NTCA and Others Send Letter to FCC Explaining Unexpected Shared View
On March 8, 2012 NTCA, NCTA, Cbeyond, Earthlink, Integra Telecom, Frontier, tw telecom, and Windstream wrote to FCC Chairman Julius Genachowski to express their thoughts on the treatment of originating access charges. The group writes, “The undersigned parties do not necessarily share a common view on the appropriate long-term framework for originating access, but we all agree that, consistent with the principle of symmetric treatment established in the CAF Order, the Commission should resolve this dispute by stating that all originating access charges are subject to the same treatment pending further reform.” Considering that many of the undersigned represent polar opposite viewpoints on other aspects of USF/ICC reform, this letter appears to signal a significant industry consensus on one of the important issues that the FCC is likely to rule on in the coming months. Originating access is one of the topics in the second part of the FNPRM, to which comments were filed last month.
The letter continues, “There are numerous advantages to the Commission acting quickly to state that the appropriate jurisdictional originating access rates apply for all traffic and all originating intrastate access traffic will be treated the same prior to the completion of the public comment process that is currently underway. By providing for the symmetrical treatment of originating access in the near term, the Commission will avoid creating further asymmetries between VoIP-PSTN and non-VoIP-PSTN traffic and foreclose what otherwise could be new avenues of arbitrage.” The group asks the FCC to cap intrastate originating access rates at the December 29, 2011 level for price cap carriers and CLECs that benchmark access rates to price cap carriers; and “place no limits on originating access rates for rate-of-return carriers and CLECs that benchmark to rate-of-return carriers.”
In addition to curbing arbitrage and avoiding asymmetries between different types of traffic, the group believes that this approach “would ensure that reforms do not disrupt further broadband investment by incumbents or competitors,” and “defer any need to reexamine access replacement support in response to originating access charge reduction.” In previous comments, NTCA and the Rural Associations urged the FCC not to reduce RLEC originating access rates to zero under a bill-and-keep methodology because the impacts of terminating access reduction and other ICC reforms are still unknown. The Rural Associations argued that RLECs would have a difficult time recovering originating access revenue, which could lead to unpleasant rate increases for customers.
Read the full letter here.