WPC 2BJZ Courier3|jx6X@`7X@HP LaserJet 5Si LPT2 Rm 500FHPLAS5SI.PRSx  @\#yX@20E6{K Z X-#Xj\  P6G;ynXP#3|j"i~'^09CSS999S]+9+/SSSSSSSSSS//]]]Ixnnxg]xx9?xgxx]xn]gxxxxg9/9MS9ISISI9SS//S/SSSS9?/SSxSSIP!PZ9+ZM999+999999S9S/xIxIxIxIxIlnIgIgIgIgI9/9/9/9/xSxSxSxSxSxSxSxSxSxSxIxSxRxSxSxS]SxIxIxInInInZnIxigIgIgIgIxSxSxSxZxSxZxS9/9S999Su]ZZxSg/gCg9g9g/xSbxSxSxSxSxn9n9n9]?]?]?]ZgFg/gMxSxSxSxSxSxSxxZgIgIgIxSg9xS]?g9xSi+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNI\\>>>\g0>03\\\\\\\\\\33gggQyyrg>Frgygrr>3>T\>Q\Q\Q>\\33\3\\\\>F3\\\\QX%Xc>0cT>>>0>>>>>>\>\3QQQQQwyQrQrQrQrQ>3>3>3>3\\\\\\\\\\Q\Z\\\g\QQQyQyQycyQtrQrQrQrQ\\\c\c\>3>\>>>\gcc\r3rIr>r>r3\l\\\\y>y>y>gFgFgFgcrMr3rT\\\\\\crQrQrQ\r>\gFr>\t0\\=!=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBT\>Q\\\\\3;\7;\7>>QQ\??n\\nBnnBmgg>Q\7"yyyy\njc\gnn\"i~'^5>g\\>>>\g0>03\\\\\\\\\\>>ggg\yyrF\yrgyy>3>j\>\gQgQ>\g3>g3g\ggQF>g\\\QI(I_>0_j>>>0>>>>>>\>g3\\\\\QyQyQyQyQD3D3D3D3g\\\\gggg\\g\\\\pg\\\QQ_QyQyQyQyQ\\\_\gjF3FgF>Fgg__gy3ySy>yIy3ggg\\QQQgFgFgFg_y^y>yjgggggg_yQyQyQgy>ggFy>\0\\=2=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBa\>\\\\\\7>\7>\7>>\\\??n\\nBnnBsgg>\\7"yyyy\nlc\gnn\"i~'^09]SS999S]+9+/SSSSSSSSSS99]]]Sxnxxng?Snxgx]nxxxxn9/9aS9S]I]I9S]/9]/]S]]I?9]SxSSIC%CW9+Wa999+999999S9]/xSxSxSxSxSxxInInInInI>/>/>/>/x]SSSSx]x]x]x]xSxSx]SSxSxSf]xSxSxSxIxIxWxIx{nInInInISSSWS]a?/?]?9?]]WW]n/nKn9nCn/x]xx]x]SSxxIxIxI]?]?]?]WnUn9nax]x]x]x]x]x]xxWnInInIx]n9x]]?n9xSz+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""\4  pG;\5hC:,%rXh*f9 xr G;XX W!@(#,h@\  P6G;hP!H5!,),5\  P6G;,P\"{,W80,%BZW*f9 xr G;X<?xxx,<x6X@`7X@ `p?< 3  ip8 @{`AƁ? ~>Po  2 yO-'> X-  #&I\  P6Qu&P#Federal Communications Commission`(#DA 98392 ă  yxdddy'   #C\  P6QɒP# v3 #C\  P6QɒP#Before the Federal Communications Commission  yO} Washington, D.C. 20554 #XP\  P6QynXP#у In the Matter ofR) R) Designation of R)  X- I. A. 1. a.(1)(a) i) a) I. 1. 1. a.(1)(a) i) a)Fort Mojave Telecommunications, Inc.,R)hpp Gila River Telecommunications, Inc., R)  X-San Carlos Telecommunications, Inc., andR)hppAAD/USB File No. 9828 Tohono O'odham Utility AuthorityR) as Eligible Telecommunications Carriers R) Pursuant to Section 214(e)(6) of theR) Communications ActR)  X--  MEMORANDUM OPINION AND ORDER T  X-}^ Adopted: February 27, 1998 Released: February 27, 1998 TT  X-TԲ PBy the Chief, Common Carrier Bureau:  X- I. INTRODUCTION ĐTP  Xu-x1.` ` On December 29, 1997, the Commission released a public notice ("214(e)(6)  X`-Public Notice") establishing the procedures the Commission will use to designate eligible telecommunications carriers pursuant to section 214(e)(6) of the Communications Act of 1934, as amended, ("the Act"), and delegating authority to make such designations to the Chief,  X-Common Carrier Bureau. $z yO-ԍ#]\  PCɒP# Procedures for FCC Designation of Eligible Telecommunications Carriers Pursuant to Section 214(e)(6) of  {O^-the Communications Act, Public Notice, FCC 97419 (rel. Dec. 29, 1997), 63 Fed. Reg. 162 (Jan. 5, 1998).  {O(-Section 214(e)(6) was added to the Communications Act on December 1, 1997. See Pub. L. No. 105125, 111  yO-Stat. 2540 (1997).#x6X@K X@#  On December 18, 1997, prior to the release of the Commission's public notice establishing procedures under section 214(e)(6), Fort Mojave Telecommunications, Inc., Gila River Telecommunications, Inc., San Carlos Telecommunications, Inc., and Tohono O'odham Utility Authority ("the petitioners" or "Arizona companies") submitted a joint petition seeking designation as eligible  X-telecommunications carriers.3Xz yO$-ԍ Fort Mojave Telecommunications, Inc., Gila River Telecommunications, Inc., San Carlos Telecommunications, Inc., and Tohono O'odham Utility Authority Petition for Designation as Eligible Telecommunications Carriers (filed Dec. 18, 1997) (Arizona Companies Petition).3 On January 28, 1998, the same companies filed a"0*&&qq" supplementary petition providing additional information pursuant to the procedures set forth in  X-the Commission's 214(e)(6) Public Notice. z yOb-ԍ Fort Mojave Telecommunications, Inc., Gila River Telecommunications, Inc., San Carlos Telecommunications, Inc., and Tohono O'odham Utility Authority Supplement to Petition for Designation as Eligible Telecommunications Carriers Pursuant to Section 214(e)(6) of the Communications Act (filed Jan. 28, 1998) (Supplement to Arizona Companies Petition). On January 30, 1998, the Universal Service Branch of the Common Carrier Bureau's Accounting and Audits Division issued a public  X-notice seeking comment on the Arizona Companies Petition and the supplement."z yO -ԍ Fort Mojave Telecommunications, Inc., Gila River Telecommunications, Inc., San Carlos Telecommunications, Inc., and Tohono O'odham Utility Authority Seek Designation as Eligible  {O -Telecommunications Carriers Pursuant to Section 214(e)(6) of the Communications Act, Public Notice,  yOx -AAD/USB File No. 9828, DA 98181 (Univ. Svc. Brnch. rel. Jan. 30, 1998). Two parties  X-filed comments supporting the petitionz yO -ԍ Comments of the National Telephone Cooperative Association (NTCA) (filed Feb. 9, 1998); Comments of the United States Telephone Association (USTA) (filed Feb. 9, 1998). and the petitioners filed reply comments.a z yOI-ԍ Arizona Companies reply comments (filed Feb. 18, 1998).a In this Memorandum Opinion and Order, we designate each of the abovecaptioned companies as eligible telecommunications carriers pursuant to section 214(e)(6) of the Communications Act.  XJ- II. BACKGROUND ĐTP  X -x2.` ` For most carriers, state commissions are responsible for designating eligible  X -telecommunications carriers and for designating service areas for such carriers.K z yO8-ԍ 47 U.S.C.  214(e)(2), (e)(5).K Section 214(e)(6), however, provides: Xx` ` In the case of a common carrier . . . that is not subject to the jurisdiction of a State commission, the Commission shall upon request designate such a common carrier that meets the requirements of [section 214(e)(1)] as an eligible telecommunications  X{-carrier for a service area designated by the Commission.C{z yO>-ԍ 47 U.S.C.  214(e)(6).C(# Pursuant to section 254(e), after January 1, 1998, "only an eligible telecommunications carrier designated under section 214(e) shall be eligible to receive . . . Federal universal service"60*&&qq*"  X-support." $z yOy-ԍ 47 U.S.C.  254(e). Section 254(e)'s effective date is "the date on which Commission regulations  {OA-implementing this section take effect." That date is January 1, 1998. See FederalState Joint Board on Universal  {O -Service, CC Docket No. 9645, Report & Order, 12 FCC Rcd 8776 (1997) (Universal Service Order); 47 C.F.R. Part 54. Section 214(e)(1) requires that, to be designated an eligible telecommunications carrier, a common carrier must, throughout its service area: (1)offer all of the services designated for support by the Commission pursuant to section 254(c) "either using its own  X-facilities or a combination of its own facilities and resale of another carrier's services . . ."F z yO -ԍ 47 U.S.C.  214(e)(1)(A).F and (2) "advertise the availability of such services and the charges therefor through media of  X-general distribution."F Dz yO -ԍ 47 U.S.C.  214(e)(1)(B).F III. DESIGNATION OF ELIGIBLE TELECOMMUNICATIONS CARRIERSTP  X1-A.xCarriers Not Subject to the Jurisdiction of a State Commission  X -x3.` ` The 214(e)(6) Public Notice required carriers seeking designation from the Commission pursuant to section 214(e)(6) to set forth a certification and brief statement of supporting facts demonstrating that the petitioner is not subject to the jurisdiction of a state  X -commission.M z {OE-ԍ 214(e)(6) Public Notice at 2.M In addition, the 214(e)(6) Public Notice directed each petitioner to provide a  X -copy of its petition for designation to the relevant state commission.? f z {O-ԍ Id.? With regard to these requirements, the Arizona Companies Petition states that each company is "subject to the jurisdiction of the governing body of a distinct federallyrecognized Indian tribe" and that "the  Xf-Arizona Corporation Commission does not assert jurisdiction over the Companies."kf z {O-ԍ Arizona Companies Petition at 2; accord USTA comments at 2.k In further support of their assertion that they are not subject to the jurisdiction of a state commission, the petitioners assert that tribal councils have authorized operation of each of the  X!-Arizona companies.X! z yO\!-ԍ Arizona Companies Petition at 6, Attachment B. Attachment B provides copies of resolutions referencing the tribal authorization for Fort Mojave Telecommunications and Gila River Telecommunications, but does not  {O"-provide similar documents for San Carlos Telecommunications and Tohono O'odham. Id. As stated infra, the Arizona Corporation Commission did not object to the assertions that neither San Carlos Telecommunications nor  yO~$-Tohono O'odham were subject to the jurisdiction of a State commission. X " <0*&&qq("Ԍ X-x4.` ` Although the Arizona Corporation Commission was notified of the Arizona Companies Petition, it did not submit comments in this proceeding. Moreover, no party challenges the petitioners' assertion that they are not subject to the jurisdiction of a state commission. Based on the record before us, we conclude that the petitioners are not subject to the jurisdiction of a state commission for purposes of section 214(e)(6), and therefore, we  X-conclude that we may, pursuant to our delegated authority,z {O-ԍ See 214(e)(6) Public Notice and 47 C.F.R. 0.291. See also 47 C.F.R.  0.91. designate them as eligible telecommunications carriers.  XH-B.xDesignation of Service Areas  X -x5.` ` Section 214(e)(1) requires eligible telecommunications carriers to offer and advertise the services designated for support "throughout the service area for which the  X -designation is received."C Zz yO-ԍ 47 U.S.C.  214(e)(1).C Section 214(e)(5) states that, "[i]n the case of an area served by a rural telephone company, service area' means such company's study area' unless and until  X -the Commission and the States . . . establish a different definition."2 z yOY-ԍ 47 U.S.C.  214(e)(5). Rural telephone company is defined in section 3(37) of the Act, which provides that: XxThe term "rural telephone company" means a local exchange carrier operating entity to the extent that such entity (# XxX` ` (A) provides common carrier service to any local exchange carrier study area that does not include either (#` XxX` ` X (i) any incorporated place of 10,000 inhabitants or more, or any part thereof, based on the most recently available population statistics of the Bureau of the Census; or(# XxX` ` X (ii) any territory, incorporated or unincorporated, included in an urbanized area, as defined by the Bureau of the Census as of August 10, 1993;(# XxX` ` (B) provides telephone exchange service, including exchange access, to fewer than 50,000 access lines;(#` XxX` ` (C) provides telephone exchange service to any local exchange carrier study area with fewer than 100,000 access lines; or(#` XxX` ` (D) has less than 15 percent of its access lines in communities of more than 50,000 on the date of enactment of the Telecommunications Act of 1996.(#` Before April 30 of each year, each LEC that seeks to be classified as a rural carrier for the purposes of high cost support must certify that it is a rural telephone company and explain how the carrier meets at least one of the  {O!-four statutory criteria. See SelfCertification as a Rural Telephone Company, Public Notice, DA 971748 (rel. Aug. 14, 1997). In the 214(e)(6) Public  X -Notice, the Commission directed petitioners that meet the definition of a rural telephone" 0*&&qq "  X-company to identify their study areas.Mz {Oy-ԍ 214(e)(6) Public Notice at 3.M Each of the petitioners asserts that it is a rural telephone company pursuant to section 3(37) of the Act and provides the study area code  X-number for its study area.ZZz yO-ԍ Arizona Companies Petition at n.1, Attachment A.Z Based on the record before us and consistent with section 214(e)(5), we designate each petitioner's study area as its service area.  X-C.xOffering the Services Designated for Support  X_-x6.` ` Section 214(e)(1) requires that, to be designated an eligible telecommunications carrier, a common carrier must offer, throughout its service area, all of the services designated  X1-for support by the Commission pursuant to section 254(c).F1z yO -ԍ 47 U.S.C.  214(e)(1)(A).F In the 214(e)(6) Public Notice, the Commission directed each carrier seeking designation as an eligible telecommunications carrier to provide a certification that it provides, throughout its service area, all services  X -designated for support by the Commission pursuant to section 254(c). zz {O-ԍ 214(e)(6) Public Notice at 2. The Commission has designated the following services for support: singleparty service; voice grade access to the public switched network; Dual Tone Multifrequency (DTMF) signalling or its functional equivalent; access to emergency services including, in some circumstances, access to 911 and Enhanced 911 (E911); access to operator services; access to interexchange service; access to directory assistance;  {O;-and tolllimitation services for qualifying lowincome consumers. Universal Service Order, 12 FCC Rcd at 8807, 88098822, paras. 56, 6182; 47 C.F.R.  54.101. Fort Mojave Telecommunications and Gila River Telecommunications provide resolutions from the Fort Mojave Tribe of the Fort Mojave Reservation of Arizona, California, and Nevada and the Gila River Indian Community, respectively, certifying that these carriers provide all of the  X-supported services.Z z yO9-ԍ Arizona Companies Petition at 78, Attachment B.Z The Tohono O'odham Utility Authority provides a sworn statement by its general manager certifying that Tohono O'odham offers all of the supported services. San Carlos Telecommunications also provides a sworn statement by its general manager certifying that it offers all the supported services except toll limitation for qualifying lowincome  X6-consumers.6 z {Om -ԍ Id. San Carlos Telecommunications's inability to offer tolllimitation service is discussed infra. USTA agrees that each carrier offers all of the supported services consistent  X-with the requirements of the Commission.?z yO"-ԍ USTA comments at 36.?  X-x7.` ` The Arizona Companies Petition states that San Carlos Telecommunications offers access to emergency services through sevendigit dialing and not through 911 service"0*&&qq"  X-because the area served by San Carlos has no Public Safety Answering Point (PSAP).Rz yOy-ԍ Arizona Companies Petition at 89.R We find that San Carlos's provision of access to emergency services is consistent with the  X-Commission's finding in the Universal Service Order that, because PSAPs are typically provided by local governments and funded by local tax revenue, a carrier is not required to  X-offer 911 or E911 services in the absence of a PSAP.Xz {O-ԍ Universal Service Order, 12 FCC Rcd at 8817, para. 74 (finding that access to emergency services includes "only the telecommunications network components necessary for access to 911 and E911 services"). We therefore find that San Carlos Telecommunications offers access to emergency services consistent with the Commission's  Xx-rules."xz {O -ԍ See 47 C.F.R.  54.101(a)(5) ("Access to emergency services' includes access to services, such as 911 and enhanced 911, provided by local governments or other public safety organizations. . . . Access to emergency services' includes access to 911 and enhanced 911 services to the extent the local government in an eligible carrier's service area has implemented 911 or enhanced 911 systems").  XJ-x8.` ` To be designated as an eligible telecommunications carrier, a carrier must offer tolllimitation services to qualifying lowincome consumers. At the time the Arizona Companies Petition was filed, the Commission defined tolllimitation service as both toll  X -control and tollblocking.t z {OR-ԍ See Universal Service Order, 12 FCC Rcd at 897879, para. 383.t In response to the tolllimitation requirement, as defined at the time, Fort Mojave Telecommunications, Gila River Telecommunications, and Tohono O'odham Utility Authority seek a waiver of that requirement, asserting that they can offer toll  X -blocking but cannot offer toll control.J . z yO-ԍ Arizona Companies Petition at 9.J In the Fourth Reconsideration Order, however, the Commission concluded that carriers that are technically incapable of offering toll control may  X-offer toll blocking alone to meet the tolllimitation requirement.$ z yO-ԍ FederalState Joint Board on Universal Service, Access Charge Reform, Price Cap Performance Review for Local Exchange Carriers, Transport Rate Structure and Pricing, End User Common Line Charge, CC Dockets  {O-9645, 96262, 941, 91213, 9572, Fourth Order on Reconsideration, FCC 97420 (Dec. 30, 1997) at para. 115;  {O]-see also 47 C.F.R.  54.400(d). Therefore, we conclude that Fort Mojave Telecommunications, Gila River Telecommunications, and Tohono O'odham Utility Authority each offers tolllimitation service consistent with the Commission's rules and do not require a waiver.  X!-x9.` ` The Arizona Companies Petition also seeks an extension of time for San Carlos  X -Telecommunications because it can offer neither tolllimitation service nor toll blocking.O z yOe%-ԍ Arizona Companies Petition at 9 n.19.O " : 0*&&qq " San Carlos Telecommunications initiated service in August 1997 and has not yet been able to complete all of its planned network upgrades. San Carlos asserts that it currently provides service through a "step office," through which it is incapable of providing tolllimitation service, but anticipates that it will acquire digital switching capability that will enable it to  X-provide toll blocking by mid1998.!z {O-ԍ Id. A step office, STEP SWITCHor a "step by step" switch is an electromechanical switch invented in the 1920s that  yO-mechanically responds to each dialed digit in a number to connect a call.  If "exceptional circumstances prevent an otherwise eligible telecommunications carrier from providing . . . toll limitation," the Commission's rules allow a carrier to receive an extension of time to complete the network upgrades  X_-necessary to provide tolllimitation service.D"_"z yO2 -ԍ 47 C.F.R.  54.101(c). D The Commission's rules further provide that the extension should extend only so long as the exceptional circumstances exist and should not  X1-extend beyond the time necessary for the carrier to complete network upgrades.3#1z {O-ԍ Id.3  X -x 10.` ` We find that exceptional circumstances justify granting San Carlos Telecommunications an extension of time to offer tolllimitation services to qualifying lowincome consumers. San Carlos Telecommunications initiated service relatively recently,  X -August 1997, having acquired an exchange to provide service in its service area.$\ Dz {O-ԍ See Petitions for Waivers filed by San Carlos Apache Telecommunications Utility and U S West, AAD  {O}-File No. 9652, memorandum Opinion and Order, 11 FCC Rcd 14591 (Acct. Aud. Div., Comm. Carr. Bur. 1996). At this time, San Carlos Telecommunications is incapable of providing tolllimitation service to qualifying low income consumers because of its switching equipment, a step by step switch. Thus, San Carlos Telecommunications cannot comply with our rules until it replaces its  Xb-current switching equipment with modern switching equipment.j%bh z {O{-ԍ See note 33 supra, describing a step by step switch.j San Carlos Telecommunications also represents that it will be able to provide digital switching services to  X4-its customers by the middle of 1998.P&Z4 z {O-ԍ Arizona Companies Petition at 9, n.19. See also Letter from Sylvia Lesse, Kraskin, Lesse, & Cosson to Cheryl Leanza, FCC (filed Feb. 26, 1998) (stating that San Carlos Telecommunications "anticipates that its digital switch will be installed and operational no later than June 30, 1998").P Given its recent initiation of service and the short time frame in which it proposes to finish upgrading its equipment to provide tolllimitation service, we find that an extension of time is justified under our rules. We therefore give San Carlos until August September 30, 1998 to offer tollblocking in order to remain eligible to receive universal service support. We adopt this date based on the Commission's directive to grant only the time necessary to complete network upgrades and San Carlos's assertion that it will be able to provide tollblocking by mid1998. We thus find it in the public interest to"&0*&&qq" designate San Carlos Telecommunications as an eligible telecommunications carrier subject to its provision of tolllimitation service by September 30, 1998.  X-x 11.` ` Based on the uncontested record before us, we find that, subject to the extension of time granted above, each of the petitioners offers, or will be able to offer all of the services designated for support by the Commission. We therefore conclude that each of the petitioners complies with the requirements of section 214(e)(1)(A) to "offer the services that are supported by the Federal universal service support mechanisms under section  XH-254(c)."F'Hz yO -ԍ 47 U.S.C.  214(e)(1)(A).F  X -D.xOffer the Supported Services Using a Carrier's Own Facilities  X -x 12.` ` Consistent with the requirements of section 214(e)(1)(A), the Commission directed each carrier seeking designation as an eligible telecommunications carrier to provide a certification that it offers the supported services "either using its own facilities or a  X -combination of its own facilities and resale of another carrier's services."z( Xz {O-ԍ  214(e)(6) Public Notice at 3; see 47 U.S.C.  214(e)(1)(A).z Fort Mojave Telecommunications and Gila River Telecommunications provide resolutions from the Fort Mojave Tribe of the Fort Mojave Reservation of Arizona, California, and Nevada and the Gila River Indian Community, respectively, certifying that each of the carriers provide the  XK-supported services using "its own facilitiesbased network."Z)Kz yO-ԍ Arizona Companies Petition at 78, Attachment B.Z The Arizona Companies Petition states "[e]ach petitioner provides voice grade local exchange and interexchange access  X-services utilizing its respective facilitiesbased network."9*zz {OH-ԍ Id. at 8.9 USTA agrees that each carrier  X-offers the supported services through its own facilities.?+ z yO-ԍ USTA comments at 36.? Based on the uncontested record before us, we conclude that each of the petitioners offers the supported services using its own facilities in accordance with section 214(e)(1)(A).  X-E.xAdvertising of Supported Services  X|-x 13.` ` The Commission directed petitioners seeking designation as eligible telecommunications carriers to submit a description of how the petitioner will meet the requirements of section 214(e)(1)(B) to "advertise the availability of the [supported] services"N+0*&&qq"  X-and the charges therefor using media of general distribution."j,z {Oy-ԍ 47 U.S.C.  214(e)(1)(B); 214(e)(6) Public Notice at 3.j The Arizona Companies Petition states that "the [c]ompanies currently utilize standard subscriber notification and public notice procedures, and will advertise the availability and cost of universal service  X-elements."J-Zz yO-ԍ Arizona Companies Petition at 8.J We expect that the petitioners will use advertising techniques designed to reach all of the residents of their service areas and will ensure that customers in their service areas are aware of the availability of supported services, and, in particular, the support available to low income consumers. We conclude that each of the petitioners complies with the requirements of section 214(e)(1)(B) of the Act.  X1-F.xAntiDrug Abuse Act Certifications  X -x 14.` ` Pursuant to section 5301 of the AntiDrug Abuse Act of 1988, no applicant is eligible for any new, modified, or renewed instrument of authorization from the Commission, including authorizations issued pursuant to section 214 of the Act, unless the applicant certifies that neither it, nor any party to its application, is subject to a denial of federal  X -benefits, including Commission benefits.. z {OB-ԍ 47 C.F.R.  1.2002(a); 21 U.S.C.  862. This provision does not apply to, inter alia, "Federal, State, or local governmental entities or subdivisions thereof." 47 C.F.R.  1.2002(c). This certification must also include the names of  X-individuals specified by section 1.2002(b) of the Commission's rules.3/Dz yO-ԍ Section 1.2002(b) provides that a certification pursuant to that section shall include: "(1) If the applicant is an individual, that individual; (2) If the applicant is a corporation or unincorporated association, all officers, directors, or persons holding 5% or more of the outstanding stock or shares (voting and/or nonvoting) of the petitioner; and (3) If the applicant is a partnership, all nonlimited partners and any limited partners holding a 5% or more interest in the partnership." 47 C.F.R.  1.2002(b).3 Each of the petitioners has provided a certification consistent with the requirements of the AntiDrug  Xb-Abuse Act of 1988._0b z yO-ԍ Supplement to Arizona Companies Petition, Attachment._ We find that the petitioners have satisfied the requirements of the AntiDrug Abuse Act of 1988, as codified in sections 1.20011.2003 of the Commission's rules.  X-  IV. SUPPORT RETROACTIVE TO JANUARY 1, 1998 ĐTP  X-x15.` ` In the 214(e)(6) Public Notice, the Commission directed petitioners seeking universal service support retroactive to January 1, 1998 to: (1) include a request for retroactive support in its petition; (2) demonstrate that, as of January 1, 1998, it met the requirements set forth in section 214(e)(1); and (3) set forth the steps it has taken to receive" 00*&&qqp"  X-designation as an eligible telecommunications carrier in a timely manner.U1z {Oy-ԍ 214(e)(6) Public Notice at 34.U  X-x16.` ` All petitioners have sought support retroactive to January 1, 1998.Z2Zz yO-ԍ Supplement to Arizona Companies Petition at 12.Z USTA and  X-NTCA support granting retroactive support.?3z yOV-ԍ USTA comments at 78.? We find that each of the petitioners met the requirements set forth in section 214(e)(1) as of January 1, 1998 and has taken adequate steps to receive designation in a timely manner. Specifically, the initial Arizona Companies Petition requesting designation as eligible telecommunications carriers was filed on December 18, 1997, only 17 days after section 214(e)(6) became law, and 11 days before the Commission issued its procedures for carriers seeking designation from the Commission. In addition, the Arizona Companies Petition included, as of its filing date, tribal resolutions and affidavits attesting to the carriers' compliance with the requirements necessary to be designated eligible telecommunications carriers.  X -x17.` ` We note, however, that pursuant to section 36.611, a carrier cannot receive high cost loop support until it provides certain historical cost data to the National Exchange  X -Carrier Association (NECA).H4 zz yO-ԍ Specifically, section 36.611(a) states that "[i]n order to allow determination of the study areas which are entitled to an expense adjustment, each incumbent local exchange carrier (ILEC) must provide [NECA] with [certain historical cost data]. This information is to be filed with the [NECA] on July 31st of each year. The information filed on July 31st of each year will be used in the jurisdictional allocations underlying the cost support data for the access charge tariffs to be filed the following October." 47 C.F.R.  36.611(a).H The cost data are filed on July 31st of each year. Since San Carlos Telecommunications did not initiate operation until August 1997, it could not provide the necessary information to NECA in order to receive high cost loop support beginning in 1998. The Arizona Companies Petition indicates that it is aware that San Carlos Telecommunications cannot receive high cost loop support pursuant to sections 36.611 and  X4-36.612 of the Commission's rules as of January 1, 1998.K54* z yO-ԍ Arizona Companies Petition at n.4K We agree that San Carlos Telecommunications should receive high cost loop support consistent with sections 36.611 and 36.612 of the Commission's rules and will not receive high cost loop support retroactively to January 1, 1998.  X-x18.` ` With the exception of high cost loop support for San Carlos Telecommunications, we conclude that each of the petitioners will receive federal universal service support retroactive to January 1, 1998. We direct the Universal Service Administrative Company to provide such support to the petitioners, and to take the steps"| 50*&&qq2" necessary to minimize any interruptions in their receipt of support.  X- V. ORDERING CLAUSES ĐTP  X-x19.` ` Accordingly, IT IS ORDERED that, pursuant to the authority contained in section 214(e)(6) of the Communications Act and section 0.291 of the Commission's rules, 47 U.S.C.  214(e)(6) and 47 C.F.R.  0.291, Fort Mojave Telecommunications, Inc., Gila River Telecommunications, Inc., San Carlos Telecommunications, Inc., and Tohono O'odham Utility Authority ARE individually DESIGNATED ELIGIBLE TELECOMMUNICATIONS CARRIERS. Such designation is effective immediately.  X -x20.` ` IT IS FURTHER ORDERED that the requests by Fort Mojave Telecommunications, Gila River Telecommunications, and Tohono O'odham Utility Authority to receive an extension of time to offer toll control are DISMISSED AS MOOT.  X -x` ` x21.` ` IT IS FURTHER ORDERED that San Carlos Telecommunications' request for an extension of time to offer toll blocking IS GRANTED until no later than August 15, 1998; its designation as an eligible telecommunications carrier after August 15, 1998 is subject to its provision of tolllimitation service by August 15, 1998.  X4-x22. ` ` IT IS FURTHER ORDERED that Fort Mojave Telecommunications, Inc., Gila River Telecommunications, Inc., San Carlos Telecommunications, Inc., and Tohono O'odham Utility Authority WILL RECEIVE, retroactive to January 1, 1998, federal universal service support, except that San Carlos Telecommunications will not receive high cost loop support retroactive to January 1, 1998.  X-x23.` ` IT IS FURTHER ORDERED that a copy of this Memorandum Opinion and Order and a list of designated eligible telecommunications carriers SHALL BE transmitted to the Universal Service Administrative Company consistent with the Bureau's Public Notice, DA1892 (rel. Sept. 29, 1997). x` `  hh@A. Richard Metzger, Jr. x` `  hh@Chief, Common Carrier Bureau