Federal Filings and Ex Parte

On June 7, 2019, Mike Romano, Senior Vice President-Industry Affairs met with Nirali Patel, Wireline Advisor to Chairman Ajit Pai to discuss the Commission's proposal to curb terminating access arbitrage in the intercarrier compensation systems. NTCA urged the Commission to ensure that any reforms adopted are targeted to address terminating access arbitrage and do not sweep so broadly as to affect innocent local exchange carriers.

On June 3, 2019, Mike Romano, NTCA Senior VP of Industry Affairs met with staff from the Wireline Competition Bureau (WCB) to discuss related to Identification and Reporting of locations where voice and broadband services are made available for purposes of compliance with deployment obligations. NTCA encouraged the Bureau to provided further guidance as to how providers can show that they are delivering robust and reliable voice and broadband services to consumers consistent with applicable buildout duties despite having done so prior to any obligations rising. NTCA also requested clarification of the process whereby recipients of USF support can identify any discrepancies in locations.

On June 3, 2019, NTCA filed comments supporting the FCC's proposal to create rules that would encourage large providers to partition/disaggregate/lease unused portions of their spectrum to small, rural carriers. NTCA recommended establishing construction benchmarks, and penalties for missing those benchmarks, for all licenses covering geographic areas that are the size of partial economic areas or larger. NTCA also recommended implementing a "use it or lose it" requirements for existing licensees.

On May 31, 2019, Mike Romano, NTCA Senior Vice President of Industry Affairs, and James Dawson of Jenner & Block, LLP, met with the Federal Communications Commission, Wireline Competition Bureau to discuss terminating access arbitrage in the Intercarrier Compensation System. NTCA encouraged the Commission to adopt a proposal that implements appropriate safeguards to protect innocent LECs that do not engage in access stimulation.

On May 21 2019, Brian Ford, NTCA Director of Industry Affairs met staffers from the Offices of Chairman Pai, Commissioner Rosenworcel, Commissioner O'Rielly, Commissioner Carr and Commissioner Starks to discuss methods to target and eliminate Unlawful Robocalls. NTCA reiterated its members commitment to combatting the scourge of unwanted and illegal robocalls. NTCA noted the Commission would need to ensure that only rural consumers' unwanted and illegal calls would be blocked to protect the reliability of telephone network.

On May 16, 2019, NTCA filed an Ex Parte letter to the Federal Communications Commission (FCC) encouraging the Commission to adopt rules that would eliminate clearly identified arbitrage resulting from transport charges as they apply specifically to stimulation. NTCA pointed out that these proposed rules must focus only on alleged "access arbitrage" and must not be included as part of any larger changes to interconnection rules applicable to all providers.

On May 9, 2019 NTCA, ACA and NRECA jointly filed an Ex Parte letter to the Federal Communication Commission applauding the Commission's announcement of the creation of the Rural Digital Opportunity Fund (RDOF). This move would ensure that rural areas have broadband service that is comparable to the increasing performance provided in urban area.

On May 7, 2019, NTCA filed an Ex Parte presentation maintaining support for performance measurement protocols to confirm deployment of broadband networks that meet robust capability targets associated with high-cost support. However, NTCA and its members have identified various issues that must be resolved before successful implementation of the rules can be achieved.

On May 6, 2019, NTCA filed a Reply to Opposition and Comments in regards to two Petitions for Reconsideration filed by Silver Star Telephone Company and Pineland Telephone Cooperative. NTCA mentioned that a grant of the petitions would enable these rural providers, as well as similarly situated operators, to invest more resources in network deployment.