using one or more of the following
categories:[^1]

**All Distance** \-- provides fixed local exchange services and
interstate long distance services to end users for a flat rate (may also
include intrastate toll).

**CAP/CLEC** (Competitive Access Provider/Competitive Local Exchange
Carrier) \-- competes with incumbent local exchange carriers (LECs) to
provide local exchange services, or telecommunications services that
link customers with interexchange facilities, local exchange networks,
or other customers, other than coaxial cable providers.

**Coaxial Cable** \-- uses coaxial cable (cable TV) facilities to
provide local exchange services or telecommunications services that link
customers with interexchange facilities, local exchange networks, or
other customers.

**Incumbent LEC** \-- provides local exchange services. An incumbent LEC
generally is a carrier that was at one time franchised as a monopoly
service provider. *See* 47 U.S.C. §251(h).

**Interexchange Carrier** (IXC) \-- provides long distance
telecommunications services substantially through switches or circuits
that it owns or leases.

**Local Reseller** \-- provides local exchange or fixed
telecommunications services by reselling services of other carriers.

**Operator Service Provider** (OSP) \-- serves customers needing the
assistance of an operator to complete calls, or needing alternate
billing arrangements such as collect calling.

**Payphone Service Provider** \-- provides customers access to telephone
networks through payphone equipment, special teleconference rooms, etc.
Payphone service providers also are referred to as payphone aggregators.

**Prepaid Card** \-- provides prepaid calling card services by selling
prepaid calling cards to the public or to retailers. Prepaid card
providers typically resell the toll service of other carriers and
determine the price of the service by setting the price of the card and
controlling the number of minutes that can be used by the card.

**Private Service Provider** \-- offers telecommunications to others for
a fee on a non-common carrier basis. This would include a company that
offers excess capacity on a private system that it uses primarily for
internal purposes. This category does not include Specialized Mobile
Radio operators.

**Shared-Tenant Service Provider /Building LEC** \-- manages or owns a
multi-tenant location that provides telecommunications services or
facilities to the tenants for a fee.

**Toll Reseller** \-- provides long distance telecommunications services
primarily by reselling the long distance telecommunications services of
other carriers.

**Other Local and Other Toll Service Providers** \-- other providers of
local exchange or toll services, including private service providers
(which offer telecommunications services to others and includes
companies that offer excess capacity on a private system that is used
primarily for internal purposes) and shared tenant service providers
(which manage or own multi-tenant locations that provide
telecommunications services or facilities to tenants for a fee.)

In its *FY 1996 Regulatory Fee Report and **Order***, the Commission
amended its rule regarding the Telecommunications Relay Service Fund
administrator to permit the National Exchange Carrier Association (NECA)
to process regulatory fees on behalf of its pooling exchange carriers
and to submit their consolidated fees to our lockbox bank in a single
payment instrument. However, we remind entities subject to regulatory
fee payment that the regulatee, not an agent such as NECA, is
responsible for ensuring that payment is made, and that there is a
penalty for not submitting the entire fee in a timely manner.

Fee Payment Amount and Payment Type Code for ITSPs

**Fee Payment Amount:** \$0.00218 per dollar of subject revenue

**Payment Type Code:** 0472

**Where to Send Payment**:

If you are sending in your payment along with your Form 159-W, and **[it
has a bill number]{.underline}** on it, please send the form and your
payment to:

Federal Communications Commission

Regulatory Fees

P.O. Box 358365

Pittsburgh, PA 15251-5365

If you are sending in your payment along with your Form 159-W, and there
is **[no bill number]{.underline}** on it, please send the form and your
payment to:

Federal Communications Commission

Regulatory Fees

P.O. Box 358835

Pittsburgh, PA 15251-5835

FCC Form 159-W and FCC Form 499-A

Most ITSP providers are receiving this Notice as part of a billing
package. The first page of the package consists of a bill that includes
a pre-filled FCC Form 159 Remittance Advice Form and a Regulatory Fee
Worksheet that shows how the bill was calculated. The bill is based on
information that you had previously provided on FCC Form 499-A. Your FCC
Form 499-A was due on April 1, 2004. The enclosed FCC prepared Form
159-W is based on the information in your FCC Form 499-A, including any
updates processed as of June 30, 2004.

**If you agree** with the dollar amounts on the enclosed pre-filled FCC
Form 159, please sign it and submit it with your payment. If the
Applicant's FRN-CORESID or the company's name/address information needs
to be filled in or corrected on your enclosed bill, please supply or
correct that information on the bill. You need not prepare a separate
FCC Form 159.

**If your total regulatory fee obligation**, including the ITSP fee and
other FCC regulatory fees, totals less than \$10, you need not pay or
make any filing.

**If you received an ITSP Fee Notification** rather than a bill, then
based on information in your FCC Form 499-A, you do not owe an ITSP fee.
Verify the information in the notification. If it is correct, then you
need not make a filing.

**If you disagree** with the dollar amounts on the enclosed bill or if
you owe an ITSP regulatory fee but did not receive a bill, you must: (1)
complete the enclosed blank FCC Form 159-W and the enclosed blank FCC
Form 159, (2) submit these forms to the FCC along with your most
recently filed FCC Form 499-A Telecommunications Reporting Worksheet,
and (3) pay the amount that you calculate. If you also need to correct
your FCC Form 499-A, you must file corrections using the procedures
specified in the form instructions. The copy that you enclose with your
regulatory fee payment will not be used to update the FCC Form 499-a
database.

**Question 1. What is the FCC Form 499-A Telecommunications Reporting
Worksheet?**

As required under the Communications Act of 1934, as amended,[^2] the
Commission has established, in a series of separate proceedings,
procedures to finance interstate telecommunications relay services
(TRS), universal service support mechanisms, administration of the North
American Numbering Plan (NANPA), and shared costs of local number
portability (LNPA). To accomplish these Congressional directed
objectives, contributions are collected from all telecommunications
carriers providing interstate telecommunications and certain other
providers of telecommunications. In 1999, the Commission amended its
rules so that for the purpose of determining their contribution(s),
contributors to these mechanisms need only file the FCC Form 499-A
Telecommunications Reporting Worksheet[^3][^4] The FCC Form 499-A is
filed by interstate service providers each year on April 1. A copy of
the form and instructions can be downloaded at
HREF=\"http://www.fcc.gov/formpage.html\".

**Question 2. Which companies must file an FCC Form 499-A?**

All providers of telecommunications services within the United States,
with very limited exceptions, must file an FCC Form 499-A.[^5] For this
purpose, the United States is defined as the contiguous United States,
Alaska, Hawaii, American Samoa, Baker Island, Guam, Howland Island,
Jarvis Island, Johnston Atoll, Kingman Reef, Midway Island, Navassa
Island, the Northern Mariana Islands, Palmyra, Puerto Rico, the U.S.
Virgin Islands, and Wake Island. As a general matter, each legal entity
that provides interstate telecommunications services for a fee,
including each affiliate or subsidiary of an entity, must complete
separately and file a copy of the FCC Form 499-A. The Commission,
however, has adopted an exception to the separate legal-entity
requirement, which enables contributors meeting certain criteria to file
the FCC Form 499-A on a consolidated basis.

For purposes of determining whether an entity provides
telecommunications, please note that the term \"telecommunications\"
means the transmission, between or among points specified by the user,
of information of the user\'s choosing, without change in the form or
content of the information as sent and received. For the purpose of
filing, the term \"interstate telecommunications\" includes, but is not
limited to, the following types of services: wireless telephony
including cellular and personal communications services (PCS); paging
and messaging services; dispatch services; mobile radio services;
operator services; access to interexchange service; special access; wide
area telecommunications services (WATS); subscriber toll-free services;
900 services; message telephone services (MTS); private line; telex;
telegraph; video services; satellite services; and resale services.
Note, for example, that all local exchange carriers provide access
services and, therefore, provide interstate telecommunications.

[Note]{.underline}: entities that offer interstate telecommunications
for a fee to the public, even if only to a narrow or limited class of
users that utilize their services, must file the FCC Form 499-A and are
subject to the universal service contribution requirement. This includes
entities that provide interstate telecommunications to entities other
than themselves for a fee on a private, contractual basis. In addition,
owners of pay telephones, sometimes referred to as \"pay telephone
aggregators,\" must file this worksheet. Most telecommunications
carriers must file this worksheet even if they qualify for the *de
minimis exemption* under the Commission\'s rules for universal
service[^6][^7]

**Question 3. Should all FCC Form 499-A filers also pay ITSP regulatory
fees?**

No. Interstate service providers that have mobile service or satellite
service revenues but that do not have interstate local revenues or
interstate toll revenues are exempt. Interstate service providers that
provide service to only other carriers are exempt. Governmental entities
are also exempt. Entities that are tax exempt under §501 of the Internal
Revenue Code are exempt. Carriers whose [total]{.underline} regulatory
fee payment obligation would be less than \$10 are also exempt. However,
the vast majority of FCC Form 499-A filers are required to pay ITSP
regulatory fees.

**Question 4. Should a carrier make a regulatory fee payment if it has
not filed an FCC Form 499-A?**

Yes. If a telecommunications carrier provided interstate
telecommunications services in 2003, then it should have filed an FCC
Form 499-A, and it must also pay the appropriate regulatory fee
payments. The FCC Form 499-A was due on April 1, 2004 and should have
contained revenue information for calendar year 2003. Carriers who have
not yet filed the FCC Form 499-A should contact NECA at (973) 560-4400
in order to obtain a filing package and to be assigned a 6-digit Filer
499 ID number. If a carrier has forgotten its Filer 499 ID, it may
contact the Universal Service administrator at (973) 560-4400, or it may
access the Commission's online carrier *Locator*:
<http://gullfoss2.fcc.gov/cib/form499/499a.cfm> .

**Question 5. What types of revenues are reported on the FCC Form
499-A?**

The FCC Form 499-A requires filers to disclose all revenues from all
goods and services, including revenues from non-regulated and
non-telecommunications services. Detailed information is submitted for
telecommunications services provided to other carriers, for
telecommunications provided to end users, and for other goods and
services. The detailed information is used to classify revenues. Only
certain revenues are subject to the ITSP regulatory fee.

**Question 6. When calculating the ITSP regulatory fee, what kind of
costs can be deducted from revenues that appear on FCC Form 499-A?**

None. The ITSP regulatory fee is based on interstate and international
end-user revenues for local and most toll services. Other types of
revenues provided on FCC Form 499-A are excluded. Filers are not allowed
to deduct any expenses from subject end-user revenues.

**Question 7. Where can I call to get help calculating my ITSP
regulatory fee?**

Call the FCC CORES Help Desk at (877) 480-3201, and select Option 4.

[Do not complete this form if you have received an ITSP bill and the
amounts are correct. File that form, instead.]{.underline}

**Approved by OMB**

**3060-0949**

**FCC FORM 159-W**

**INTERSTATE TELEPHONE SERVICE PROVIDER WORKSHEET**

+---+--------------------------+-------------------+------------------+
| P |                          | Filer 499 ID (FCC |                  |
| a |                          | Form 499-A, Line  |                  |
| y |                          | 101):             |                  |
| e |                          |                   |                  |
| r |                          |                   |                  |
| N |                          |                   |                  |
| a |                          |                   |                  |
| m |                          |                   |                  |
| e |                          |                   |                  |
| : |                          |                   |                  |
+---+--------------------------+-------------------+------------------+
| C |                          |                   |                  |
| a |                          |                   |                  |
| l |                          |                   |                  |
| e |                          |                   |                  |
| n |                          |                   |                  |
| d |                          |                   |                  |
| a |                          |                   |                  |
| r |                          |                   |                  |
| Y |                          |                   |                  |
| e |                          |                   |                  |
| a |                          |                   |                  |
| r |                          |                   |                  |
| 2 |                          |                   |                  |
| 0 |                          |                   |                  |
| 0 |                          |                   |                  |
| 3 |                          |                   |                  |
| R |                          |                   |                  |
| e |                          |                   |                  |
| v |                          |                   |                  |
| e |                          |                   |                  |
| n |                          |                   |                  |
| u |                          |                   |                  |
| e |                          |                   |                  |
| I |                          |                   |                  |
| n |                          |                   |                  |
| f |                          |                   |                  |
| o |                          |                   |                  |
| r |                          |                   |                  |
| m |                          |                   |                  |
| a |                          |                   |                  |
| t |                          |                   |                  |
| i |                          |                   |                  |
| o |                          |                   |                  |
| n |                          |                   |                  |
| ( |                          |                   |                  |
| s |                          |                   |                  |
| h |                          |                   |                  |
| o |                          |                   |                  |
| w |                          |                   |                  |
| a |                          |                   |                  |
| m |                          |                   |                  |
| o |                          |                   |                  |
| u |                          |                   |                  |
| n |                          |                   |                  |
| t |                          |                   |                  |
| s |                          |                   |                  |
| i |                          |                   |                  |
| n |                          |                   |                  |
| w |                          |                   |                  |
| h |                          |                   |                  |
| o |                          |                   |                  |
| l |                          |                   |                  |
| e |                          |                   |                  |
| d |                          |                   |                  |
| o |                          |                   |                  |
| l |                          |                   |                  |
| l |                          |                   |                  |
| a |                          |                   |                  |
| r |                          |                   |                  |
| s |                          |                   |                  |
| ) |                          |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | Service provided by U.S. |                   |                  |
|   | carriers that both       |                   |                  |
|   | originates and           |                   |                  |
|   | terminates in foreign    |                   |                  |
|   | points. FCC Form 499-A,  |                   |                  |
|   | Line 412 (e)             |                   |                  |
+---+--------------------------+-------------------+------------------+
| 2 | Interstate end-user      |                   |                  |
|   | revenues from all        |                   |                  |
|   | telecommunications       |                   |                  |
|   | services. FCC Form       |                   |                  |
|   | 499-A, Line 420 (d)      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 3 | International end-user   |                   |                  |
|   | revenues from all        |                   |                  |
|   | telecommunications       |                   |                  |
|   | services except          |                   |                  |
|   | interna                  |                   |                  |
|   | tional-to-international. |                   |                  |
|   | FCC Form 499-A, Line 420 |                   |                  |
|   | (e)                      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 4 | Total end-user revenues  |                   |                  |
|   | (Sum of lines 1, 2 and   |                   |                  |
|   | 3)                       |                   |                  |
|   |                          |                   |                  |
|   | Also enter this number   |                   |                  |
|   | on Block (28A) - FCC     |                   |                  |
|   | Code 1.                  |                   |                  |
+---+--------------------------+-------------------+------------------+
| 5 | End-user interstate      |                   |                  |
|   | mobile service monthly   |                   |                  |
|   | and activation charges.  |                   |                  |
|   | FCC Form 499-A, Line 409 |                   |                  |
|   | (d)                      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 6 | End-user international   |                   |                  |
|   | mobile service monthly   |                   |                  |
|   | and activation charges.  |                   |                  |
|   | FCC Form 499-A, Line 409 |                   |                  |
|   | (e)                      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 7 | End-user interstate      |                   |                  |
|   | mobile service message   |                   |                  |
|   | charges including        |                   |                  |
|   | roaming charges but      |                   |                  |
|   | excluding toll charges.  |                   |                  |
|   | FCC Form 499-A, Line 410 |                   |                  |
|   | (d)                      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 8 | End-user international   |                   |                  |
|   | mobile service message   |                   |                  |
|   | charges including        |                   |                  |
|   | roaming charges but      |                   |                  |
|   | excluding toll charges.  |                   |                  |
|   | FCC Form 499-A, Line 410 |                   |                  |
|   | (e)                      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 9 | End-user interstate      |                   |                  |
|   | satellite services. FCC  |                   |                  |
|   | Form 499-A, Line 416 (d) |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | End-user international   |                   |                  |
| 0 | satellite services. FCC  |                   |                  |
|   | Form 499-A, Line 416 (e) |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | Surcharges on mobile and |                   |                  |
| 1 | satellite services       |                   |                  |
|   | identified as recovering |                   |                  |
|   | universal service        |                   |                  |
|   | contributions and        |                   |                  |
|   | included in Line 403 (d) |                   |                  |
|   | or 403 (e) on your FCC   |                   |                  |
|   | Form 499-A. **Note**:    |                   |                  |
|   | **You may not include in |                   |                  |
|   | Block (11) universal     |                   |                  |
|   | service pass-through     |                   |                  |
|   | surcharges applied to    |                   |                  |
|   | local or toll services,  |                   |                  |
|   | nor any surcharges       |                   |                  |
|   | identified as intrastate |                   |                  |
|   | surcharges.**            |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | Interstate and           |                   |                  |
| 2 | international revenues   |                   |                  |
|   | from resellers that do   |                   |                  |
|   | not contribute to USF.   |                   |                  |
|   | FCC Form 499-A, Line 511 |                   |                  |
|   | (b)                      |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | Total excluded end-user  |                   |                  |
| 3 | revenues. (Sum lines 5   |                   |                  |
|   | through 12.)             |                   |                  |
|   |                          |                   |                  |
|   | Also enter this number   |                   |                  |
|   | on Block (29A) -- FCC    |                   |                  |
|   | Code 2.                  |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | Total subject revenues.  |                   |                  |
| 4 | (Line 4 minus Line 13)   |                   |                  |
|   |                          |                   |                  |
|   | Also enter this number   |                   |                  |
|   | on Block (25A) --        |                   |                  |
|   | Quantity.                |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | Interstate               |                   | .00218           |
| 5 | telecommunications       |                   |                  |
|   | service provider fee     |                   |                  |
|   | factor                   |                   |                  |
+---+--------------------------+-------------------+------------------+
| 1 | 2003 Regulatory Fee      |                   |                  |
| 6 | (Line 14 times Line 15). |                   |                  |
|   | Also enter this number   |                   |                  |
|   | on Block (27A) -- Total  |                   |                  |
|   | Fee. You are exempt from |                   |                  |
|   | filing if the sum of all |                   |                  |
|   | regulatory fees due on   |                   |                  |
|   | Line 16 is less than     |                   |                  |
|   | \$10. If you file, using |                   |                  |
|   | this form, you must also |                   |                  |
|   | complete an FCC Form     |                   |                  |
|   | 159, and **include a     |                   |                  |
|   | copy of this FCC Form    |                   |                  |
|   | 159-W with your          |                   |                  |
|   | filing.**                |                   |                  |
+---+--------------------------+-------------------+------------------+

**FCC FORM 159-W**

**July 2004**

# 

# Approved by OMB

**3060-0949**

FCC NOTICE TO INDIVIDUALS REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to
average 15 minutes per response, including the time for reviewing
instructions, searching existing data sources, gathering and maintaining
the required data, and completing and reviewing the collection of
information. If you have any comments on this burden estimate, or how we
can improve the collection, please write to the Federal Communications
Commission, AMD-PERM, Paperwork Reduction Project (3060-0949),
Washington, DC 20554. We will also accept your comments via the Internet
if you send them to jboley@fcc.gov. PLEASE DO NOT SEND COMPLETED FORMS
TO THIS ADDRESS.

You are not required to respond to a collection of information sponsored
by the federal government, and the government may not conduct or sponsor
a collection, unless it displays a currently valid OMB control number.
This collection has been assigned an OMB control number of 3060-0949.

**THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF
1995, P.L. 104-13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.**

**FCC FORM 159-W**

**July 2004**

**Special Instructions for Completing FCC Forms 159 and 159-C**

In addition to the general FCC Form 159 filing instructions in the *FY
2004 Regulatory Fees Public Notice*, the following information applies
specifically to ITSP regulatees:

[Block (2) - Payer Name]{.underline}:

-   Enter the legal name of the entity that is actually submitting the
    payment. This may be the name of the interstate telecommunications
    service provider (applicant) that owes the regulatory fee or the
    name of an entity that is making payment on behalf of the applicant.

    [Block (9) - Telephone Number]{.underline}:

-   Enter the contact name and telephone number of the specific
    individual responsible for submitting the payment and supporting FCC
    Form 159 and FCC Form 159-C.

    [Block (11) - Payer FRN]{.underline}:

-   Enter the FRN of the entity identified in Block (2).

    [Block (21) - Applicant FRN]{.underline}:

 If different from payer, enter the applicant\'s FRN number.

[Block (23A) - FCC Call Sign/Other ID]{.underline}:

 ITSPs should enter their Filer 499 ID number (FCC Form 499-A, Line
101.)

[Block (24A) - Payment Type Code]{.underline}:

-   Enter 0472 when paying for an ITSP regulatory fee (\$0.00218 per
    revenue dollar.)

    [Block (25A) - Quantity]{.underline}:

 First complete Blocks (28A) (FCC Code 1) and (29A) (FCC Code 2) on FCC
Form 159. (See instructions below.)

 ITSPs should subtract the amount in Block (29A) (FCC Code 2) from the
amount in Block (28A) (FCC Code 1) and enter the Telecommunications
Reporting Worksheet end-user revenues. This should equal the amount
reported on Line 14 of the FCC Form 159-W.

[Block (27A) - Total Fee]{.underline}:

 For ITSP regulatory fees (payment type code 0472), multiply the amount
in Block 25A (Quantity) by \$0.00218. This amount should equal the
amount reported on Line 16 of the FCC Form 159-W. **Enter exact dollars
and cents; do not round.**

[Block (28A) - FCC Code 1]{.underline}:

 For ITSP regulatory fees (payment type code 0472), enter the total
end-user revenues. This amount should be the same as Line 4 of the FCC
Form 159-W. **Enter exact dollars and cents; do not round.**

[Block (29A) - FCC Code 2]{.underline}:

-   For ITSP regulatory fees (payment type code 0472), the amount
    entered in Block (29-A) should equal the amount reported on Line 13
    of the FCC Form 159-W. This amount is excluded from the interstate
    and international end-user revenues that are used to calculate the
    telephone service provider fee. Exclusions are limited to:

```{=html}
<!-- -->
```
-   Interstate and international end-user revenues from mobile services;

-   Interstate and international end-user revenues from satellite
    services;

-   Interstate and international end-user revenues from services
    provided to resellers that do not contribute to USF; and

-   The interstate and international portion of any universal service
    pass-through surcharges levied on the interstate and international
    end-user revenues from the above revenues (i.e. mobile services,
    satellite services, and services provided to resellers that do not
    contribute to USF).

-   The interstate and international end-user revenues reported on Line
    511 of the FCC Form 499-A.

    [Certification:]{.underline}

 Provide the printed name and signature of an individual owner/licensee
or officer attesting to the accuracy and completeness of the information
supplied.

**Please include a daytime telephone number so that we can contact you
if questions arise regarding your payment.**

\- FCC -

[^1]: If you timely filed an FCC 499-A, in 2004, you will receive this
    Factsheet as part of a package that includes a pre-completed FCC
    Form 159-W that also includes Form 159 information. If the
    pre-completed information is correct, complete the form and use it
    to pay your ITSP regulatory fee. If the information is incorrect,
    you may enter corrections on the pre-completed form rather than
    completing one of the enclosed blank forms.

[^2]: 47 U.S.C. §§151, 225, 251, 254.

[^3]: ^.^

[^4]: *1998 Biennial Regulatory Review \-- Streamlined Contributor
    Reporting Requirements Associated with Administration of
    Telecommunications Relay Services, North American Numbering Plan,
    Local Number Portability, and Universal Service Support Mechanisms*,
    CC Docket No. 98-171, Report and Order, 14 FCC Rcd 16602 (1999)
    (*Contributor Reporting Requirements Order*).

[^5]: Section 254(d) applies not only to "every telecommunications
    carrier that provides interstate telecommunications *services"* but
    also to certain "other providers of interstate telecommunications."
    47 U.S.C. §254(d) (emphasis added).

[^6]: ^.^

[^7]: See *Federal-State Joint Board on Universal Service*, *1998
    Biennial Regulatory Review -- Streamlined Contributor Reporting
    Requirements Associated with Administration of Telecommunications
    Relay Service, North American Numbering Plan, Local Number
    Portability, and Universal Service Support Mechanisms,
    Telecommunications Services for Individuals with Hearing and Speech
    Disabilities, and the Americans with Disabilities Act of 1990,
    Administration of the North American Numbering Plan Cost Recovery
    Contribution Factor and Fund Size, Number Resource Optimization,
    Telephone Number Portability, Truth-in-Billing and Billing Format*,
    CC Docket Nos. 96-45, 98-171, 90-571, 92-237, 99-200, 95-116,
    98-170, Further Notice of Proposed Rulemaking and Report and Order,
    17 FCC Rcd 3752 (2002).