Federal Filings and Ex Parte

In comments filed on July 29, 2019 NTCA registered its opposition to the implementation of an overall cap on the Universal Service Fund (USF). It noted that a cap is contrary to both law and policy and would place at risk the complementary missions of universal service as Congress intended

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)

In comments filed on July 24, 2019, NTCA discussed ways the FCC can facilitate rural carriers’ implementation of anti-caller-ID spoofing technology. NTCA further noted that there are important steps the FCC can take to protect rural consumers from having their legitimate calls inadvertently blocked.

On July 19, 2019, Mike Romano, Senior VP of Industry Affairs met with Randy Clarke, Wireline Advisor to Commissioner Geoffrey Starks to discuss the Rural Digital Opportunity Fund ("RDOF") and Mapping issues. NTCA expressed support for the establishment of rules for the RDOF auction but urged the Commission to include commentary that would foster discussion and promote efficiency by promoting investments in networks with capabilities that will outlast the initial term of support.

On July 19, 2019, NTCA filed comments encouraging the FCC to decline to adopt a pro rata approach to reducing carriers' funding pursuant to the Alternative Connect America Cost Model ("A-Cam") if the carrier is willing to commit to providing service throughout their support areas. NTCA noted that this approach is consistent with industry practice and the method used to develop A-CAM support. NTCA mentioned that providers deploy infrastructure throughout service areas, conduct the engineering studies, obtain any necessary permits needed to install network facilities regardless of the precise number of locations to be served.

On July 16, 2019, Mike Romano and Brian Ford of NTCA, and NTCA Member, Denny Law, of Golden West Telecommunications met with Nicholas Degani, Senior Counsel, and Nirali Patel, Wireline Advisor to Chairman Ajit Pai. NTCA discussed how the Commission can facilitate RLEC's full participation in the SHAKEN/STIR caller-ID "spoofing" mitigation framework by adopting policies that will not incur transport charges upon small carriers and the rural customers they serve. NTCA noted our members have a strong commitment to combatting the scourge of illegal caller-ID spoofing.

On July 16, 2019, NTCA filed reply comments to the Texas Carrier's Petition for Rulemaking that seeks more effective use of USF resources through better coordination among programs and by leveraging, where possible, high-quality broadband networks that are already available in rural America and supported by the Federal Communications Commission's High-Cost program.

On July 11, 2019, NTCA filed an Ex Parte Letter as a follow-up to a prior meeting with Preston Wise, special counsel to Chairman Ajit Pai. In the letter NTCA addressed concerns that increasing standalone broadband conversions could reintroduce troubling effects of the Universal Service Fund (USF) budget control mechanisms soon after the Commission took the important and much-welcome steps to overcome the uncertainty. NTCA reaffirmed that no provider should lose prior support in connection with any policy adopted to address concerns to of the funding mechanisms.

On July 10, 2019, NTCA filed comments with the Federal Communications Commission (FCC) supporting a Petition for Clarification or Declaratory Ruling filed by Northeast Iowa Telephone Company and Western Iowa Telephone Association. The petition noted disparities between USAC's HUBB FAQ "definition" of locations that share the same property as a residence and the Commission's rules and orders. NTCA recommended the Commission direct USAC to modify the FAQ to strike a balance between accountability and flexibility that reflects rural realities and is consistent with the Commission's rules and orders.