Telecom Associations Respond to FCC Notice of Proposed Rulemaking on Call Completion Issues



Laura Withers, NTCA, 703-351-2086, 
Derrick Owens, WTA, 202-548-0202,
Jeff Dupree, NECA, 202-682-2495,  
Carole Woodward, ERTA, 919-708-7404,

Support meaningful rules aimed at capturing the data necessary to further enforcement efforts and resolve long-standing problem in rural America

WASHINGTON (May 13, 2013) – The National Exchange Carrier Association (NECA), NTCA–The Rural Broadband Association, the Western Telecommunications Alliance (WTA) and the Eastern Rural Telecom Association (ERTA) today filed comments with the Federal Communications Commission (FCC) in response to the agency’s February 2013 Notice of Proposed Rulemaking (NPRM) on call completion issues. The NPRM seeks comments to improve the FCC’s ability to monitor the delivery of long-distance calls to rural areas and aid enforcement action in connection with providers’ call-completion practices as necessary.

The associations support the FCC’s efforts to resolve this long-standing problem that affects the availability of reliable telephone service to consumers, businesses, and public health and safety officials in rural America. The NPRM, combined with swift and meaningful enforcement action, is a step toward ensuring that consumers and businesses across America may once again rely on the nation’s communications networks to talk with friends, relatives and customers in rural areas. 

While many of the NPRM’s proposals will help the FCC, industry and consumers track the problems and pursue enforcement action, some of those proposals require clarification and refinement to aid in such efforts. For example, the commission should make clear that the obligation to track and report call completion rates will fall on facilities-based providers that control the initial long-distance call routing. The associations also pointed out that the proposed reporting threshold would fail to capture call completion failure in some of the most rural areas of the country and would likely only mask the problem.

The associations also urge the FCC not to limit reporting of call failures to peak hours. This would suggest call completion failures are merely a symptom of network congestion even as there is no evidence or allegation to support this notion. Moreover, the associations ask the FCC to track call performance data on a weekly basis and report such results quarterly to strike a balance between data needed for compliance, investigation, and enforcement and the burden on the reporting carriers.

The associations support the NPRM’s proposal that facilities-based originating carriers capture and retain detail on every long-distance call, including the identification of intermediate providers, jurisdiction and whether the call attempt was going to a rural carrier as well as reporting associated performance metrics. However, the proposed reporting safe harbor provisions are overly broad and would undermine the commission’s ability to track call completion rates and investigate call failures while offering little corresponding benefit to the affected providers. In sum, the FCC should strive for nothing less than parity in call quality and completion rates between rural and nonrural areas.

Because the intermediate provider market will still exist and there is no evidence that the need for these rules will go away with the elimination of access charges, the associations believe only after complete, sustained elimination of the problem should the FCC consider relaxing or eliminating the reporting and recordkeeping requirements needed to support its investigation and enforcement efforts. 

The associations hope these proposed rules, once in effect, along with enforcement of existing rules, will help eliminate the call completion problems that currently plague America.

"I commend the commission for looking for ways to identify bad actors and better understand the practices that are preventing calls to rural consumers from completing," said Shirley Bloomfield, chief executive officer of NTCA. "But this ongoing data-collection exercise must not be seen as, or become a substitute for, strict enforcement of current rules intended to protect the integrity and reliability of our country's communications networks. While the FCC's proposals may aid future enforcement, pervasive call failures continue to be a national crisis that needs and deserves more immediate resolution through enforcement of rules that are already on the books."

"We're pleased that the Commission is addressing the problem of calls not being completed to rural areas," said Kelly Worthington, WTA Executive Vice President. "Basic voice communication is just as much a necessity for rural residents, businesses, emergency services and anchor institutions as it is in more densely populated areas. With the clarifications and modifications suggested in our comments, we're hopeful this rulemaking can ameliorate the problem. We urge the Commission to move quickly to issue an Order so that this problem doesn't persist," said Worthington.

“We have joined the other rural associations in responding to the FCC’s Call Completion NPRM with the hope our united comments will help refine call data collection, retention and reporting rules to effectively re-establish consistent and reliable telecommunications service to rural America,” stated Jeff Dupree, NECA Vice President—Government Relations.

“Consumers and businesses across the country continue to be frustrated by the problem of calls not being completed to rural areas because they have been blocked upstream. We hope that the FCC will enforce existing rules and that their proposed rules, once adopted and effective, will put a stop to this call completion problem affecting the entire country,” said Carole Woodward, ERTA Executive Director.

# # #

The National Exchange Carrier Association (NECA) is a membership association of U.S. local telephone companies, dedicated to keeping customers connected on state-of-the-art communications networks. Our services help more than 1,000 members across rural America deliver high-speed multi-use broadband services. Visit us at

NTCA–The Rural Broadband Association represents nearly 900 independent, community-based telecommunications operating companies that are leading innovation in rural and small-town America. NTCA advocates on behalf of its members in the legislative and regulatory arenas, and it provides training and development; publications and industry events; and an array of employee benefit programs. In an era of exploding technology, deregulation and marketplace competition, NTCA’s members are leading the IP evolution for rural consumers, delivering technologies that make rural communities vibrant places in which to live and do business. Because of their efforts, rural America is fertile ground for innovation in economic development and commerce, education, health care, government services, security and smart energy use. Visit us at

Western Telecommunications Alliance (WTA) is a trade association whose membership is comprised of approximately 250 rural telecommunications carriers providing high-quality voice, video and broadband throughout rural areas in the 24 states west of the Mississippi River. On average, WTA member companies serve fewer than 3,000 access lines with fewer than 500 customers in each exchange. WTA’s members serve some of the most rural and hard-to-serve communities in the country and are on the forefront of bringing 21st Century telecommunications services to rural America. Visit us at

The Eastern Rural Telecom Association (ERTA) is a membership organization made up of community based local exchange companies and support companies that provide telecommunications services to rural customers in the Eastern half of America.  Besides providing local, long distance, and broadband Internet services, some ERTA members also provide wireless and cable television services. Visit us at