Federal Filings and Ex Parte

On November 22, 2019, NTCA filed comments on Notice of Inquiry Concerning Deployment of Advanced Telecommunications Capability to all Americans in a Reasonable and Timely Fashion. NTCA urged the Commission to take a long-term view of the sustainability of broadband networks and affirm its previously adopted conclusion that while mobile broadband services provide significant value of their own they are not a substitute for fixed broadband services.

On November 19, 2019, NTCA member Jimmy Todd, General Manager of Nex-Tech in Lenora, Kansas and Brian Ford of NTCA met with staff from the FCC Wireless Telecommunication Bureau to urge the FCC to grant the Petition for Waiver filed jointly by the Wireless Internet Service Providers Association (“WISPA”) and the Utilities Technology Council (“UTC”) requesting an extension of the April 17, 2020 deadline in regards to the Part 96 Citizens Broadband Radio Service (“CBRS”) rules. NTCA noted many companies including Nex-Tech use CBRS spectrum to offer fixed wireless broadband service to difficult to reach customers and would be adversely affected by the deadline to replace equipment in order to become compliant.

On November 15, 2019, NTCA filed reply comments in response for suggestions on ways to improve the E-Rate application form 470. NTCA supported adding a new tab in the Form 470 drop down menu that would allow E-Rate entities to select the name and address of the entity requesting services. NTCA noted, that currently the only place where this information can be entered on the form is in the "narrative field" and can be easily missed by the applicant. NTCA mentioned valuable time is lost by interested providers tracking down the location(s) to be served, thereby potentially decreasing the number of bids an E-Rate provider may receive.

On November 14, 2019, NTCA filed Reply Comments with the FCC in response to the FCC's proposal to expand the types of wireless service applications that can be filed electronically. NTCA stated that electronic filing benefits filers by providing immediate filing confirmations and faster processing and should be encouraged. NTCA also supported requiring all filers to include an email addresses where communications related to the application could be received, while cautioning the Commission not to rely solely on electronic communications regarding applications due to the fact that an applicant or licensee could miss a crucial deadline if it fails to receive, and respond to, Commission correspondence, possibly leading to a dismissal of the application or license.

On November 12, 2019, NTCA filed reply comments on the competitive bidding procedures for Auction 105, the auction of Priority Access Lines. As indicated in the public record, NTCA and a broad cross-section of the industry opposed the proposal to utilize Cellular Market Area-level bidding. NTCA noted the current proposal is too complex, would undermine the goals of Auction 105 and would limit small, rural and regional carriers' ability to compete effectively at auction for this valuable spectrum. The Commission should therefore move forward with Auction 105 utilizing county-based license areas only.

On November 8, 2019, NTCA filed an Ex Parte letter commenting on the Draft Order on Supply Chain. NTCA supports the Commission's efforts to find a reasonable but expeditious path forward to identify, manage and address potential national security risks in the communications supply chain. NTCA noted the Commission must address the financial impacts to small, rural entities, that may have previously deployed equipment manufactured by "covered companies" before proceeding with a "rip and replace" policy.

On November 8, 2019, Mike Romano, of NTCA met with Nirali Patel, wireline advisor to Chairman Ajit Pai to discuss 8YY Access Charge Reform and Lifeline minimum service standards. NTCA discussed the implications of 8YY originating access reforms on rural consumers and carriers and urged the Commission to ensure sufficient recovery mechanisms are in place for RLEC's. NTCA clarified their Petition for Waiver for Lifeline would only enable an existing customer to choose not to upgrade to a higher-speed service and instead to retain their existing service even if that services were below the minimum service standard.

On October 28, 2019, NTCA filed comments on the bidding procedures for Auction 105 to the Federal Communications Commission. NTCA urged the FCC to modify the Public Notice proposal for Cellular Market Area level bidding to ensure a competitive auction among bidders of all sizes for access to the valuable spectrum available in Auction 105.

On October 21, 2019, Mike Romano and Tamber Ray met with staff from Chairman Ajit Pai's office regarding NTCA's request for waiver of the increased minimum service standards for Lifeline customers scheduled to take effect December 1, 2019. NTCA stated that it supports the Commission's concern that Lifeline customers not be relegated to low-speed fixed broadband service, but recommended the FCC allow existing Lifeline customers to choose between their current speed tier and the minimum standards. NTCA further requested that the Commission act on the waiver request pursuant to delegated authority prior to December 1, 2019.