July 25, 2014

July 25, 2014

In This Issue

Meetings and Events

MTA Updates

>> Become a Sponsor of the 2014 MTA Fall Conference!

>> Is Your Company Getting All of the Money You Are Owed by the State?

>> USAC Releases De-Enrollment Information for Lifeline Customers with Duplicate Services

>> FCC Releases Order/FNPRM on Rural Broadband Experiments

>> DEED Wants to Help You Market Your Fiber

>> Public Utilities Commission Issues Order on Call Completion

>> FCC Announces Creation of USF Strike Force

>> FCC Announces Budget and Application Window for Rural Broadband Experiments

>> FCC Approves E-Rate for Wireless Connections in Schools

>> Minnesota Border to Border Infrastructure Grant Program

>> Telco Marketing Peer Group Summer Conference

>> Administrative Assistant Peer Group Summer Conference

>> Office Managers/HR Peer Group Fall Conference

>> MTA Peer Group 2014 Investment Opportunities Are Available!

>> DOT’s MOT Regulation

People and Companies

>> Calix User Group Conference

MTA Staff

MTA President/CEO:
Brent Christensen
Team Leader:

Jacquie Durant
Event Planners:
Julie Cygan
Carissa Wolf
Member Services:
Chris Swanson
Janey Duntley
Administrative Assistant:
Anne Christensen

Stay up-to-date on daily happenings at the MTA offices by following us on Facebook. From peer group meetings to annual conferences and everything in between, get the scoop on what’s happening at our offices!




Meetings and Events

August 6-8, 2014: 2014 Telco Marketing Peer Group Summer Conference

August 11, 2014: Pinnacle Golf Day

August 27-28, 2014: 2014 Administrative Assistant Peer Group Summer Conference

September 11-12, 2014: 2014 Office Managers/HR Peer Group Fall Conference

October 9-10, 2014: MTA Fall Conference

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MTA Updates


Become a Sponsor of the 2014 MTA Fall Conference!

Maximize your company's exposure to the MTA membership at the 2014 Fall Conference. The conference will be held on Thursday, October 9 and Friday, October 10 at the Minneapolis Marriott Northwest. MTA members will be coming to Minneapolis from all over the state to learn more about the important issues facing our industry — and this is your opportunity to get your company’s message in front of them.


If you have any questions about the sponsorship information, please contact Carissa Wolf (carissaw@mnta.org).

Is Your Company Getting All of the Money You Are Owed by the State?

In a last-minute deal at the end of the 2013 Legislative session, lawmakers repealed the upfront sales tax exemption on central office equipment. The MTA worked with a wide coalition of stakeholders to educate lawmakers about why this was a mistake and would adversely affect the deployment of broadband in Minnesota. “They took away the only incentive the State had for providers to deploy more broadband”, commented MTA President/CEO Brent Christensen, “basically this means that it will now cost 7% more to get service to those truly unserved.”

After countless hours of educating legislators, commissioning a tax study to show the impact on the economy, and participating in the MN Chamber's United for Jobs coalition, the MTA and our allies were successful in re-instating the sales tax exemption on telecom equipment. The new exemption went into effect for purchases made after March 31, 2014. While it was expanded to include more than central office equipment, the exemption still does not include wire, cable, fiber, poles, or conduit. Here are the highlights:

  1. Effective for telecom equipment purchases made after March 31, 2014.
  2. The sales tax exemption applies to telecommunications or pay television services machinery and equipment purchased or leased for use directly by a telecommunications or pay television services provider primarily in the provision of telecommunications or pay television services that are ultimately to be sold at retail, regardless whether purchased by the owner, a contractor, or a subcontractor.
  3. Telecommunications or pay television machinery and equipment includes, but is not limited to:
    a. machinery, equipment, and fixtures utilized in receiving, initiating, amplifying, processing, transmitting, retransmitting, recording, switching, or monitoring telecommunications or pay television services, such as computers, transformers, amplifiers, routers, bridges, repeaters, multiplexers, and other items performing comparable functions;
    b. machinery, equipment, and fixtures used in the transportation of telecommunications or pay television services, such as radio transmitters and receivers, satellite equipment, microwave equipment, and other transporting media – but not wire, cable, fiber, poles, or conduit;
    c. ancillary machinery, equipment, and fixtures that regulate, control, protect, or enable the machinery in clauses (1) and (2) to accomplish its intended function, such as auxiliary power supply, test equipment, towers, heating, ventilating, and air conditioning equipment necessary to the operation of the telecommunications or pay television equipment; and software necessary to the operation of the telecommunications or pay television equipment; and
    d. repair and replacement parts, including accessories, whether purchased as spare parts, repair parts, or as upgrades or modifications to qualified machinery or equipment.
  4. Effective July 1, 2015, the sales tax exemption will be upfront. Until then, companies must apply for a refund. Click here for form ST11.

The reason the Legislature makes you apply for the refund, instead of giving it to you up front, is because they know not everyone will apply for the refund and that will leave taxes collected in the State’s general fund. DON’T LEAVE MONEY ON THE TABLE FOR YOUR COMPANY! Apply for every refund you are eligible for and get the money returned to your company! Contact your tax professional for more information.

USAC Releases De-Enrollment Information for Lifeline Customers with Duplicate Services

Currently, USAC is undergoing the process of resolving duplicate claims of Lifeline Program benefits. Subscribers who were identified during the NLAD loading process as having multiple Lifeline Program benefits were sent letters on a state-by-state basis by USAC. See USAC, Duplicate Resolution. Once a subscriber receives the letter from USAC, he/she has 35 days from the date of the letter to select a single Lifeline Program carrier. During this 35-day period, the NLAD does not allow changes to be made to the subscriber’s information. Significantly, subscribers may not be de-enrolled from their Lifeline Program benefit by any service provider from the NLAD. We have received complaints that subscribers have asked to be de-enrolled from their Lifeline Program benefit with a service provider during the 35-day letter period. These subscribers are not aware that the NLAD does not allow for changes during the letter period. Therefore, we direct ETCs to undertake this process effective Tuesday, July 29, 2014, to effectuate the request of the subscriber:

  1. If a subscriber approaches an ETC and asks to be de-enrolled during his/her 35-day period, the ETC must de-enroll that subscriber within the ETC’s system and cease provision of Lifeline Program service to that individual at that time.
  2. The ETC must keep a record of the subscriber’s request to be de-enrolled and the subsequent de-enrollment.
  3. Once the 35-day letter period expires for that particular subscriber, the ETC must de-enroll the subscriber from the NLAD and enter the de-enrollment date.
  4. ETC must keep a record of the entry into the NLAD 36 days later as necessary due to the 35-day letter period for that particular subscriber.
  5. ETC records should make reference to this USAC guidance as authorizing these actions for audit purposes.

For example, a subscriber receives the letter on June 13 and the 35-day selection period ends on July 18. If he/she requests de-enrollment on July 15, the ETC should de-enroll the subscriber from its systems and keep a record of the request and transaction. Then, after July 19 (one day after the 35-day period ends), the ETC can de-enroll the customer in NLAD any day between July 29 (the day this process goes into effect) and August 7 (the de-enroll deadline), and should enter the "de-enroll date" as July 15. The ETC should keep a record of this entry and use these guidelines as justification for entering a de-enroll date prior to the end of the 35-day period.

Website Update: New NLAD Maintenance Page Includes Release Notes

As a result of carrier feedback during the weekly industry webinars, USAC has begun posting NLAD release notes to the USAC website. Because of this new addition, the name of the NLAD "Outage Schedule" page has changed to "Maintenance Schedule" to more accurately reflect the information that can be found on that page. NLAD maintenance takes place on a regular basis. This maintenance can include deployment of a new version of the system to make system changes or upgrades, or scheduled maintenance (typically completed on the third Saturday of each month). The table on the Maintenance Schedule page outlines all 2014 dates for NLAD maintenance, which may or may not include taking the system offline. If a new version of the system was deployed, you will find a link to the release notes for that deployment in the "Notes" column of the table. Questions about NLAD: If you have any questions, contact us at NLADSupport@usac.org or (877) 524-1325.

FCC Releases Order/FNPRM on Rural Broadband Experiments

from NECA’s Washington Watch

The FCC released a Report and Order on July 14, 2014, establishing a $100 million budget and a methodology for selecting winning applications for the Connect America rural broadband experiments. The experiments will be divided into three groups: $75 million to test construction of networks offering service plans providing 25 Mbps downloads and 5 Mbps uploads for the same or lower amounts of support than will be offered to carriers in CAF Phase II; $15 million to test interest in delivering service at 10/1 speeds in high cost areas; and $10 million for 10/1 service in areas that are extremely costly to serve. To ensure diverse experiments, project sizes are capped, while entities serving Tribal lands are eligible for a 25 percent bidding credit. Final applications for the experiments are due 90 days after release of the FCC Order, with selection expected by the end of 2014. The accompanying FNPRM seeks comment on how the CAF Phase II competitive bidding process can offer bidding credits when states provide matching funds to expand rural broadband. Comments are due 30 days after publication in the Federal Register; replies due 45 days after FR. News Release

DEED Wants to Help You Market Your Fiber

The MN Department of Employment and Economic Development has put together a brochure to market to companies wishing to expand data centers in Minnesota. The Find Your Center fact sheet has useful information for prospective businesses encouraging them to expand in our state. Included in the brochure is a map listing Enventis’ fiber routes. The Office of Broadband Development has asked for the MTA’s help to reach out to members to expand the map to include all fiber routes. If your company is interested in marketing your fiber routes through DEED and being included on its map, please contact Diane Wells at diane.wells@state.mn.us, 651-259-7613 or MTA President/CEO Brent Christensen at bchristensen@mnta.org, 651-288-3723.


Public Utilities Commission Issues Order on Call Completion

Earlier this week, the PUC issued its order on Call Completion. The Order requires the following:

  1. The Commission will keep this docket open, track the Federal Communications Commission’s (FCC’s) initiatives regarding rural call completion issues, and investigate all complaints received regarding this issue on a case-by case basis.
  2. The Commission will accept and adopt the Department’s recommendations to require interexchange carriers to report to the Commission and the Department all call completion complaints they receive on a quarterly basis for a year, including the information set forth more specifically herein.
  3. Finally, the Commission will also require rural incumbent carriers to make test lines available so that interexchange carriers have the opportunity and ability to test the effectiveness of their call routing systems.

The order was a result of testimony taken at the PUC's June 26 meeting. The MTA and others provided testimony on the serious problem facing rural Minnesota. “There is no silver bullet to solve this problem,” commented MTA President/CEO Brent Christensen, “We think the Commission’s actions are prudent and hopefully will work in concert with the FCC’s plan to address this issue.” Click here to read the full order.

FCC Announces Creation of USF Strike Force

Chairman Wheeler announced on July 14, 2014, the creation of a Universal Service Fund Strike Force to combat waste, fraud and abuse in Commission funding programs. Chairman Wheeler said the Strike Force will investigate violations of the Communications Act, the Commission’s rules, and other laws bearing on USF programs and contributions, and will coordinate with the FCC’s Office of Inspector General, the U.S. Department of Justice, and other law enforcement agencies to prosecute unlawful conduct. The Strike Force will be led by Loyaan Egal, a former federal prosecutor.

FCC Announces Budget and Application Window for Rural Broadband Experiments

A Connected Nation Policy Brief

At an Open Commission Meeting on July 11, 2014, the Federal Communications Commission (FCC) voted to approve a budget and open an application window for Rural Broadband Experiments through the Connect America Fund program. Formal applications will be due 90 days after the release of the official Order, which is expected shortly. Later this year, the FCC will analyze formal applications and will select winners through a competitive auction, with the goal being to award the funds to the most cost-effective proposals to offer broadband service in rural areas of the country that do not have adequate access to broadband today.

As noted in an earlier Connected Nation Policy Brief, in January 2014 the FCC established the Rural Broadband Experiments program with the purpose of shaping and adjusting its Connect America Fund broadband subsidy program to include an application-based, competitive-bidding framework. The formal process launched on July 11 will make available funds from earlier phases of the Connect America Fund. The Rural Broadband Experiments program is the first opportunity for providers that are not the incumbent local telephone company in a particular area to receive Connect America Fund subsidies to build and operate fixed broadband networks. This “experiment” will serve as a test to the competitive bidding process the FCC will plan on using to distribute more Connect America Funds in 2015 and beyond.

The FCC’s January action requested that providers and communities interested in the program file “expressions of interest” by March 7, 2014, and over one thousand “expressions of interest” were filed from a variety of applicants including current providers, electric cooperatives, communities, and organizations. The FCC used these expressions of interest in devising the formal rules and nature of the project as well as the broadband service standards and expectations for recipients. According to the FCC News Release, the FCC will divide the $100 million budget for the program into three buckets:

  1. $75 million will be awarded to projects that will offer broadband service to residential and small business consumers at speeds of at least 25 Mbps download/5 Mbps upload speed.
  2. $15 million will be awarded for projects that will offer broadband service at speeds of at least 10 Mbps download/1 Mbps upload.
  3. $10 million will be awarded to projects that will serve “extremely high cost areas” at speeds of at least 10 Mbps download/1 Mbps upload. (The FCC has identified “extremely high cost areas” generally to be those with a monthly subsidy of at least approximately $2,400 per unserved location per year.)

Formal applications will be due 90 days after release of the complete text of the FCC’s action. The Order will specify service standards for applicants and will establish a cap on project size per application.

After applications are received, the FCC will conduct a single-round, competitive auction to identify applications within each of these buckets to receive subsidies. The auction will be nationwide – for example, proposals to fund a network project in Tennessee will compete on a per-location subsidy cost against network projects in Minnesota. The FCC will give a 25% bidding credit to projects that propose to serve Tribal lands.

The FCC also launched another proceeding that will consider rules for a broader, Connect America Fund Phase II competitive bidding process. The Rural Broadband Experiments program is designed to help the FCC and industry gather information on how to distribute Connect America Fund subsidies through a competitive mechanism. Phase II of the Connect America Fund is a $1.75 billion/year program targeted at the unserved areas of larger local telephone companies, such as CenturyLink, Windstream, AT&T, and Verizon. In allocating those subsidies, the FCC has proposed to offer bidding credits or incentives to applicants for those Phase II projects that include partnerships and funding from state governments and other non-Federal sources.

Dozens of communities and providers have expressed interest in this program, and Connected Nation has actively supported these initiatives and stands ready to assist its stakeholders with this process, provide information and data, and answer questions. When the Order text is released, Connected Nation will provide stakeholders information on further details of the project (including specific application requirements and timing).

FCC Approves E-Rate for Wireless Connections in Schools

from Blandin on Broadband

More funding is coming for broadband, which always seems good. This time, the FCC has approved $2 billion for wireless access in the schools. According to Bloomberg

The Federal Communications Commission approved a plan to spend $2 billion to boost wireless Internet connectivity in U.S. schools and libraries during the next two years.

“We’re at a watershed moment,” FCC Chairman Tom Wheeler said during a hearing in Washington in which the panel voted 3-2 to approve the plan he proposed in April. “Because of what we do today 10 million kids will be connected next year who otherwise wouldn’t. That’s a good day's work.”

The move will phase out funding under a program known as E-rate for old technologies like pagers and dial-up phone service in order to subsidize broadband and wireless Internet connections in classrooms and libraries.

I’m interested to hear how this will play out in terms of library testing spectrum to wireless connections to serve unserved areas. I also wonder if someone is setting time and/or money aside to help teachers learn to work with new technologies. Years ago, I worked with teachers on developing curriculum that included access to websites. To really adopt the technology, the teachers need time, training and incentive to learn how to use it.

Connected Nation also provided a nice summary of the E-Rate Reform.

Many important details about the FCC’s action will only be known upon release of the full Order, which is expected soon. The FCC has released a Fact Sheet outlining key aspects of the Order, including:

  • Repurposing of previously collected funds under E-rate to inject $1 billion annually in 2015 and 2016 ($2 billion total) to support school and library on-campus Wi-Fi. An array of services and equipment supporting Wi-Fi connectivity across schools and libraries will be eligible for this funding opportunity, including IT equipment that enables Wi-Fi connectivity, managed Wi-Fi services and catching services. This key piece of the reform aims to address a significant gap in Wi- Fi connectivity across schools and libraries. According to FCC estimates, three in five schools in America do not have adequate on-campus Wi-Fi. The FCC estimates that this new funding will help connect 10 million students to better on-campus Wi-Fi in 2015 alone.
  • For some applicants, the new Wi-Fi program will have a different discount rate than traditional E-rate. Today, schools and libraries serving the poorest communities across the country receive an E-rate discount of 90% over retail Internet and Wi-Fi connections prices. Moving forward, the discount rate for Wi-Fi services for these institutions will decrease to 85%. Discounts for other applicants in more affluent communities, ranging from 20% to 89%, will remain unchanged.
  • The new rules will provide multi-year funding predictability for schools and libraries to tap into this separate Wi-Fi fund. While details are scant, it appears that applicant funding for Wi-Fi services will be capped using a formula based on a student basis, in the case of schools, and on a square footage basis, in the case of libraries. Libraries will be able to receive as much as $2.3 per square foot annually to support Wi-Fi connectivity.
  • There will be no change in the annual E-rate cap (currently $2.4 billion) at this time, but a Further Notice of Proposed Rulemaking will solicit comment on adjusting this cap. The FCC’s decision to leave the current cap in place is perhaps the most controversial aspect of the action, and it has been criticized by multiple parties advocating for an increase in the overall E-rate fund in order to better meet increasing demand for funding at the nation’s schools and libraries. Chairman Wheeler reiterated a position he voiced as early as February of this year that, while he does not oppose an increase in the program’s cap, the first step has been to focus on a structural reform of the program, such as the one voted for, that would re-prioritize the goals of the program and streamline its processes. Only then would the FCC be in a position to assess the overall need for E- rate funding. This assessment will likely be the core debate for continued E-rate reform moving forward.
  • Commencement of a multi-year transition of all program funding to broadband by gradually phasing down support for non-broadband, legacy services, such as voice telephony and paging. Currently, the FCC estimates that E-rate invests $1 billion annually in support of legacy services.
  • The FCC officially adopted broadband goals for the program, including 100 Mbps per 1000 students in the short run, and 1 Gbps per 1000 students in the longer term. However, rules for funding of broadband services to the school and library remain roughly unchanged. As we have noted previously, this is a significant departure in both substance and emphasis from several proposals debated earlier in the process. The E-rate will still prioritize services that connect schools and libraries to the Internet over Wi-Fi funding through a “safety valve” mechanism. In short, the bulk of the E-rate budget of $2.4 billion will continue to support connections to school and library buildings.
  • While broadband connections to schools and libraries will be prioritized, the FCC expects that it will continue to fund Wi-Fi connections within schools and libraries beyond the initial $2 billion allocated for 2015 and 2016. Further funds are expected to fit within the current E-rate cap due to program cost savings stemming from the phase out of legacy services. FCC staff indicated that it expects the transition away from legacy services will free up approximately $300 million in Funding Year 2015, $600 million in 2016, $800 million in 2017, $900 million in 2018, and $950 million in 2019. § Other FCC actions include providing incentivizes consortia and bulk buying, streamlining the process for multi-year applications, and expediting the processing of small applications.
  • E-rate rules now will allow E-rate applicants to purchase goods and services from federally- negotiated General Services Administration prices without having to go through a competitive bidding process.
  • The FCC will also increase transparency on how E-rate dollars are spent and prices charged for E-rate services.
  • Finally, the Order expands applicant document retention period to ten years and toughens rules for site inspection.

Additionally, the Further Notice will seek comment on the following issues:

  • Long-term program funding needs necessary to meet goals and funding targets established in the Order.
  • Further steps to facilitate the use of cost-effective consortium-based purchasing.
  • Alternative methodologies for allocating support for library Wi-Fi connectivity instead of the per-student and per-square foot approach that the FCC will use in 2015 and 2016.

Minnesota Border to Border Infrastructure Grant Program

Recently, the MTA sent an email to members about the broadband grant program. More information has come out since then. The Office will host its next regional information meeting on Monday to provide an overview on the status of the new broadband infrastructure grant program and discuss the application process and obtain feedback. That meeting will be Monday, July 28 from 1:30 to 3:00 in Baxter at The Lodge at Brainerd Lakes, 6967 Lake Forest Road, Baxter, MN. Background information on the grant program is available DEED's website, mn.gov/deed/programs-services/broadband/grant-program/index.jsp.

In addition to the Baxter meeting and a July 18 meeting held in Montevideo, five other regional meetings have been scheduled:

Wednesday, July 30, 1:30 to 3:00
IRRRB Offices
4261 Highway 53
Eveleth, MN

Wednesday, August 6, 1:30 to 3:00
Wyoming Library
26855 Forest Boulevard
Wyoming, MN 55092

Tuesday, August 19, 2:00 to 3:30
University of Minnesota at Crookston
2900 University Avenue
Bede Ballroom A, B and C
Sargeant Student Center 2nd Floor
Crookston, MN 56716

Friday, August 22, 1:30 to 3:00
Southern Minnesota Initiative Foundation
525 Florence Avenue
Owatonna, MN

Wednesday, August 26
Time and location TBD

DEED encourages all potential applicants to subscribe to the OBD email list which will be used to distribute information on the grant process as it develops.

The timeline has also been released:

  1. Application process will open in late September and run through October. No firm start or end dates at this point.
  2. Once the application process closes, a six week scoring period will begin.
  3. Other providers will have the opportunity to challenge applications during the first two weeks of the scoring period.
  4. Grants will be awarded in late December or early January.

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Peer Group Bulletin
All MTA members are welcome to join a Peer Group

Telco Marketing Peer Group Summer Conference

August 6-8, 2014
Chase on the Lake, Walker, MN

Get up to date on a variety of topics at the Summer 2014 TMG conference. With speakers covering a wide variety of topics, you're certain to get information that you can put to use. Topics include Social Media, Branding, Messaging, Home Monitoring and Channel dropping panels, FTTH value discussion, and even Memory Improvement.

Learn More and Register Here

Administrative Assistant Peer Group Summer Conference

August 27-28, 2014
West Central Telephone Association Headquarters, Sebeka, MN

We are excited to announce the upcoming MTA Administrative Assistant Peer Group Summer Conference scheduled for August 28 at West Central Telephone Association in Sebeka! This is a great opportunity to attend a very informative meeting (for a very minimal cost) and take advantage of the knowledge and resources that our Administrative Assistant peers have.

To kick off the conference, join us Wednesday evening, August 27, for an informal ice breaker at Blueberry Pines Golf Club, located at 39161 US Hwy 71, Menahga, where you can meet, mingle, and connect with both old and new friends! Appetizers and drinks will be provided (dinner on your own).

Thursday morning, we will meet at West Central Telephone Association headquarters to start the day off with registration and a continental breakfast. Agenda topics include a GM Perspective, MTA update, KwikTag and Effective Communication Skills & Office Attitudes presentations. A group luncheon (included in registration) will be held at “The Hub,” followed by the afternoon open forum discussion on topics that are pertinent and important to our roles as Administrative Assistants. And, of course, there will be many door prize drawings throughout the event!

As you can see, this conference has a full agenda of interesting topics that will not only leave you with great ideas from sessions but will also allow you to network with our peers in the telecom industry. We are really looking forward to a good turnout and hope you will consider joining us!

Learn More and Register Here

Office Managers/HR Peer Group Fall Conference

September 11-12, 2014
Thumper Pond Resort, Ottertail, MN

Join us at beautiful and relaxing Thumper Pond in Ottertail, MN on September 11-12, 2014. As always, this informative two-day event will get you updates on not only industry related items, but about finding your strengths and how to use them better in a team, about how the directory business has changed and where it’s going, about hot topics in Human Resources such as recruiting and retaining employees and also to learn from David Arvig about his company in our GM perspective. Oh yeah, and we might find some time for socializing with old and new friends!

We’ll kick off the event in the bar/restaurant at Thumper Pond on Wednesday night. The tentative agenda for the daytime is available here. We’re still finalizing plans for Thursday night fun; we’ll get out more details on that as soon as we can.

Hotel rooms must be reserved by August 11, 2014 to guarantee the special event rates. Room rates are $79.95 for either a King or Two Queens. Please ask for the MTA Office Manager/HR Peer Group block when calling. Thumper Pond, 300 Thumper Lodge Road, Ottertail, MN. Call 218-367-2000 or learn more at www.thumperpond.com.

Learn More and Register by August 29!

We look forward to seeing you in the fall!

MTA Peer Group 2014 Investment Opportunities Are Available!

MTA’s core purpose is to enhance the success and viability of its telecommunications industry members. You are an important part of helping us fulfill this mission. Here is your opportunity to maximize the impact of your event sponsorships for 2014.

Sponsor a Peer Group: Download the PDF or Sign Up Online!

Would you like to be added to a Peer Group listserv?
Email Jacquie at jacquied@mnta.org to be added – please specify which listserv(s) you would like to join:

Administrative Assistant (AA)
Customer Service (CSR)
Office Managers (OM)
Human Resource (HR)
Plant Superintendents (PM)
Telco Marketing (TMG)

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Safety Corner

DOT’s MOT Regulation

I had the opportunity to sit in on a training session put on by the Minnesota State Patrol and conducted by a Commercial Vehicle Inspector.  During the training on Load Securement, the term Materials of Trade (MOT) came up. When the Inspector asked if we transported Hazardous Materials while performing our work duties, the answer was NO.  When he asked whether, in the Telecom industry while performing our duties, we transported Materials of Trade, the room got a little quiet. I should probably take a step back and provide the definition of Materials of Trade provided by the Minnesota Commercial Truck and Passenger Fact Sheet:

A Material of Trade (MOT) is a Hazardous Material (HM), other than a hazardous waste, that is carried on a motor vehicle:

  • For the purpose of protecting the health and safety of the vehicle operator or passengers (e.g., self-contained breathing apparatus, oxygen cylinders, or insecticide);
  • For the purpose of supporting the operation or maintenance of a motor vehicle including its auxiliary equipment (e.g., engine starting fluid or spare wet batteries carried on a tow truck); or
  • By a private motor carrier, including a vehicle operated by a rail carrier, in direct support of a principal business that is other than transportation by motor vehicle (e.g., landscaping, plumbing, or welding services).

The second and third items relate to our industry the most. We transport hazardous materials in direct support of our business (e.g., gasoline, propane, aerosol paint, isopropyl alcohol)

Important reminders for MOT Packaging Regulations
Cylinders of compressed gas must be no larger than 220 pounds gross weight each and limited to 440 pounds aggregate gross weight.

Packages of MOT must be leak-proof, closed and secured in the vehicle against movement and damage.  The package should be the original manufacturer’s package, or one of equal or greater strength.

Gasoline transported as MOT must be packaged in containers that meet the OSHA requirements.  [NFPA 30 and OSHA 29 Code of Federal Regulations (CFR) 1910.106 (a)(29) define a safety can as, "an approved container of not more than 5 gallons (18.9 liters) capacity, having a spring-closing lid and spout cover so designed that it will safely relieve internal pressure when subjected to fire exposure."]

MOT Training Requirements

Drivers transporting MOT must be aware of the presence of MOT in their vehicle, must be informed of the requirements of the MOT rule, and be able to identify the HM to truck inspectors or emergency response personnel as materials of trade.

The importance of drivers knowing that they are more than likely transporting Hazardous Materials that are exempt under the Materials of Trade Regulations is critical. Drivers operating vehicles in excess of 10,000 pounds, upon being stopped by an inspector and questioned if they are transporting any hazardous materials, need to answer “NO”.  And when the inspector inquires whether they are aware of the chemicals they are transporting are referred, they should inform the inspector that they are “Materials of Trade.”

If you have any questions regarding the Materials of Trade Regulations, please feel free to contact me at dberg@mnta.org.

Take Care,
Dan Berg M.S.
Senior Safety Consultant

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People Companies

Calix User Group Conference

October 25-28, 2014
Wynn Resort, Las Vegas

Have you registered for the Calix User Group Conference, October 25-28 in Las Vegas? Join hundreds of service providers, consulting engineers, sponsors, and Calix experts for this four-day event filled with insights, inspiration, and fun. Find more information here: www.calix.com/usergroup.

Do you have an announcement for People & Companies? Send an email to MTA at info@mnta.org or fax to 651-290-2266.

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© Copyright 2014
Minnesota Telecom Alliance
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www.mnta.org | Tel: 651-291-7311 | Fax: 651-290-2266 | Email: info@mnta.org