Verizon Wireless proposed to FCC methodology for wireless carrier...

revising USF contribution methodology (CD Oct 28 p7). In separate filing, Verizon Wireless said safe harbor played key role in minimizing complexity of wireless carrier contributions to USF. Challenge for wireless carriers is in separating end-user revenue into interstate and intrastate categories, it said. Carriers can use software, system upgrades and baseline assumptions to track interstate and intrastate minutes of use, filing said. That can create “reasonable proxy” for allocating wireless revenue for USF contributions, it said. “A safe harbor, updated to reflect current wireless calling activity, furthers the policy objectives of promoting equitable contributions, fund stability and administrative simplicity,” it said. Verizon Wireless said because calling patterns could vary among states and carriers, operators should be able to file interstate/international revenue calculation based on company-specific calling patterns if they had system to track such traffic. Carriers could create such systems based on FCC-approved methodology and Commission could require retention of records that were used to develop company- specific levels. Proposed methodology would: (1) Track min. of use from call records, dividing all interstate and international min. by total min. over certain time period to come up with percentage of interstate and international min. of use. (2) Multiply that percentage of interstate/international min. of use by qualifying service revenue to come up with total revenue base that would count toward USF contribution.