On August 207, 2018, NTCA–The Rural Broadband Association (“NTCA”) filed these comments in response to the Further Notice of Proposed Rulemaking (“FNPRM”) recently released by the Federal Communications Commission (the “Commission”) in proceeding CC Docket 80-286. The FNPRM seeks comment on: (1) a proposal to extend the existing short-term jurisdictional separations freeze for 15 years; (2) whether the Commission should alter the scope of its referral to the Federal-State Joint Board on Separations (“Joint Board”); and (3) a proposal to allow RLECs that elected to freeze their category relationships in 2001 a chance to opt out of that freeze.
