#ruraliscool Volume 1, Issue 1/December 6, 2018

**Editor's Note: Welcome to the first issue of NTCA's #RuralIsCool! This evolution of our Washington Report e-newsletter continues to bring you the latest advocacy news and updates from the rural broadband industry, while adding member news, social buzz and stories of innovation. Current Washington Report subscribers will continue to receive #RuralIsCool each Thursday. Others can sign up here to receive the newsletter. Thank you for your continued readership.**

NTCA Expresses Strong Support for Draft USF Order; Identifies Matters for Further Consideration

In a November 30, 2018, meeting with Arielle Roth, wireline legal adviser to FCC Commission Michael O’Rielly, NTCA–The Rural Broadband Association expressed its strong support for a draft order on Universal Service Fund (USF) support that is circulating among commissioners ahead of a potential vote during the commission’s December open meeting.

The association said that the draft order “as currently designed would take substantial steps toward fulfillment of statutory mandates with respect to predictability and sufficiency, promote the effectiveness of existing USF support mechanisms, and achieve important public policy objectives with respect to promoting network investment and ensuring the availability of services for the benefit of consumers on a reasonably comparable basis between rural and urban areas.”

The association also raised concerns regarding “verification of Form 477 data in connection with accurately confirming the extent of any competitive overlap and the operation of budget controls over time.”

NTCA Supports FCC USF Order, Expands on Form 477 and Other Concerns During Meetings With Commission

In meetings with the FCC November 27 and November 29, 2018, NTCA–The Rural Broadband Association addressed potential Universal Service Fund (USF) action by the commission.

During each of the meetings, the association voiced support for a draft order addressing USF support circulating ahead of a potential commission vote during its December open meeting (see related story, “NTCA Expresses Strong Support for Draft USF Order; Identifies Matters for Further Consideration,” in today’s issue of #RuralIsCool).

The association also brought up, however, concerns regarding verification of Form 477 data “in connection with accurately confirming the extent of any competitive overlap, proper calibration of buildout obligations to reflect increased speed targets, changes to the budget control mechanism calculation and the per-line cap on cost-based support, and pending petitions for reconsideration with respect to model-based support.”

The November 27 meetings were with Arielle Roth, wireline legal adviser, and Kagen Depain, legal intern, from the office of Commissioner Michael O’Rielly; Jamie Susskind, chief of staff for Commissioner Brendan Carr; and Travis Litman, chief of staff for Commissioner Jessica Rosenworcel. The November 29 meetings were with Preston Wise, special counsel to Chairman Ajit Pai; and Ted Burmeister (by phone), Jesse Jachman, Sue McNeil, Alexander Minard and Suzanne Yelen from the Wireline Competition Bureau.

NTCA Suggests Modifications to FCC’s Draft Order on Robocalls

In a December 3, 2018, letter to the FCC, NTCA–The Rural Broadband Association identified three areas where “modest modifications” to the commission’s draft second report and order on targeting and eliminating unlawful robocalls could support the commission’s objectives in that proceeding.

  • First, to help ensure that the North American Numbering Council (NANC) produces a robust set of technical recommendations for implementing and operating the new reassigned numbers database, a recommended fee structure and fee amounts, the commission should give the NANC at least nine months to complete its work instead of six. The order also “should make clear that in developing the technical recommendations for implementing and operating the new reassigned numbers database, the NANC should consider minimizing the burdens on reporting providers as one of its primary goals.” The commission also should build in processes to ensure that the NANC can leverage expert and stakeholder input, and it should wait to submit its Paperwork Reduction Act analysis of the final rules until the details regarding the interface specifications and reporting format recommendations of the NANC are shared with the commission.
  • Second, the commission should build in a measure of flexibility for voice providers to comply with the proposed 45-day minimum aging period.
  • Third, the commission should address TCPA liability issues promptly and provide a safe harbor for callers that utilize the new database.

The association was joined in the letter by American Cable Association (ACA), CTIA and US Telecom. Subsequently, NTCA and ACA held  separate meetings with FCC Chairman Ajit Pai and Commissioner Michael O’Rielly to emphasize minimizing the burdens on small carriers.

Notes in the News for December 6, 2018

The U.S. House Energy and Commerce Committee’s Communication and Technology Subcommittee has rescheduled its hearing, “RAY BAUM’S Act: A Bipartisan Foundation for Bridging the Digital Divide,” for December 11, 2018. 

The FCC’s Wireline Competition Bureau (WCB) has announced comment deadlines on its business data services (BDS) proceedings, and made available secure data relevant to the second further notice on price-cap BDS.

The WCB is seeking additional comment on determining the urban and rural rates of support in the FCC’s Rural Health Care Program.

The Mobility Fund Phase II Challenge Process Portal has been updated for the seventh time, as of November 27, 2018.


NTCA Regulatory Counsel Tamber Ray on December 6, 2018, attended “Anywhere to Anywhere Together,” an event in Washington, D.C., focused on accelerating telemedicine/virtual care innovation for veterans. 

NTCA Senior Vice President of Industry Affairs and Business Development Michael Romano presented a Washington update at the Broadband Association of North Dakota Annual Meeting on December 4, 2018, in Bismarck, N.D.  

NTCA Director of Government Affairs Michael Daniels took part in a panel discussion, “Washington Scene Review,” December 4, 2018, at the Indiana Broadband & Technology Association’s December Conference in Indianapolis, Ind.

NTCA Vice President of Policy Joshua Seidemann presented on performance measurement obligations at the Minnesota Telecom Alliance managers meeting on December 6, 2018.