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Federal Register / Vol. 86, No. 166 / Tuesday, August 31, 2021 / Rules and Regulations
reflect the lower pricing information Mavenir submitted to Widelity.
Accordingly, the Bureau implements these clarifications in the Catalog.
However, the Bureau rejects Mavenirs request to lower the low end of the range of cost estimates for the distribution layer Distributed Unit cost category because Widelity had already factored in the pricing information Mavenir submitted to Widelity when developing the range of cost estimates for the preliminary catalog. Because the Bureau finds the range of cost estimates for Distributed Unit identified in the preliminary catalog to be reasonable, the Bureau includes it in the final Catalog.
93. USTelecom asked the Commission to reexamine and confirm the appropriate prices for WDM and OTN
equipment. USTelecom asserted that it was unclear why cost estimates for access layer Access WDM & OTN
equipment matches core layer Metro WDM & OTN equipment, yet the apparently similar distribution layer Metro WDM & OTN cost estimates are very different. To remove a potential source of confusion for participants, the Bureau removed the core layer Metro WDM & OTN cost category since this equipment is identical to distribution layer WDM and OTN equipment and thus the cost estimates were duplicative.
As a result, the Bureau adjusted the range of cost estimates for WDM &
OTNCore Equipment to reflect the removal of distribution layer WDM and OTN equipment and the associated range of cost estimates. Accordingly, the Bureau adopts this revision in the Catalog. WDM and OTN associated equipment costs are included for the access layer, distribution layer, and core layer equipment cost categories.
94. USTelecom states that a member has Huawei equipment that would appear to be classified as Coaxial Media Converters in the proposed catalog and reports that it paid well in excess of the maximum allowed, and the cost to replace Huawei with equal functionality will range from $13,000
$16,000 per replacement. USTelecom notes that the carrier typically refers to the Coaxial Media Converters equipment as a cable modem termination system CMTS and, while CMTS systems are generally deployed in a cable operators headend, these particular Huawei CMTS devices are field-deployed. Because the Bureau finds that the costs for replacing CMTS
are reasonably necessary to comply with the Reimbursement Program, the Bureau finds that the Catalog should be revised to account for CMTS costs. The Bureau agrees with USTelecom that the highend cost estimate should be $16,000 per
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node but, based on cost estimates recommended by Widelity based on industry engagement, the Bureau finds that the low-end cost estimate should be $8,500 per node. The Bureau modifies the Catalog to include this range of cost estimates for CMTS per node.
95. CCA asks us to add the costs of cell site routers to the Catalog, with an estimated cost of $3,000 per site because each cell site typically has a router installed. The preliminary catalog identified a Distribution Layer cost subcategory and range of cost estimates for Cell Site Routers. The Bureau revised the Catalog to include additional Distribution Layer cost subcategories and ranges of cost estimates for small, medium, and large cell site routers based on Widelitys additional engagement with industry stakeholders. The Bureau finds that Widelitys thorough survey of communications industry manufacturers and service providers reasonably identified relevant ranges of estimated costs for cell site routers. To the extent that applicants disagree with the Catalog cost estimates, they may submit individualized cost estimates along with supporting documentation.
96. The Bureau also takes this opportunity to clarify that costs associated with removing, replacing, and disposing of wired Wi-Fi and wireless routers that constitute CPE are not be reimbursable under the program and revise the Catalog accordingly. The preliminary catalog included a subcategory without cost estimates for Smart Home CPE but clarified that IP cameras, wifi doorbells, wifi, light switches, etc. would not be reimbursable. In the preliminary Report, Widelity noted that for wireless networks, CPE can include an internal modem and broadband router possibly with a wireless access point to distribute a signal throughout the premises or office, and for wired networks, CPE can include a broadband router, or a premise gateway with wireless Wi-Fi capabilities. In the 2021 Supply Chain Order, the Commission found that certain CPE equipment including enduser handsets were distinctly different from cell sites, backhaul, core network, etc. used to operate a network and provide advanced communications services. In particular, the Commission found this equipment was not reasonably necessary to the removal, replacement and disposal of covered communications equipment. Wired WiFi and wireless routers may constitute CPE used by end users to access noncore network elements and, consistent with the 2021 Supply Chain Order, are
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not reasonably necessary for the removal, replacement, and disposal of covered communications equipment or services. Accordingly, the Bureau revises the Catalog Smart Home subcategory to clarify that Wi-Fi Routers would not be reimbursable under the program.
97. Airspan argues that the Cost Catalogs pricing appears grossly inflated, noting that some of the lower bound cost estimates listed in the Cost Catalog are as much as three times 3x the price Airspan currently offers for equivalent hardware and other network elements, and that network equipment and services are becoming less expensive by the day due to the ongoing evolution of network architecture design and equipment manufacturing.
Airspan did not sufficiently quantify with specificity the changes to the range of cost estimates it envisioned. The Bureau thus declines to modify the Catalog in response to Airspans comment because it believes that Widelitys thorough survey of communications industry manufacturers and service providers reasonably identified relevant ranges of estimated costs. The Bureau notes that it modified the Catalog in parts to reduce the low-end of the range of cost estimates where appropriate.
98. Vantage Point argues that the preliminary Catalog underestimates shipping costs in Alaska, failing to account for shipping costs to any other major Alaskan port, other than Seattle to Dutch Harbor, and failing to account for inland transportation costs. The Bureau declines to modify the Catalog to account for additional shipping costs in Alaska raised by Vantage Point. The Catalog accounts for shipping costs to Alaska based on the longest shipping route, Seattle to Dutch Harbor, as an example for the costs typically incurred.
Cost estimates for other outlying regions, which vary depending on multiple cost factors, including distance, time of year, freight weight, etc., would be too variable to include in the Catalog. To the extent that providers believe the Catalog does not adequately represent their shipping costs, they may submit individualized cost estimates with supporting documentation.
99. Widelity Proposed Revisions.
Widelity also proposed various modifications, clarifications, and improvements to the preliminary catalog, based on additional engagement with communications industry stakeholders and its own thorough review. Widelity proposed various clarifications to the descriptions of the cost categories. For example, Widelity proposed clarifying that the Virtual/

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