NTCA–The Rural Broadband Association filed reply comments July 25, 2019, with the FCC pointing out that those who filed comments in the proceeding unanimously supported the request by Northeast Iowa Telephone Co. (Monona, Iowa) and Western Iowa Telephone Association for clarification or modification of the Universal Service Administrative Co.’s (USAC) guidance regarding whether residential locations that are co-located with a business count as two separate locations for purposes of complying with the commission’s service requirements.
NTCA noted that the “record unmistakably demonstrates that carriers have been relying upon the [commission’s] definition of serviceable locations … in determining whether to elect A-CAM support” and “changing the rules midstream would be detrimental to carriers that relied upon” that definition. NTCA also commented that USAC’s guidance creates “uncertainty among carriers” and adds “unnecessary costs and delays to customers seeking to subscribe to broadband service in rural areas” due to the conflicting statement that carriers must install separate equipment to any business location that shares the same property as a residence.