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Argued February 5, 2001

On Petition for Review of an Order of the Federal Communications Commission

The National Exchange Carrier Association challenges an order of the Federal Communications Commission adopting a formula for distributing money from the Universal Service Fund (USF) to subsidize high-cost telephone service providers and thereby promote telephone subscribership. The petitioner claims that the Commission’s order violates the Administrative Procedure Act because it arbitrarily and capriciously undercompensates telephone service providers, and it was adopted without adherence to the applicable procedures for public notice and comment. The NECA, however, fails to articulate an intelligible explanation of its substantive claim, and its procedural claim lacks merit. Accordingly, we deny the petition for review.

 
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