Federal Filings and Ex Parte

On January 16, 2020, NTCA and industry partners jointly filed a letter to Chairman Pai and Commissioners O'Reilly, Carr, Rosenworcel and Starks noting the need to significantly reduce the burdens of the letter of credit (LOC) requirements in the RDOF auction so that the obligations correspond more appropriately to the risks presented. The group highlighted the importance of connecting every American to broadband and stated that many of our members are motivated about the prospects of participating in the RDOF auction this year.

On January 16, 2020, NTCA Member Doug and Ryan Boone, of Premier Communications and Mike Romano, of NTCA met with staff from Chairman Pai, Commissioner O'Rielly, Commissioner Rosenworcel and Commissioner Carr's Offices to discus the Rural Digital Opportunity Fund ("RDOF"). During the meeting NTCA offered support for the proposed structure for the RDOF Auction and urged the Commission to proceed as promptly as possible to launch RDOF while asking the Commission not to overlook the mandate to promote reasonably comparable services at reasonably comparable rates for unserved areas in rural communities.

On January 14, 2020, NTCA met with staff from the FCC Wireline Competition Bureau ("WCB") to discuss the urgent need for IP interconnection rules for voice traffic. The association stated that simple "rules of the road" will hasten rural carrier participation in anti robocalling standards as well as ensure the continued affordability of voice rates in rural areas.

On January 10, 2020, NTCA joined Industry Partner on a joint letter urging the Department of Commerce provide clearly defined, advance notice of equipment or services posing a Cyber threat. The letter highlighted the need to align any rules governing the "supply chain security" with other federal agencies, such as the FCC and the National Defense Authorization Act of 2019.

On January 10, 2020, NTCA filed comments with the Department of Commerce in response to the Department's request for comments on proposed rules governing the identification and removal of equipment and services from communications' providers networks if the equipment and/or services poses a threat to national security. NTCA recommended Commerce align any rules governing "supply chain security" with other federal agencies, such as the FCC and the National Defense Authorization Act of 2019. NTCA also joined thirty other companies urging the Department of Commerce to work with industry to develop rules that will address national security without the uncertainty that the proposed rules would create for the communications industry.

On January 7, 2020, NTCA filed an Ex Parte letter responding to USTelecom's proposal that uses the Rural Digital Opportunity Fund ("RDOF") to deploy and sustain lower speed broadband networks over the next decade in rural America. NTCA noted that at a time when digital opportunity in urban areas is generally well above the speed targets advocated by USTelecom, it would be opportunity lost for rural America if the RDOF auction were to favor specifically and distinctly lower speed tiers.

On January 6, 2020, NTCA and ACA Connects responded to a recent Ex Parte filed by USTelecom that argued for lower upstream speeds in the proposed Rural Digital Opportunity Fund 100 Mbps performance tier. NTCA and ACA Connects asked the Commission to reject USTelecom's proposal countering it is inconsistent in the Commissions goal of using universal service funding to close the digital divide. NTCA's letter highlighted several reasons why USTelecom's proposal does not reflect the best course of action in developing the RDOF auction and voiced concerns their proposal would be a deterrent to broadband deployment in rural America.

On December 19, 2019, NTCA-The Rural Broadband Association, along with ACA Connects-America's Communications Association, the Fiber Broadband Association and the National Rural Electric Cooperatives Association met with Preston Wise, rural broadband advisor to Chairman Ajit Pai to discuss the Rural Digital Opportunity Fund (RDOF). The group stated although each of the parties has proposed slightly different weighting and tiering structures for the RDOF auction, each share an interest in maximizing participation in the upcoming auction from bidders across all tiers of service as well as an effective use of the available budget to advance the mission of universal service.

On December 17, 2019, NTCA met with staff from the FCC Wireline Competition Bureau to discuss Lifeline and Link-Up Reform. NTCA discussed options to implement requirements that ask for the submission of personally identifiable information by employees of NTCA members in connection with the Lifeline Representative Accountability Database. NTCA supports any efforts that address concerns about fraud in the use of universal service resources but asked for some level of differentiated treatment between employees of eligible telecommunications carriers and independent contractors or agents in collection such information.