Federal Filings and Ex Parte

NTCA Files Reply Comments on Lifeline Proposed Changes

On September 13, 2019, NTCA filed reply comments stating that commenters universally supported NTCA's Petition for Waiver of the scheduled December 1, 2019, increase in minimum service standards for Lifeline subscribers. NTCA and commenters noted that requiring Lifeline subscribers to a higher speed Internet service would likely result in some Lifeline subscribers disconnecting their service due to inability to afford the increased cost of service. NTCA requested the Commission allow Lifeline subscribers the option of choosing to subscribe to broadband service at the current minimum services standard or to any updated minimum services standard established by the Commission in the future.

NTCA Members discuss Access Arbitrage with the Wireline Competition Bureau

On September 9, 2011, Denny Law of Golden West Telecommunications, Ryan Boone of Premier Communications and Trey Judy of Hargray Communications joined Mike Romano, NTCA Vice President of Industry, to talk with staff from the FCC's Wireline Competition Bureau and Office of Economics and Analytics. NTCA stated their continued support of targeted actions to address inefficient access stimulation practices however they noted concerns that the Draft Order may inadvertently include RLECs that are not engaging in access stimulation. NTCA suggested modifications to the Draft Order to ensure any new rules do not sweep in non-access stimulating carriers.

NTCA discusses Intercarrier Compensation with Staff from Chairman Pai's Office

On August 30, 2019, Mike Romano talked with Nicholas Degani and Nirali Patel from Chairman Ajit Pai's office on the FCC proposed changes to eliminate access arbitrage. NTCA noted that any change to the definition of access stimulation must be structured carefully to ensure that smaller rural operators do not become embroiled in disputes and self-help measures by larger carriers due to traffic imbalances that have no relationship whatsoever to access stimulation. NTCA supports the efforts to eliminate arbitrage of the intercarrier system by the Commission but highlighted that any effort should take care to prevent unintended harms to LEC's.

NTCA discusses C-Band with Chairman Pai's Staff

On, August 19, 2019, NTCA's Jill Canfield met with Aaron Goldberger, Wireless and International Advisor to Chairman Ajit Pai to discuss concerns regarding the proposed reallocation of spectrum. NTCA urged the FCC to consider any reallocation of spectrum licenses that would ensure small and rural providers would have an opportunity to obtain spectrum to benefit telecommunications services in rural America.

NTCA Files Ex Parte on C-Band Discussions at the FCC

On August 15, 2019, NTCA's Jill Canfield met with staff from Commissioner O'Reilly, Commissioner Carr, and Commissioner Rosenworcel's offices to discuss concerns regarding the proposed reallocation of spectrum. NTCA urged the Commission to adopt smaller sized geographic territories for spectrum licenses that would ensure small and rural providers will have an opportunity to obtain spectrum so rural consumers would receive service.

NTCA Files Additional Comments on 3.7-4.2 GHz C-Band Spectrum

On August 7, 2019, NTCA filed additional comments on the 3.7-4.2 GHz band proceeding. NTCA supports a balanced and measured approach that ensures that all consumers, including those in rural areas can take advantages of the spectrum base services the band has to offer. NTCA noted the FCC should consider licensing the spectrum according to geographic areas that are small enough to afford rural companies a realistic opportunity to participate in the auction bidding.

NTCA Details Labor Hours Associated with Performance Measurement Testing

On August 6, 2019, NTCA filed comments responding to the FCC estimates of labor hours to report broadband network performance measurement results. NTCA outlined sequential steps that providers will need to take as part of the testing process and noted these measures do not appear to be contemplated in the original burden estimate set forth for under the Paperwork Reductions Act (PRA) requirements.