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 a Unified Intercarrier Compensation Regime, CC Docket 01-92; Federal-State Joint Board onUniversal Service,CC Docket No. 96-45; Lifeline and Link-Up, WC Docket No. 03-109
The National Exchange Carrier Association, the National Telecommunications CooperativeAssociation, the Organization for the Promotion and Advancement of Small Telecommunications Companies, and the Western Telecommunications Alliance (collectively, the “Rural Associations”) hereby submit a working discussion draft of proposed rules to implement the universal service fund (“USF”) and intercarrier compensation (“ICC”) components of the reform plan set forth by the Rural Associations in their April 18, 2011 comments in the above-captioned proceedings, as modified by the Industry Consensus Letter filed with the Federal Communications Commission (the “Commission”) on July 29, 2011 (the “RLEC Plan”). These draft rules reflect USF and ICC provisions intended to be applicable to rate-of-return-regulated carriers pursuant to the RLEC Plan, and do not address implementation specifically of the ABC Plan submitted by USTelecom and several carriers.