September 7, 2010 - NTCA Urges Consistent Broadband Definition, Opposes Cost Modeling
Says expanding base of USF contributors will hasten broadband deployment
Arlington, Va., (September 7, 2010) - Because the ongoing analysis of Section 706 of the Telecommunications Act will drive the FCC's broadband policy and regulatory decisions, it is imperative that the commission accurately assess broadband deployment by correctly identifying areas that are served and distinguishing them from areas that remain unserved, the National Telecommunications Cooperative Association (NTCA) said today. The association filed comments in response to the FCC's inquiry concerning the deployment of advanced telecommunications capability in a reasonable and timely fashion, and possible steps to accelerate such deployment.
In the comments, NTCA said the commission should define "broadband" consistently for all regulatory purposes and that the definition should reflect consumer expectations. "To do otherwise would mean that an area could be deemed served by broadband for one regulatory purpose, but be declared unserved for another, leaving providers and consumers unsure about what services and applications are available in any given location," the group said in the comments
However, in determining where broadband is not available to consumers, the association vigorously opposed the use of models, which have consistently failed to capture the vagaries of providing telecommunications and advanced services in rural areas. NTCA cited its previous analysis of the FCC's Broadband Assessment Model (BAM) in which it identified several flaws in the proposed model, including that the BAM:
- Incorporates a number of faulty assumptions regarding the extent to which particular areas are "unserved;"
- Utilizes flawed processes to determine the cost of extending existing facilities;
- Has not been statistically validated;
- Did not include middle-mile capacity as a variable; and
- Ignores several critical real-world parameters resulting from its net present value (NPV) approach to estimating costs of providing broadband service.
"The commission should not balance the future viability of broadband availability on something as tenuous as an economic model," NTCA said.
Noting that rural carriers have done a commendable job of deploying broadband to rural communities, due largely to predictable and stable funding mechanisms and rate of return regulation, NTCA suggested specific actions the commission should take to accelerate deployment in these areas. NTCA said the commission should expand the base of contributors to the universal service fund, expand the call signaling rules to mitigate phantom traffic, and clarify that all IP to PSTN and PSTN to IP traffic is subject to intercarrier compensation.
NTCA also supported ensuring that services meeting the broadband threshold are capable of supporting advanced video services such as two-way video conferencing and streaming high-definition video. NTCA also urged the commission to act to ensure that rural carriers have nondiscriminatory access to video content, recognizing that access to video spurs deployment.View comments
The National Telecommunications Cooperative Association is the premier association representing more than 560 locally owned and controlled telecommunications cooperatives and commercial companies throughout rural and small-town America. NTCA provides its members with legislative, regulatory and industry representation; meetings; publications and educational programs; and an array of employee benefit programs. Visit us at www.ntca.org.