#RuralisCool, Volume 1, Issue 43 | October 17, 2019


FCC Commissioner Jessica Rosenworcel, CISA Director Christopher Krebs to Headline NTCA Policy Summit 

The NTCA 2019 Telecom Executive Policy Summit, November 17–19 in Washington, D.C., will feature several notable speakers, including FCC Commissioner Jessica Rosenworcel and Christopher Krebs, director of the Cybersecurity and Infrastructure Security Agency (CISA) of the U.S. Department of Homeland Security. 

Commissioner Rosenworcel will address recent developments at the FCC, including an update on the Rural Digital Opportunity Fund (RDOF) and the agency’s efforts to improve the broadband mapping process. Director Krebs will provide an overview of the mission of CISA and trends in cybersecurity, especially those impacting small businesses.

NTCA CEO Shirley Bloomfield will also engage in a lively Q&A with Axios Managing Editor Kim Hart about her time as press secretary for the FCC, new endeavors at Axios and relevant policy trends she anticipates for 2020 and beyond. 

State Members of Joint Board on USF Advise Connections-Based Broadband Assessment 

State members of the Joint Board on Universal Service submitted a letter October 15 to the FCC commissioners with their recommendations on reforming contribution methodology for the Universal Service Fund (USF). 

In those recommendations, the state members find that the commission has the authority and that it is in the public interest to expand the contribution base to include broadband internet access service (BIAS). The state members advise the commission to adopt a connections-based assessment on residential services and an expanded revenues-based assessment on business services.

Recommendations also include establishing a firm budget for each of the USF programs, with those budgets not growing any more than the Consumer Price Index for any given year. In addition, the state members recommend that the commission take steps to assure the continued viability of state universal service mechanisms.

NTCA Continues to Advocate for Equitable, Efficient Performance Testing Requirements

Michael Romano, senior vice president of Industry Affairs and Business Development for NTCA, and Joshua Seidemann, NTCA vice president of policy, met with an advisor to FCC Commissioner Michael O’Rielly on October 11 to discuss performance measures for recipients of Connect America high-cost Universal Service support. NTCA supports the usefulness of network testing but highlighted the need to ensure the protocols can be implemented in ways that are administratively and economically equitable and efficient for rural telecom providers. 

Romano and Seidemann recommended that providers test only those portions of the network that are actually supported by universal service funds and under the control of the operator. They noted that rural providers do not control facilities leased from a middle-mile provider and lack the bargaining power that the Performance Measure Order conjectures they possess. 

NTCA also discussed the value of a “safe harbor” that would ensure that a provider that purchased sufficient capacity and entered into reasonable arrangements to ensure service would be accorded a presumption of compliance if it could demonstrate than an event or events that caused a test failure occurred outside the network that the provider owns or controls.

Another concern expressed by NTCA relates to the penalties for failed performance tests. As one example, NTCA indicated that the Draft Reconsideration Order appears to establish what amounts to “double jeopardy,” as a carrier that fails to meet speed and latency requirements could be penalized for not achieving performance objects and for not meeting deployment objectives. The latter would occur when a provider was considered to have not built to certain locations because the provider was unable to meet speed and latency requirements for those locations.

Finally, NTCA expressed concern that consumer consent issues may exist where software-based solutions are implemented. This would exist where the current customer equipment is incapable of supporting the software-based solution and would require replacement. The issue could be particularly concerning where the subscriber owns the device, Romano and Seidemann noted.

NTCA Supports House Broadband Speed Act

The Broadband Speed Act, introduced in the House of Representatives by Rep. Antonio Delgado (D-N.Y.), aims to address flawed broadband mapping practices and increase speed standards in rural communities.

In a statement, NTCA Chief Executive Officer Shirley Bloomfield thanked Delgado for his ongoing interest in promoting the availability of high-speed broadband services and improving the accuracy of broadband speed data reported by providers. 

Notes in the News

NTCA, in conjunction with a group of stakeholders representing smaller video providers, sent a letter to U.S. House and Senate Commerce Committee leadership urging them to help smaller video providers, as part of the reauthorization of STELAR, by providing buying groups used by these operators with the same good faith protections afforded larger 

The FCC authorized over $61.8 million in rural broadband funding over the next decade, which will go toward expanding broadband to nearly 22,000 unserved rural homes and businesses in 14 states.

In a public notice, the FCC Public Safety and Homeland Security Bureau shared lessons learned from several recent major communications network outages and encouraged providers to review industry best practices to help ensure network reliability.

Jill Canfield, NTCA vice president of legal, was re-elected to the NG911 Institute’s board

Adam Jorde, director of government affairs for NTCA, did a presentation with Andrew Ward of Award Consulting Services about robocalls at the Washington Independent Telecommunications Association on October 15