(Jan 24) Pointing out that the CAA did not require the FCC to eliminate the sub-prioritization for Eligible Telecommunications Carriers (ETCs) seeking reimbursement for the cost of removing and replacing equipment deemed a threat to national security, as previously adopted by the FCC, NTCA also stated in its January 24 filing with the FCC that the well-reasoned basis for prioritizing ETCs to ensure they receive full reimbursement for the cost of removing and replacing covered equipment and services has not changed. Specifically, as NTCA described in earlier comments, ETCs not only are quite conceivably most in need of reimbursement funding due to the high cost of providing service to their communities but also are at risk of losing critical universal service funding if they do not remove and replace covered equipment and services.
