NTCA raised concerns that parties may seek to leverage migration of intercarrier compensation rates to bill-and-keep as a basis for shifting interconnection responsibilities, foisting additional costs upon rural local exchange carriers (“RLECs”). Building upon a comparable rule established in 2011, NTCA urged adoption of a default rule to preclude parties from unilaterally dictating changes to existing financial responsibilities for interconnection and transport.
8YY Access Charge Reform, WC Docket No. 18-156