09.23.11Ex Parte Notice re Furchtgott-Roth FCC White Paper


 Ex parte Presentation

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


The National Telecommunications Cooperative Association, the Organization for the Promotion and Advancement of Small Telecommunications Companies, and the Western Telecommunications Alliance (collectively, the Associations) filed a presentation in the above-captioned proceedings.  This paper, "Why the FCC Should Not Hold a Position with Respect to Consolidation Within the Rural Telephone Industry," amplifies an issue raised by the Associations in Reply Comments of May 23, 2011 (p. 46), specifically, addressing proposed regulatory actions that may be intended to encourage consolidation within the rural telecommunications industry.  The paper explains why pursuit of such policies would conflict with both the Commission’s statutory authority and economic rationality.


09.23.11 FCC ex parte - HFR-FCC White Paper_w-attachment.pdf