Federal Filings and Ex Parte

NTCA Comments on Digital Opportunity Data Collection

On September 23, 2019, NTCA filed comments in the Digital Opportunity Data Collection proceeding. NTCA encouraged the Commission to ensure consistency in reporting by prescribing common technical standards for reporting broadband availability. NTCA mentioned policy should include a robust challenge validation process that is a critical part of refining baseline mapping data prior to its use in any policy or funding decision.

NTCA Comments on the Rural Digital Opportunity Fund

On September 20, 2019, NTCA filed comments noting that with Rural Digital Opportunity Fund ("RDOF"), the Commission has the opportunity to promote the goal of closing the digital divide in rural America. NTCA stated to accomplish this goal, the Commission must adopt rules that require RDOF participants demonstrate that they truly have the capability to deliver robust voice and broadband services in their chosen area.

NTCA and AT&T Jointly Propose Modifications to FCC Order Regarding Access Stimulation

On September 19, 2019, NTCA and AT&T talked with Nirali Patel, Wireline Advisor to Chairman Ajit Pai, and Lisa Hone, Deputy Chief of the Wireline Competition Bureau, to offer suggestions on identifying when rate-of-return incumbent local exchange carriers ("RLECs") might be engaged in access stimulation and for resolving any disputes as to whether an RLEC is engaged in such activities.

NTCA Addresses Performance Measurement Labor Burdens in Comments to OMB

On September 19, 2019, NTCA filed comments to the Federal Office of Management & Budget (OMB), which explained the steps rural providers must take before performance measuring testing can commence. NTCA urged the OMB and FCC to consider the labor hours involved when estimating the annual hourly burden on providers who implement the requirements.

NTCA Discusses Access Arbitrage Concerns with staff from Commissioner Starks and Commissioner Carr's Offices

On September 16, 2019, Mike Romano met with staff from Commissioner Starks and Commissioner Carr's offices to discuss Access Arbitrage issues concerning rural carriers. NTCA stated we continue to support target actions to address inefficient access stimulation practices to ensure that such arbitrage does not undermine the integrity of the intercarrier compensation system. However, NTCA noted concerns that the Draft Order may inadvertently sweep in RLEC's that are not engaging in access stimulation.

NTCA Discusses Access Arbitrage Concerns with staff from Chairman Pai, Commissioner O'Reilly and Commissioner Rosenworcel's Offices

On September 13, 2019 Mike Romano met with staff from Chairman Pai, Commissioner O'Reilly, and Commissioner Rosenworcel Offices to discuss Access Arbitrage issues concerning rural carriers. NTCA stated we continue to support targeted actions to address inefficient access stimulation practices to ensure that such arbitrage does not undermine the integrity of the intercarrier compensation system. However, NTCA noted concerns that the Draft Order may inadvertently sweep in RLECs that are not engaging in access stimulation.

NTCA Files Reply Comments on Lifeline Proposed Changes

On September 13, 2019, NTCA filed reply comments stating that commenters universally supported NTCA's Petition for Waiver of the scheduled December 1, 2019, increase in minimum service standards for Lifeline subscribers. NTCA and commenters noted that requiring Lifeline subscribers to a higher speed Internet service would likely result in some Lifeline subscribers disconnecting their service due to inability to afford the increased cost of service. NTCA requested the Commission allow Lifeline subscribers the option of choosing to subscribe to broadband service at the current minimum services standard or to any updated minimum services standard established by the Commission in the future.

NTCA Members discuss Access Arbitrage with the Wireline Competition Bureau

On September 9, 2011, Denny Law of Golden West Telecommunications, Ryan Boone of Premier Communications and Trey Judy of Hargray Communications joined Mike Romano, NTCA Vice President of Industry, to talk with staff from the FCC's Wireline Competition Bureau and Office of Economics and Analytics. NTCA stated their continued support of targeted actions to address inefficient access stimulation practices however they noted concerns that the Draft Order may inadvertently include RLECs that are not engaging in access stimulation. NTCA suggested modifications to the Draft Order to ensure any new rules do not sweep in non-access stimulating carriers.

NTCA discusses Intercarrier Compensation with Staff from Chairman Pai's Office

On August 30, 2019, Mike Romano talked with Nicholas Degani and Nirali Patel from Chairman Ajit Pai's office on the FCC proposed changes to eliminate access arbitrage. NTCA noted that any change to the definition of access stimulation must be structured carefully to ensure that smaller rural operators do not become embroiled in disputes and self-help measures by larger carriers due to traffic imbalances that have no relationship whatsoever to access stimulation. NTCA supports the efforts to eliminate arbitrage of the intercarrier system by the Commission but highlighted that any effort should take care to prevent unintended harms to LEC's.