#RuralIsCool Volume 1, Issue 11/February 28, 2019

USAC Reminds Providers of March 1 HUBB Filing Deadline

The Universal Service Administrative Co. has reminded providers that have not already certified locations in USAC’s HUBB (High Cost Universal Broadband) portal that the deadline for filing is March 1, 2019.

It is important that carriers review the USAC instructions carefully to ensure reporting of the proper information, rather than relying upon any summary like that in this newsletter.  As an overarching matter, subject to a number of important caveats that should be reviewed in USAC’s instructions, carriers that participate in these funds must file latitude and longitude coordinates for all broadband locations newly deployed or upgraded during the following periods:

  • Connect America Fund (CAF) Phase II: locations deployed in 2018
  • Alternative Connect America Cost Model (A-CAM): locations deployed in 2018
  • Rural Broadband Experiments (RBE): locations deployed in 2018
  • Connect America Fund-Broadband Loop Support (CAF-BLS): locations deployed in 2018

Alaska Plan participants must submit wireline end-user locations and middle-mile node locations (and associated shapefiles) deployed in 2018. Alaska Plan carriers with individualized performance plans that only require them to maintain service at existing levels are not required to file wireline end-user locations in the HUBB.

USAC said carriers with no locations to report still must log into the HUBB and select “No Locations to Upload” on the “Managing Uploads” screen of the HUBB.

FCC Offers $67 Million to Boost Broadband to Nearly 110,000 Rural Homes and Businesses

The FCC on February 25, 2019, said it had offered $67 million annually to support more robust broadband speeds for nearly 110,000 rural homes and businesses across 43 states.

The offer went to 207 rural rate-of-return carriers that currently receive funding via the Alternative Connect America Cost Model (A-CAM) on the condition that the providers make 25/3 Mbps service available in additional locations that otherwise would have received no greater than 10/1 Mbps service.

The carriers eligible for the new offer have one month from the issuance of the commission’s public notice to choose whether to elect to receive the revised amount of model support. Carriers that fail to submit a final election letter by the deadline will be deemed to have declined the revised offer and will continue to receive current support amounts and be subject to current deployment obligations.

FCC Open Meeting Agenda Includes Rural Call Completion

The tentative agenda for the FCC’s upcoming open meeting on March 15, 2019, includes rural call completion—specifically, consideration of a fourth report and order to implement the Improving Rural Call Quality and Reliability Act of 2017.

Noting that “rural call completion issues persist” and that they can have “significant impacts on quality of life, economic opportunity, and public safety in rural communities,” the commission said its fourth report and order would:

• Implement the Improving Rural Call Quality and Reliability Act of 2017 by establishing flexible service quality standards for intermediate providers (i.e., entities that carry, but do not originate or terminate, voice calls).

• Provide an exception to the new service quality standards for intermediate providers that qualify for the covered provider safe harbor in existing commission rules.

• Transition to the new service quality standards by sunsetting the commission’s existing call data recording and retention rules one year after the new standards become effective.

The meeting will be held at FCC headquarters on March 15, 2019, at 10:30 ET.

NTCA Talks Rate Floor, Performance Testing, ICC With Commission

As part of its ongoing advocacy on key issues before the FCC, NTCA–The Rural Broadband Association met February 21, 2019, with Travis Litman, chief of staff and senior legal adviser to Commissioner Jessica Rosenworcel, to share its concerns on three key issues.

First, as the association had advocated previously, it warned that the current rate-floor policy, if left unaddressed, could raise local voice telephony rates on rural consumers by nearly $9 per month starting in May.

Second, on performance testing, the association said testing standards remain “in flux,” and that providers remain unsure about how to test parts of networks they don’t own or control, among other concerns.

Last, on intercarrier compensation, the association asked the commission to take action only in areas where “clear and convincing evidence on the record confirms concerns exist with respect to particular practices or routing patterns,” but it added that “greater analysis and additional evidence are needed to establish where such concerns arise specifically and to target and tailor solutions for such concerns prior to adoption of any order in these proceedings.”

NTCA Discusses Spectrum Concerns With FCC

During a February 15, 2019, meeting with Umair Javed of FCC Commissioner Jessica Rosenworcel’s office, NTCA–The Rural Broadband Association brought up concerns it has over the planned allocation and auction of certain spectrum bands.

The association said it supports Rosenworcel’s proposal to auction 2.5 GHz spectrum, with the proceeds going toward education needs. However, with regard to priority licensing windows, the association suggested controls be in place to prevent larger carriers from obtaining discounted prices for the spectrum. The association added that any priority license holder looking to offer its spectrum on a secondary market transaction be required to at least work with a local service provider.

On the subject of the proposed reallocation of 3.7 GHz spectrum and a potential private market transfer of spectrum, the association explained that its members currently use 3.7 GHz spectrum for satellite downlinks, and therefore “any changes to the spectrum licensing rules must fully protect incumbent users and consumers from harmful interference and service loss and disruptions.” In addition, NTCA members should be “afforded a fair opportunity to acquire mid-band spectrum at reasonable prices.” Last, the association said the commission must avoid excessive concentration of licenses and distribute licenses among a wide variety of applicants. “The record in the proceeding does not make clear how a private sale mechanism would ensure transparency, inclusivity or competitive access to spectrum,” the association said.

Last, the association expressed its opposition to the Sprint/T-Mobile merger, saying that it doubted T-Mobile’s promise to offer 5G service to rural America. The association also said the loss of Sprint as a partner in roaming and spectrum leasing would have a negative impact on competition, pricing and rural service.

Notes in the News for February 28, 2019

The FCC’s Enforcement Bureau issued a reminder to telecommunications carriers and interconnected Voice over Internet Protocol (VoIP) providers that Customer Proprietary Network Information (CPNI) compliance documentation is due by March 1, 2019

Nominations for NTCA–The Rural Broadband Association board directors to fill open seats in the Northwest and Southeast regions were due February 8. All elections were uncontested, and as such, Roxie Mayberry (cooperative) and Allen Hoopes (commercial company) were elected in the former region and two incumbents, Fred Johnson (cooperative) and H. Keith Oliver (commercial company), were re-elected in the latter region.

The U.S. Department of Agriculture has announced new application deadlines for various aspects of its new ReConnect Program. Loan applications are now due July 12, 2019; applications for loan/grant products are now due June 21, 2019, and grant applications are due May 31, 2019.

The FCC’s Media Bureau is seeking comment on the TV ratings system and the oversight monitoring board. Comments are due by May 15, 2019.

The Global Positioning System will reset its week counter system to zero on April 6, 2019.

The U.S. Senate Commerce Committee held a hearing, “Policy Principles for a Federal Data Privacy Framework in the United States,” on February 27.

The U.S. House Committee on Energy and Commerce also held a data privacy hearing on February 26.

Secretary of Agriculture Sonny Perdue acted as a witness at both a U.S. Senate Agriculture hearing on implementing the Farm Bill and a U.S. House Agriculture Committee hearing on the state of the rural economy this week.

The newest FCC commissioner, Geoffrey Starks, recently issued a statement on Windstream Holdings Inc. filing petitions for bankruptcy.

The FCC’s Wireless Telecommunications Bureau has found 38 applicants qualified to bid in its auction of flexible use licenses in the 24 GHz band.

The budget agreement reached by Congress on February 15 included $550 million to support expansion of broadband service into sparsely populated rural areas.


NTCA–The Rural Broadband Association Senior Vice President of Industry Affairs and Business Development Michael Romano spoke February 28, 2019, at the Louisiana Telecom Association annual meeting in New Orleans, La.