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Federal Register / Vol. 86, No. 166 / Tuesday, August 31, 2021 / Rules and Regulations However, the Bureau rejects CCAs request because network integration costs are highly variable, making it difficult to develop a quantifiable range of cost estimates based on the record and information provided by communications industry stakeholders to Widelity. As noted in this document, the final Catalog does, however, include specific integration costs, such as SAS
integration, that are specific to the type of equipment which may be eligible for reimbursement. Participants seeking reimbursement for network integration costs not identified in the Catalog will need to provide individualized cost estimates with supporting documentation.
86. RWA asked the Commission to modify the Catalog to include VoLTE
compatible replacement subscriber handsets to replace CDMA-capable voice services on some handheld devices. Relatedly, CCA asked the Commission to modify the Catalog to clarify that replacements to add, upgrade, or replace HSS, IMS, PCRF, etc. to support UMTS/LTE/VoLTE
devices fall within the catalogs purview. In the 2021 Supply Chain Order, however, the Commission rejected RWAs request, finding CDMA-capable handsets not produced or provided by Huawei or ZTE ineligible for reimbursement under the Reimbursement Program rules because replacing such handsets with VoLTEcompatible subscriber handsets is not reasonably necessary to the removal, replacement, and disposal of covered communications equipment or service.
Consistent with the 2021 Supply Chain Order, the Bureau declines to modify the Catalog to include handsets and other end user customer premises equipment CPE outside of the limited CPE already accounted for in the Catalog.
87. RWBC asked the Commission to modify the Catalog to include cost estimates for deploying fiber backhaul equipment, arguing that fiber backhaul facilities should be considered comparable to microwave backhaul facilities under the Emerging Technologies compatibility standard.
Similarly, USTelecom asked the Commission to clarify whether leasing additional capacity on a long-term basis like a fiber IRU that would support the parallel network is eligible for reimbursement. In the 2021 Supply Chain Order, however, the Commission did not consider replacing microwave backhaul with fiber backhaul . . .
necessary for the removal, replacement, and disposal of covered communications equipment or services. Instead, the Commission
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viewed such fiber link replacements as a technology upgrade, and not a reasonable, comparable replacement.
As the Commission explained in the 2021 Supply Chain Order, if the participant decides to upgrade its equipment, it will bear the difference in cost between the comparable replacement and the upgrade, must provide price quotes for the comparable replacement with its application, as opposed to relying on the cost estimates in the Catalog, and must certify that the estimated cost is in good faith. Fiber backhaul facilities and additional capacity would be considered an upgrade, not a reasonable, comparable replacement. Accordingly, the Bureau declines to add this equipment as a separate cost category to the Catalog.
88. Ericsson argues that the preliminary catalog only included Internet of Things IoT software licenses associated with core network nodes, which does not reflect the need to replace existing Machine-toMachine M2M and IoT software licenses in the Radio Access Networks RAN nodes. Ericsson asked the Commission to expand the current Catalog to include specific RAN
software licenses for existing functionality, such as M2M, Cat-M1, Narrowband IoT, and similar items because it would ensure the continuation of IoT capabilities in one frequency band in all sectors of an existing LTE site with typical 2, 4, and 8-port radios. The Bureau declines to implement Ericssons request because the functionality cited, Internet of Things capabilities, is not reasonably necessary for core network operations and therefore is outside of the scope of the Catalog. The cost categories Ericsson requests to include in the Catalog are not part of the core network but rather are used by end users to connect to advanced communications services. In the 2021 Supply Chain Order, the Commission found that Internet of Things devices, used by end users to access and utilize advanced communications services are distinctly different from the cell sites, backhaul, core network, etc. used to operate a network and provide advanced communications services, and were not reasonably necessary to the removal, replacement, and disposal of covered communications equipment or service.
89. Vantage Point argues that annual software or license fees are a true cost of network replacement and should be included in Catalog replacement estimates. While these expenses may be reimbursable, the Bureau declines to implement Vantage Points proposed
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change because specific software licensing fees are already included in the Catalog based on Widelitys engagement with industry stakeholders.
Participants seeking reimbursement for software and licensing fees not identified in the Catalog will need to provide individualized cost estimates with supporting documentation.
90. Requests to Clarify or Modify Cost Categories. CCA asks us to clarify that the full range of 911 implementation costs are reasonable, including thirdparty integration costs. The Catalog includes cost estimates for 911 and E911 Services and Test Services which the Bureau finds are sufficiently specific. To the extent that there are additional costs associated with 911 and E911 Enhanced 911 implementation as CCA suggests, there is no evidence in the record or provided to Widelity that would form a basis for altering the Catalog 911 and E911 services cost categories. Accordingly, the Bureau declines to implement the change proposed by CCA.
91. USTelecom asked the Commission to clarify that the Leasing cost category is not limited to wireless networks, but that wireline networks may also need to obtain or modify leases, such as, for example, for space in third-party datacenters. In particular, USTelecom asserts that the existing colocation expense type is unclear.
The Bureau clarifies that providers of wireline networks may be eligible for reimbursement of leasing expenses, including colocation expenses, reasonably incurred in removing, replacing, or disposing of covered communications equipment and services. The Bureau declines, however, to modify the Catalog to account for costs of leasing space in third-party data centers. The Bureau notes that there is no documentation in the record to quantify costs for leasing space in thirdparty data centers, and Widelity did not receive cost data on leasing space in third-party data centers.
92. Amendments to the Range of Cost Estimates. Commenters requested that the Bureau modifies the range of cost estimates for certain cost categories identified in the preliminary Catalog.
Mavenir argues that the low range of cost estimates identified in the preliminary Catalog for Open vRAN
eNodeB, RAN Open RAN/vRAN
Components or Distributed Unit . . .
need to be changed to reflect that costs provided by Mavenir. The Bureau agrees with Mavenir that it should modify the Catalog to reduce the low end of the range of estimated costs for Open vRAN eNodeB, and RAN
Open RAN/vRAN Components to
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