FCC Harmonizes Part 32/Part 36 Rules


The FCC has adopted a Report and Order simplifying its Part 36 jurisdictional separations rules and allowing for all carriers to use the simpler jurisdictional separations processes previously reserved for smaller carriers. This change also harmonizes the Commission’s Part 36 rules with the Commission’s previous amendments to the agency’s Part 32 accounting rules. Earlier this year, the FCC released a notice of proposed rulemaking proposing the recent rule changes, which themselves were based off of recommendations by the Federal-State Joint Board on Jurisdictional Separations. Traditionally, Part 32 rules divided LECs into large carriers (Class A) and smaller carriers with less than $157 million in annual regulated revenues (Class B). After the FCC began its Part 32 Reform Order reformation process, which culminated in all carriers following the less onerous requirements applicable to Class B carriers, it began the process to harmonize the Part 32 and Part 36 rules. Specifically, the Report and Order: (1) removes from the Commission’s Part 36 rules references to Class A accounts; (2) amends Section 36.112 of the Commission’s rules to allow former Class A carriers to select between the legacy Class A and Class B procedures in apportioning their general support facilities costs; and (3) corrects certain stylistic and typographical errors found in Part 36, so that they are clearer to read and interpret. The Part 36 rules changes become effective January 1, 2019.

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