Comments on USF/ICC FNPRM, Round 2 Drop February 24, 2012

So far this year JSICA has covered legal challenges, ex parte meetings, letters, comments, reply comments, petitions to deny, opposition to petitions to deny, and replies to oppositions to deny various aspects of the FCC's USF/ICC Transformation Order. The work is not over yet, not by a long shot. On February 24, 2012, stakeholders will submit comments on Sections L-R in the FNPRM, which primarily deal with unresolved issues in intercarrier compensation, the transition to bill-and-keep, and IP-to-IP interconnection. We can likely expect rural telecom stakeholders to present impact studies and analysis of why the transition to bill-and-keep will be financially detrimental.

The full list of topics up for debate in the second round of FNPRM comments includes:

1. Transitioning all rate elements to bill-and-keep
2. Bill-and-keep implementation
3. Reform of end user charges and CAF ICC support
4. IP-to-IP interconnection
5. Further call signaling rules for VoIP
6. New intercarrier compensation rules

After the extremely depressing comments in FNPRM Round 1 about quantile regression analysis and rate-of-return represcription depicting an RLEC doomsday, Round 2 might prove to be light reading in comparison. Next week, Cassandra Heyne will analyze these comments and report on the big issues for RLECs.

Comments on the Mobility Fund Phase I are also due February 24, ensuring a fun weekend for all. 

NECA, Rural Associations Respond to CTIA Letter

Source: NECA Press Release

NECA, NTCA, OPASTCO and WTA sent the FCC a letter regarding the treatment of intraMTA traffic between local telephone companies and wireless carriers. The associations dispute the arguments of wireless association CTIA, who urges immediate implementation of a bill-and-keep arrangement, and reaffirm their support of the midsize carriers’ proposal to treat reciprocal compensation traffic in the context of any and all rate transitions.

The associations explained that CTIA’s arguments are simply inapplicable to small, rate-of-return regulated providers. For example, while CTIA said the impact of bill-and-keep on price cap carriers is insignificant, it did not address the effect on RLECs. According to NECA’s analysis, more than 90 percent of RLECs it surveyed have reciprocal compensation rates higher than $.0007 per minute. Likewise, CTIA’s argument that bill-and-keep is an offset to purported benefits for price cap LECs under the FCC’s USF/ICC Order is not applicable to rate-of-return carriers.

The associations urged the FCC to support the mid-size carriers’ request on how to handle intraMTA traffic. At a minimum, any rate reductions for intraMTA traffic should be paired with the availability of the Recovery Mechanism established in the Order.

Court Challenges Begin on USF/ICC Reform

Source: The ILEC Advisor

As rural stakeholders have been busy analyzing the potential impacts of the USF/ICC Order, 3 parties have already moved on to the courts by filing lawsuits or petitions for review. On December 9, NTCA announced it has filed a petition for judicial review with the Fourth Circuit Court of Appeals (VA). NTCA argues that the rules, particularly bill-and-keep and the $250 per line cap on USF support are arbitrary, capricious, and all-around bad news for rural telecom providers. Cassandra Heyne looks at NTCA's petition for review and discusses the FCC's defense of bill-and-keep.

Read the full story here.