On February 12, 2009, the Ad Hoc Coalition of International Telecommunications Companies filed a Petition for Declaratory Ruling with the FCC. In this Petition, the Coalition asked the FCC to hold that, among other things, qualifying downstream carriers may choose to either accept supplier pass-through surcharges or pay Universal Service fees directly.
The Coalition asserts that members currently face discriminatory, indirect USF obligations resulting from pass-through charges from their underlying carriers, despite qualifying for exemptions from direct contribution requirements. This problem is particularly prevalent for carriers that qualify for the "de minimis" exemption.
The Coalition requested that the FCC issue a declaratory ruling finding that "de minimis" providers may choose whether to (a) have their underlying carrier/supplier pass through surcharges OR (b) pay contributions directly, even if the contributions would be less than $10,000. In addition, the Coalition asked the FCC to hold that Prepaid Calling Card Providers' distributor revenues are not "end-user" revenues and allow reporting of actual receipts only.
The ACITC Petition is available for review here.