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Federal Register / Vol. 70, No.

138 / Wednesday, July 20, 2005 / Proposed Rules 41655

this Order is available for public Dortch, Office of the Secretary, Federal contained data submissions and
inspection Monday through Thursday Communications Commission, 445 12th economic analyses. Moreover, there was
from 8 a.m. to 4:30 p.m. and Friday from Street, SW., Washington, DC 20554. In approximately a one-week delay before
8 a.m. to 11:30 a.m. in the Commission’s addition, parties should send a copy of all of the comments were available on
Consumer and Governmental Affairs their filings to Pamela Arluk, Pricing the Commission’s Electronic Comment
Bureau, Reference Information Center, Policy Division, Wireline Competition Filing System (ECFS). In the interest of
Room CY–A257, 445 Twelfth Street, Bureau, Federal Communications developing a thorough and complete
SW., Washington, DC 20554. The Commission, Room 5–C434, 445 12th record in this proceeding, the Bureau
complete text is also available on the Street, SW., Washington, DC 20554. grants the Petitioners’ requests, and
Commission’s Internet Site at http:// Parties shall also serve one copy with hereby extends the reply comment
www.fcc.gov. Alternative formats are the Commission’s copy contractor, Best deadline to July 29, 2005. This
available to persons with disabilities by Copy and Printing, Inc. (BCPI), Portals extension should allow parties adequate
contacting Brian Millin at (202) 418– II, 445 12th Street, SW., Room CY–B402, time to review and respond to the
7426 or TTY (202) 418–7365. The Washington, DC 20554, (202) 488–5300, record in this proceeding. All other
complete text of the Order may be or via e-mail to fcc@bcpiweb.com. filing requirements set forth in the
purchased from the Commission’s Documents in WC Docket No. 05–25, NPRM remain in effect.
duplicating contractor, Best Copying RM–10593 are available for review
and Printing, Inc., Room CY–B402, 445 through the ECFS and are available for Ordering Clause
Twelfth Street, SW., Washington, DC public inspection and copying during Accordingly, it is ordered that,
20554, telephone (202) 488–5300, business hours at the FCC Reference pursuant to the authority contained in
facsimile (202) 488–5563, or e-mail at Information Center, Portals II, 445 12th sections 4(i), 4(j), and 303(r) of the
http://www.bcpiweb.com. Street SW., Room CY–A257, Communications Act, as amended, 47
When filing reply comments, parties Washington, DC 20554. The documents U.S.C. 154(i), 154(j), and 303(r), and
should reference WC Docket No. 05–25, may also be purchased from BCPI, §§ 0.91, 0.204(b), 0.291, 1.45, and 1.415
and RM–10593 and conform to the filing telephone (202) 488–5300, facsimile of the Commission’s rules, 47 CFR 0.91,
procedures referenced in the Order and (202) 488–5563, TTY (202) 488–5562, or 0.204(b), 0.291, 1.45, and 1.415, the
Notice of Proposed Rulemaking. See by e-mail at fcc@bcpiweb.com. deadline for filing reply comments in
Special Access Rates for Price Cap Local response to the NPRM is extended to
Synopsis of Order
Exchange Carriers, AT&T Corp. Petition July 29, 2005.
for Rulemaking to Reform Regulation of On January 31, 2005, the Commission
Incumbent Local Exchange Carrier Rates released a Notice of Proposed Federal Communications Commission.
for Interstate Special Access Services, Rulemaking (NPRM) in WC Docket No. Tamara L. Preiss,
WC Docket No. 05–25, RM–10593, 05–25, RM–10593. See Special Access Chief, Pricing Policy Division, Wireline
Order and Notice of Proposed Rates for Price Cap Local Exchange Competition Bureau.
Rulemaking, 70 FR 19381, April 13, Carriers, AT&T Corp. Petition for [FR Doc. 05–14420 Filed 7–19–05; 8:45 am]
2005. All pleadings may be filed using Rulemaking to Reform Regulation of BILLING CODE 6712–01–P
the Commission’s Electronic Comment Incumbent Local Exchange Carrier Rates
Filing System (ECFS) or by filing paper for Interstate Special Access Services,
copies. Comments filed through the WC Docket No. 05–25, RM–10593, FEDERAL COMMUNICATIONS
ECFS can be sent as an electronic file Order and Notice of Proposed COMMISSION
via the Internet to http://www.fcc.gov/e- Rulemaking, 70 FR 19381, April 13,
file/ecfs.html. Commenters must 2005. In the NPRM, the Commission 47 CFR Part 52
transmit one electronic copy of the commenced a broad examination of the
comments to each docket or rulemaking regulatory framework to apply to price [CC Docket No. 95–116; FCC 05–87]
number referenced in the caption. In cap local exchange carriers’ (LECs)
completing the transmittal screen, interstate special access services after Telephone Number Portability
commenters should include their full June 30, 2005, and sought comment on
the special access regime that should AGENCY: Federal Communications
name, U.S. Postal Service mailing Commission.
address, and the applicable docket or follow the expiration of the CALLS
rulemaking number, in this case WC plan, including whether to maintain or ACTION: Proposed rule.
Docket No. 05–25, RM–10593. Parties modify the Commission’s pricing
flexibility rules for special access SUMMARY: This document seeks
may also submit an electronic comment
services. The comment deadline was comment on an Initial Regulatory
by Internet e-mail. To get filing
June 13, 2005, and the reply comment Flexibility Analysis (IRFA) of the
instructions for e-mail comments,
deadline is July 12, 2005. Intermodal Order concerning wireline-
commenters should send an e-mail to
ecfs@fcc.gov, and should include the CompTel/ALTS and the United States to-wireless number portability. The
following words in the body of the Telecom Association (USTA) (together, Federal Communications Commission
message, ‘‘get form <your e-mail the Petitioners) filed motions with the will use the specific IRFA comments it
address>.’’ A sample form and Commission, requesting a seventeen-day receives in preparing a Final Regulatory
directions will be sent in reply. extension of the deadline for filing reply Flexibility Analysis in connection with
Parties who choose to file by paper comments. The Petitioners explain that the Intermodal Order and in
must file an original and four copies of the requested extension would allow all determining whether to modify the
each filing. If more than one docket or parties the opportunity to better intermodal porting rules with respect to
rulemaking number appears in the evaluate, and respond to, the complex their application to small entities in
caption of this proceeding, commenters economic analyses offered by many light of the requirements of the
must submit two additional copies for commenters in this proceeding. On June Regulatory Flexibility Act (RFA).
each additional docket or rulemaking 13, 2005, the Commission received more DATES: Comments are due on or before
number. All filings must be addressed to than 2,000 pages of comments from August 19, 2005, and reply comments
the Commission’s Secretary, Marlene H. multiple parties, many of which are due on or before September 6, 2005.

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41656 Federal Register / Vol. 70, No. 138 / Wednesday, July 20, 2005 / Proposed Rules

ADDRESSES: You may submit comments, contractor, Qualex International, Portals may be filed using: (1) The
identified by CC Docket No. 95–116, by II, 445 12th St., SW., Room CY–B402, Commission’s Electronic Comment
any of the following methods: Washington DC, telephone (202) 863– Filing System (ECFS), (2) the Federal
• Federal eRulemaking Portal: http:// 2893, facsimile (202) 863–2898, or via e- Government’s eRulemaking Portal, or (3)
www.regulations.gov. Follow the mail qualexint@aol.com. Additionally, by filing paper copies. See Electronic
instructions for submitting comments. the complete item is available on the Filing of Documents in Rulemaking
• Agency Web Site: http:// Federal Communications Commission’s Proceedings, 63 FR 24121 (1998).
www.fcc.gov. Follow the instructions for Web site at http://www.fcc.gov/wtb. • Electronic Filers: Comments may be
submitting comments on the http:// filed electronically using the Internet by
Synopsis of the Public Notice accessing the ECFS: http://www.fcc.gov/
www.fcc.gov/cgb/ecfs/.
• E-mail: ecfs@fcc.gov. On March 11, 2005, the United States cgb/ecfs/ or the Federal eRulemaking
• Mail: All filings must be addressed Court of Appeals for the District of Portal: http://www.regulations.gov.
to the Commission’s Secretary, Office of Columbia Circuit remanded to the Filers should follow the instructions
the Secretary, Federal Communications Federal Communications Commission provided on the website for submitting
Commission. the Intermodal Order, concerning comments.
• U.S. Postal Service first-class, porting between wireline and wireless • For ECFS filers, if multiple docket
Express, and Priority mail should be carriers. See United States Telecom or rulemaking numbers appear in the
addressed to 445 12th Street, SW., Ass’n v. FCC, 400 F.3d 29 (D.C. Cir. caption of this proceeding, filers must
Washington DC 20554. 2005). The Court determined that the transmit one electronic copy of the
• The Commission’s contractor will Federal Communications Commission comments for each docket or
receive hand-delivered or messenger- had failed to prepare a Final Regulatory rulemaking number referenced in the
delivered paper filings for the Flexibility Analysis regarding the caption. In completing the transmittal
Commission’s Secretary at 236 impact of the Intermodal Order on small screen, filers should include their full
Massachusetts Avenue, NE., Suite 110, entities, as defined by the RFA, which name, U.S. Postal Service mailing
Washington, DC 20002. the Court found to have been required address, and the applicable docket or
• Commercial overnight mail (other by the RFA, 5 U.S.C. 604. The Court rulemaking number. Parties may also
than U.S. Postal Service Express Mail accordingly directed the Federal submit an electronic comment by
and Priority Mail) must be sent to 9300 Communications Commission to Internet e-mail. To get filing
East Hampton Drive, Capitol Heights, prepare the required Final Regulatory instructions, filers should send an e-
MD 20743. Flexibility Analysis, and stayed future mail to ecfs@fcc.gov, and include the
Instructions: All submissions received enforcement of the Intermodal Order following words in the body of the
must include the agency name and ‘‘only as applied to carriers that qualify message, ‘‘get form.’’ A sample form and
docket number for this proceeding. All as small entities under the RFA’’ until directions will be sent in response.
comments received will be posted the agency prepares and publishes that • Paper Filers: Parties who choose to
without change to http://www.fcc.gov/ analysis. 400 F.3d at 43. file by paper must file an original and
cgb/ecfs/, including any personal In the Public Notice, to prepare to four copies of each filing. If more than
information provided. For detailed comply with the Court’s direction, the one docket or rulemaking number
instructions on submitting comments Federal Communications Commission appears in the caption of this
seeks comment on an Initial Regulatory proceeding, filers must submit two
and additional information on the
Flexibility Analysis of the Intermodal additional copies for each additional
rulemaking process, see the
Order. The Commission will use the docket or rulemaking number.
SUPPLEMENTARY INFORMATION section of
specific IRFA comments it receives in Filings can be sent by hand or
this document.
preparing a Final Regulatory Flexibility messenger delivery, by commercial
Docket: For access to the docket to
Analysis in connection with the overnight courier, or by first-class or
read background documents or
Intermodal Order and in determining overnight U.S. Postal Service mail
comments received, go to http://
whether to modify the intermodal (although we continue to experience
www.fcc.gov/cgb/ecfs/.
porting rules with respect to their delays in receiving U.S. Postal Service
FOR FURTHER INFORMATION CONTACT: application to small entities in light of mail). All filings must be addressed to
Jennifer Salhus, Attorney Advisor, the requirements of the RFA. The the Commission’s Secretary, Office of
Spectrum and Competition Policy Federal Communications Commission the Secretary, Federal Communications
Division, Wireless Telecommunications also expects to publish a document Commission.
Bureau, at (202) 418–1310 (voice) or amending 47 CFR Part 52 at a later date, • The Commission’s contractor will
(202) 418–1169 (TTY) or Pam Slipakoff, pursuant to the Intermodal Order, receive hand-delivered or messenger-
Attorney Advisor, Telecommunications which the court held effectively delivered paper filings for the
Access Policy Division, Wireline amended the Federal Communications Commission’s Secretary at 236
Competition Bureau at (202) 418–7705 Commission’s previous legislative rule. Massachusetts Avenue, NE., Suite 110,
(voice) or (202) 418–0484 (TTY). This is a ‘‘permit but disclose’’ Washington, DC 20002. The filing hours
SUPPLEMENTARY INFORMATION: This is a proceeding pursuant to § 1.1206 of the at this location are 8 a.m. to 7 p.m. All
summary of the Federal Commission’s rules. Ex parte hand deliveries must be held together
Communications Commission Public presentations that are made with respect with rubber bands or fasteners. Any
Notice released April 22, 2005, FCC 05– to the issues involved in the IRFA will envelopes must be disposed of before
87. The full text of the Public Notice be allowed but must be disclosed in entering the building.
and its appendices is available for accordance with the requirements of • Commercial overnight mail (other
inspection and copying during normal § 1.1206(b) of the Commission’s rules. than U.S. Postal Service Express Mail
business hours in the FCC Reference Pursuant to §§ 1.415 and 1.419 of the and Priority Mail) must be sent to 9300
Center, Room CY–A257, 445 12th St., Commission’s rules, 47 CFR 1.415, East Hampton Drive, Capitol Heights,
SW., Washington DC 20554. The 1.419, interested parties may file MD 20743.
complete text may also be purchased comments and reply comments on or • U.S. Postal Service first-class,
from the Commission’s duplicating before the dates indicated. Comments Express, and Priority mail should be

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Federal Register / Vol. 70, No. 138 / Wednesday, July 20, 2005 / Proposed Rules 41657

addressed to 445 12th Street, SW., C. Description and Estimate of the business size standard (e.g., a telephone
Washington DC 20554. Number of Small Entities To Which the communications business having 1,500
People with Disabilities: Contact the Rules Would Apply or fewer employees), and ‘‘is not
FCC to request materials in accessible 3. The RFA directs agencies to dominant in its field of operation.’’ The
formats (braille, large print, electronic provide a description of and, where SBA’s Office of Advocacy contends that,
files, audio format, etc.) by e-mail at feasible, an estimate of the number of for RFA purposes, small incumbent
FCC504@fcc.gov or call the Consumer & small entities that may be affected by LECs are not dominant in their field of
Governmental Affairs Bureau at 202– the proposed rules, if adopted, 5 U.S.C. operation because any such dominance
418–0531 (voice), 202–418–7365 (TTY). 603(b)(3). The RFA generally defines the is not ‘‘national’’ in scope. We have
term ‘‘small entity’’ as having the same therefore included small incumbent
Initial Regulatory Flexibility Analysis LECs in this RFA analysis, although we
meaning as the terms ‘‘small business,’’
As required by the Regulatory ‘‘small organization,’’ and ‘‘small emphasize that this RFA action has no
Flexibility Act, as amended, 5 U.S.C. governmental jurisdiction.’’ In addition, effect on the Commission’s analyses and
603, the Federal Communications the term ‘‘small business’’ has the same determinations in other, non-RFA
Commission has prepared this Initial meaning as the term ‘‘small business contexts.
Regulatory Flexibility Analysis of the concern’’ under Section 3 of the Small 7. Neither the Commission nor the
possible significant economic impact on Business Act. Under the Small Business SBA has developed a small business
a substantial number of small entities of Act, a ‘‘small business concern’’ is one size standard specifically for incumbent
the rules and policies described in the that: (1) Is independently owned and local exchange services. The appropriate
Intermodal Order concerning wireline- operated; (2) is not dominant in its field size standard under SBA rules is for the
to-wireless number portability. Written of operation; and (3) satisfies any category Wired Telecommunications
public comments are requested on this additional criteria established by the Carriers. Under that size standard, such
IRFA. Comments must be identified as Small Business Administration (SBA). a business is small if it has 1,500 or
responses to the IRFA and must be filed 4. In this section, we describe and fewer employees. According to
by the deadlines for comments estimate the number of small entities Commission data, 1,310 carriers have
indicated on the Public Notice. This is that may be affected by our action. The reported that they are engaged in the
a summary of the full text of the IRFA. most reliable source of information provision of incumbent local exchange
The full text of the IRFA may be found regarding the total numbers of certain services. Of these 1,310 carriers, an
at Appendix A of the full text of the common carriers and related providers estimated 1,025 have 1,500 or fewer
Public Notice. The Commission will nationwide appears to be the data that employees and 285 have more than
send a copy of the IRFA to the Chief the Federal Communications 1,500 employees. Consequently, the
Counsel for Advocacy of the Small Commission publishes in its Trends in Commission estimates that most
Business Administration. See 5 U.S.C. Telephone Service report. In addition, providers of incumbent local exchange
603(a). In addition, this will be the SBA has developed size standards service are small entities.
published in the Federal Register. for small businesses within the 8. Competitive Local Exchange
commercial census category of Wired Carriers, Competitive Access Providers
A. Need for, and Objectives of, the Rules
Telecommunications Carriers. Under (CAPs), ‘‘Shared-Tenant Service
1. The Intermodal Order involved this category, a business is small if it has Providers,’’ and ‘‘Other Local Service
rules and policies aimed at ensuring 1,500 or fewer employees. Below, we Providers.’’ Neither the Commission nor
wide availability of number portability discuss the total estimated numbers of the SBA has developed a small business
for consumers across the country. By small businesses that might be affected size standard specifically for these
making it easier for greater numbers of by our actions. service providers. The appropriate size
consumers to switch freely among 5. Wired Telecommunications standard under SBA rules is for the
carriers, the Intermodal Order was Carriers. The SBA has developed a category Wired Telecommunications
intended to promote competition and small business size standard for Wired Carriers. Under that size standard, such
encourage carriers to provide new Telecommunications Carriers, which a business is small if it has 1,500 or
services and lower prices for consumers. consists of all such companies having fewer employees. According to
To obtain these objectives, the order 1,500 or fewer employees. According to Commission data, 563 carriers have
required porting to any wireless carrier Census Bureau data for 1997, there were reported that they are engaged in the
whose ‘‘coverage area’’ overlaps the 2,225 firms in this category, total, that provision of either competitive access
geographic location of the original rate operated for the entire year. Of this provider services or competitive LEC
center associated with the number to be total, 2,201 firms had employment of services. Of these 563 carriers, an
ported, provided that the porting-in 999 or fewer employees, and an estimated 472 have 1,500 or fewer
carrier maintains the number’s original additional 24 firms had employment of employees and 91 have more than 1,500
rate center designation following the 1,000 employees or more. Thus, under employees. In addition, 14 carriers have
port. The order defined wireless this size standard, the majority of firms reported that they are ‘‘Shared-Tenant
‘‘coverage area’’ as the area in which can be considered small. In addition, Service Providers,’’ and all 14 are
wireless service can be received from limited preliminary census data for estimated to have 1,500 or fewer
the wireless carrier. 2002 indicate that the total number of employees. In addition, 37 carriers have
wired communications carriers reported that they are ‘‘Other Local
B. Legal Basis for Rules
increased approximately 34 percent Service Providers.’’ Of the 37, an
2. The Intermodal Order was from 1997 to 2002. estimated 36 have 1,500 or fewer
authorized under § 52.23 of the Federal 6. Incumbent Local Exchange Carriers. employees and one has more than 1,500
Communications Commission’s rules, We have included small incumbent employees. Consequently, the
47 CFR 52.23, and in Sections 1, 3, 4(i), local exchange carriers (LECs) in this Commission estimates that most
201, 202, 251 of the Communications RFA analysis. As noted above, a ‘‘small providers of competitive local exchange
Act of 1934, as amended, 47 U.S.C. 151, business’’ under the RFA is one that, service, competitive access providers,
153, 154(i), 201, 202, and 251. inter alia, meets the pertinent small ‘‘Shared-Tenant Service Providers,’’ and

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41658 Federal Register / Vol. 70, No. 138 / Wednesday, July 20, 2005 / Proposed Rules

‘‘Other Local Service Providers’’ are that does not have a physical point of imposing a technically infeasible
small entities. interconnection or numbering resources requirement; and (B) is consistent with
in the rate center associated with the the public interest, convenience, and
D. Description of Projected Reporting,
ported number would give wireless necessity. Numerous petitions have
Recordkeeping, and Other Compliance
carriers an unfair competitive been filed with state commissions since
Requirements for Small Entities
advantage. The order found however, the Intermodal Order’s release and in
9. Requiring porting beyond wireline that these considerations did not justify many of these cases, states have granted
rate center boundaries could impose denying wireline consumers the benefit temporary or permanent relief from LNP
compliance burdens on small entities. of being able to port their numbers to requirements to small carriers. We seek
First, by making porting more widely wireless carriers. In addition, the order comment on the effectiveness of this
available, the requirement may increase noted that each type of service offers its mechanism for addressing any potential
the amount of telephone numbers that own advantages and disadvantage and burdens on small carriers.
small carriers may be required to port. that consumers would consider these
To handle this increased porting attributes in determining whether or not F. Overlapping, Duplicating, or
volume, small carriers may need to add to port their numbers. The Intermodal Conflicting Federal Rules
personnel, update porting procedures, Order also considered the concern 14. None.
or upgrade software. In addition to the expressed by small carriers that Federal Communications Commission.
compliance burdens associated with requiring porting beyond wireline rate
increased porting volume, porting Marlene H. Dortch,
center boundaries would lead to
beyond wireline rate center boundaries Secretary.
increased transport costs. The order
may cause small or rural carriers to concluded that such concerns were [FR Doc. 05–14179 Filed 7–19–05; 8:45 am]
incur transport costs associated with outside the scope of the number BILLING CODE 6712–01–P
delivering calls to ported numbers portability proceeding and noted that
served by distant switches. We seek the rating and routing issues raised by
comment on the costs associated with the rural wireline carriers were also FEDERAL COMMUNICATIONS
these potential compliance burdens. implicated in the context of non-ported COMMISSION
10. In addition to the impacts numbers and were before the Federal
associated with transporting calls to 47 CFR Part 54
Communications Commission in other
ported numbers, by making it easier for proceedings. [WC Docket No. 05–195, CC Docket No. 96–
more consumers to port, the 13. The order also, for wireline 45, CC Docket No. 02–6, WC Docket No.
requirements may cause small or rural carriers operating in areas outside of the 02–60, WC Docket No. 03–109, CC Docket
carriers to lose customers. Small carriers 100 largest MSAs, waived, until May 24, No. 97–21; FCC 05–124]
have expressed concern that permitting 2004, the requirement that these carriers
porting beyond wireline rate center port numbers to wireless carriers that do Comprehensive Review of Universal
boundaries would give large wireless not have a point of interconnection or Service Fund Management,
carriers an unfair competitive advantage numbering resources in the rate center Administration, and Oversight
over smaller LECs by making it easier where the customer’s wireline number
for more consumers to port numbers to AGENCY: Federal Communications
is provisioned. The order noted that the
larger nationwide carriers. Commission.
transition period would help ensure a
smooth transition for carriers operating ACTION: Notice of proposed rulemaking.
E. Steps Taken To Minimize Significant
Economic Impact on Small Entities, and outside of the 100 largest MSAs and
SUMMARY: In this document, the
Significant Alternatives Considered provide them with sufficient time to
Commission initiates a broad inquiry
make necessary modifications to their
11. The RFA requires an agency to into the management and
systems. The order also noted that
describe any significant alternatives that administration of the Universal Service
carriers could file petitions for waiver of
it has considered in reaching its Fund (USF), as well as the
their obligation to port numbers to
proposed approach, which may include Commission’s oversight of the USF and
wireless carriers, if they could provide
the following four alternatives (among the USF Administrator. We seek
substantial, credible evidence that there
others): (1) The establishment of are special circumstances that warrant comment on ways to improve the
differing compliance or reporting departure from existing rules. management, administration, and
requirements or timetables that take into 14. In addition to the steps taken by oversight of the USF, including
account the resources available to small the Federal Communications simplifying the process for applying for
entities; (2) the clarification, Commission, pursuant to section USF support, speeding the
consolidation, or simplification of 251(f)(2) of the Communications Act of disbursement process, simplifying the
compliance or reporting requirements 1934, as amended, carriers with fewer billing and collection process,
under the rule for small entities; (3) the than two percent of the nation’s addressing issues relating to the
use of performance, rather than design, subscriber lines in the aggregate Universal Service Administrative
standards; and (4) an exemption from nationwide may petition state Company (USAC or the Administrator),
coverage of the rule, or any part thereof, commissions to suspend or modify the and exploring performance measures
for small entities. LNP requirements. Under the terms of suitable for assessing and managing the
12. The Federal Communications section 251(f)(2), the state commission USF programs. We also seek comment
Commission has previously addressed shall grant such petition to the extent on ways to further deter waste, fraud,
concerns raised by small and rural that, and for such duration as, the state and abuse through audits of USF
carriers when considering intermodal commission determines that such beneficiaries or other measures, and on
portability issues. Specifically, the suspension or modification: (A) Is various methods for recovering
Intermodal Order considered limiting necessary to avoid a significant adverse improperly disbursed funds.
the scope of intermodal porting based economic impact on end users, to avoid DATES: Comments are due on or before
on the small carrier concern that imposing an unduly economically October 18, 2005. Reply comments are
requiring porting to a wireless carrier burdensome requirement, or to avoid due on or before December 19, 2005.

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