USTA proposed interim universal service contributions system that...

said “the most practical, lawful and risk-free course” would be use of interstate, end-user revenue as contribution base. FCC could implement “collect and remit” system in which Universal Service Administrative Co. (USAC) could set quarterly contribution percentage based on projected fund needs and projected collected revenue, McCormick said. “Carriers would then remit payments based on the application of the USAC percentage to the interstate retail revenues actually collected,” McCormick said. Other aspects of proposal: (1) Raising “safe harbor” contribution limit for wireless carriers to 20-28% range from current 15% “unless a wireless provider can determine its actual interstate retail revenue.” Safe harbor percentage should apply to wireless carriers on companywide basis, USTA said. (2) To determine interstate retail revenue, CLECs “should impute an amount equal to the subscriber line charge (SLC) assessed by the incumbent local exchange carrier in a CLEC’s service area.” Letter said CLECs should have option of “reporting the imputation based on the actual SLC amount assessed by the ILEC or an amount equal to the nationwide SLC cap.” (3) Capping recovery of administrative, billing and overhead costs that contributors to universal service support programs are allowed to include in the universal service charge collected on customers’ bills. USTA said carriers should be allowed to recover “just and reasonable costs” but it was concerned that some were “recovering excessive amounts.” Letter emphasized that plan was interim proposal and that USTA still was committed to connections-based contribution methodology.