01.18.19 JT Comments re CAF/ICC FNPRM, Sec. XVII, Pts A-K, WC 10-90, et al

The Rural Associations hereby submit their initial comments on questions identified in sections XVII A-K of the Commission’s Report and Order and Further Notice of Proposed Rulemaking in the following proceeding:

 Connect America Fund, WC Docket No. 10-90; A National Broadband Plan for Our Future, GN Docket No. 09-51; Establishing Just and Reasonable Rates for Local Exchange Carriers, WC Docket No. 07-135; High-Cost Universal Service Support, WC Docket No. 05-337; Developing an Unified Intercarrier Compensation Regime, CC Docket No. 01-92; Federal-State Joint Board on Universal Service, CC Docket No. 96-45; Lifeline and Link-Up, WC Docket No. 03-109; Universal Service Reform – Mobility Fund, WT Docket No. 10-208

Filed on behalf of NECA, NTCA, OPASTCO, and WTA