The Federal Communications Commission (FCC) has implemented a new rule that requires all tariff filers, including competitive local exchange carriers (CLECs), to utilize the FCC’s Electronic Tariff Filing System (ETFS). Until now, only incumbent carriers were required to use ETFS.

CLECs will have 60 days, starting on November 17, 2011, to file a copy of their current tariff, also known as the carrier’s Base Document. CLECs must include a transmittal letter with their Base Document filing. There is no filing fee applicable to this initial filing. A CLEC may not make changes to its Base Document prior to filing it via ETFS. All subsequent tariff revisions, along with any associated working papers, must be filed in ETFS going forward.

Any tariffs that are currently on file with the FCC, but are not refiled in ETFS by January 17, 2012, will be cancelled by the FCC.

A copy of the Report and Order establishing the rule may be found here. (FCC-11-92, WC Docket No. 10-141) A copy of the FCC’s public notice that announced the window for filing may be found here. (DA-11-1706, WC Docket No. 10-141)

For more information please contact Katherine Barker Marshall or any of our attorneys in the Arent Fox Telecommunications Practice Group, including: