Federal Filings and Ex Parte

NTCA Files Comments in Support of Petition to Align HUBB FAQ Defining Locations with FCC Rules and Orders

On July 10, 2019, NTCA filed comments with the Federal Communications Commission (FCC) supporting a Petition for Clarification or Declaratory Ruling filed by Northeast Iowa Telephone Company and Western Iowa Telephone Association. The petition noted disparities between USAC's HUBB FAQ "definition" of locations that share the same property as a residence and the Commission's rules and orders. NTCA recommended the Commission direct USAC to modify the FAQ to strike a balance between accountability and flexibility that reflects rural realities and is consistent with the Commission's rules and orders.

NTCA Files Reply Comments on FCC Request for Ways to Incentivize Large Carriers to Partition, Disaggregate or Lease Unused Portions of Spectrum to Small, Rural Carriers

On July 1, 2019, NTCA filed reply comments in response to the request from the Federal Communications Commission (FCC) for ways to incentivize large carriers to sell or lease unused portions of their licensed spectrum to small, rural carriers. NTCA emphasized the FCC needs to ensure rural carriers have a meaningful opportunity to acquire spectrum on a primary basis through spectrum auctions, as providers-and customers who rely on them-cannot build a business on secondary spectrum alone.

NTCA Member Panhandle Telephone Cooperative Discusses Broadband Mapping with FCC

On June 27, 2019, Kelly Wells, Regulatory Affairs Manager of Panhandle Telephone Cooperative (PTCI) and Mike Romano, NTCA Senior VP of Industry Affairs met with staff from Chairman Ajit Pai, Commissioner Michael O'Reilly, Commissioner Brendan Carr, Commissioner Geoffrey Starks Offices to discuss the accuracy of broadband availability mapping. PTCI described their efforts to develop accurate maps for its own operations and to identify accurately coverage claimed by other service providers. PTCI highligted how their experience with mapping can be instructive moving forward in developing solutions for better mapping as the FCC considers how to improve its broadband availability data collections processes.

NTCA Iowa Members Discuss ACAM Locations with FCC Staff

On June 26, 2019, NTCA members, Dave Duncan of the Iowa Communications Alliance, Ryan Boone of Premier Communications, Tom Conry of Farmers Mutual Cooperative Telephone, and Josh Seidemann from NTCA met with staff from Chairman Ajit Pai's Office and staff from the Wireline Competition Bureau to discuss ACAM Locations. The group described Smart Ag applications and other rural home business models and explained the potential for business broadband connections at residential locations.

NTCA Member Golden West Telecommunications meets with FCC to talk about High-Cost Universal Service Support

On June 25, 2019, NTCA member Denny Law, CEO from Golden West Telecommunications and Mike Romano, NTCA Vice-President of Industry Affairs met with staff from Chairman Ajit Pai's and Commissioner Jessica Rosenworcel's office to discuss High-Cost Universal Service Fund (USF) support. Golden West and NTCA expressed gratitude for the efforts of the FCC to provide greater certainty to the USF funding model but noted concerns that the potential for action by the Commission in the form of imposing a new overall cap on USF programs could undermine the predictability finally restored by the December 2018 order and would hinder progress in broadband investments spurred by the decision.

NTCA Discusses Lifeline and Link-Up Reform and Modernization with the FCC-Wireline Competition Bureau

On June 24, 2019, Mike Romano, NTCA Senior Vice President of Industry Affairs spoke with Trent Harkrader, Deputy Chief of the Wireline Competition Bureau to voice concerns by NTCA member companies and cooperatives regarding new obligations imposed by the Universal Service Administrative Company (USAC) that would compel companies to provide personally identifiable information (PII) to USAC as part of the Lifeline Representative Accountability Database (RAD). Although NTCA expressed support for efforts by the FCC and USAC to address concerns about fraud or waste in the use of universal service resources, NTCA member employees should not be obligated to submit personal information for verification. NTCA recommended employees of a service provider should be required to submit business-related information to interact with the Lifeline RAD.

NTCA Comments on NTIA Voluntary Collection of Broadband Availability Maps

On June 20, 2019, NTCA filed comments in response to the request from the National Telecommunications and Information Administration (NTIA). NTIA is currently seeking approval from the Office of Management and Budget (OMB) to collect voluntary data that would be used to create a national map of broadband availability. NTCA voiced support for the creation of a single nationwide coverage map, but urged NTIA to "provide clearer guidelines regarding the methods that will be deemed acceptable to us when measuring and collecting the data" as well as to consider "a process to reconcile, validate or challenge the date prior to the publication of such data in a map."

NTCA Discusses Broadband Availability Mapping Issues with Chairman Pai's Office

On June 19, 2019, Mike Romano, Senior VP of Industry Affairs met with Preston Wise, Special Counsel, to Chairmen Ajit Pai to discuss Broadband Mapping issues. NTCA raised concerns that ongoing reports from providers indicate that the models used to develop buildout obligations do not resemble the "facts on the ground" in rural areas. NTCA suggested the Federal Communication Commission (FCC) conduct a more detailed investigation as why the models appear to be so amiss in estimating location counts in rural areas. NTCA also offered recommendations on how to improve the processes for identifying broadband availability and unserved locations.