Nebraska PSC Advocates States' Role in USF

NPSC Argues State Commissions are “Valuable” and Should Not be Preempted

The Nebraska Public Service Commission (NPSC) submitted comments last week in response to the FCC’s Universal Service-Intercarrier Compensation Transformation Proceeding Public Notice, where it primarily focused on the price cap ILECs’ ABC Plan proposal to preempt state authority in the reformed USF/ICC system.  NPSC argued that parts of the ABC Plan should be rejected, while other parts could be modified.  NPSC refers favorably to the Federal-State Joint Board’s plan, and they do not comment specifically on the Rural Association’s RLEC Plan.

NPSC believes that the proposal to preempt state authority is inconstant with the current laws: “The legal framework of the ABC Plan which uses preemption of state rate setting authority, carrier designation and carrier of last resort obligations, contradicts the explicit federal-state partnership required by the Telecommunications Act.”  NPSC warns that since “many competitive carriers, cable providers, smaller wireless and wireline providers, state governments and consumer advocates” did not participate in the ABC Plan negotiations, the FCC should be wary about accepting the plan without modification.

NPSC urges the FCC not to disregard the Telecommunications Act or Congressional intent, and the Act “expressly reserves state jurisdiction over intrastate rates, terms and conditions.”  Furthermore, “the Commission has no power to act, let alone preempt validly enacted legislation of a sovereign state, unless and until Congress confers power upon it.”  NPSC also worries that states could abandon broadband programs, and preemption of state authority could discourage states from providing additional state-level universal service support.

A more appropriate framework, according to NPSC, would include a coordinated federal-state partnership, not unlike the current partnership between NPSC and the FCC.  NPSC explains that it has an effective partnership with the FCC, and Nebraska has already “implemented access reforms, rebalanced local rates, developed affordability benchmarks, and provides supplemental high-cost Telehealth and Lifeline support though its state universal service fund program.”  It should be noted, though, that Nebraska has been a much more active participant in state-level universal service initiatives and reforms than most states.

NPSC believes that state commissions “can be extremely valuable” to the FCC for the following responsibilities: identifying unserved and underserved areas, prioritizing areas for support, providing supplemental funding, and determining if support is being used efficiently and effectively.  Furthermore, “States have close knowledge of the extent to which broadband is being provided.  States are familiar with the obstacles impeding broadband deployment, [and]…many state commissions are familiar with the operating costs, investment levels, and revenue sources for the carriers.”  NPSC makes a valid point here, and states with a large number of RLECs and significant rural territory arguably have a big responsibility in terms of knowing specific geographic and demographic details as well as unique cost challenges for carriers as a result of local geographic and demographic particulars.  As a rural state with a large number of RLECs, NPSC probably has this point in mind when it recommends that states should determine provider eligibility for broadband support.

Although NPSC generally supports utilizing a forward-looking cost model to determine support in unserved areas, it is concerned that the ABC Plan’s CQBAT model has not been made available for analysis.  NPSC recommends that the FCC publish an open model as well as “results demonstrating support allocated to each state by census block or support area so that everyone may have the ability to quantify the level of universal service support which could be received by broadband services.”

Regarding ICC, NPSC agrees that “the Commission and states need to provide a sustainable framework which reduces the dependence upon an outdated Intercarrier compensation mechanism,” but it is skeptical of the ABC Plan’s methods to achieve this ICC reform goal.  First, NPSC believes that the ABC Plan could be modified “by providing state incentives to reform intrastate rates, increase artificially low local rates, and/or create universal service funds by requiring states to contribute a certain amount per line of recovery to offset intrastate rate reductions.”  Second, NPSC is not in favor of the proposed uniform $0.0007 rate, because “The ABC Plan proponents disregard the actual cost of providing access service and propose to establish a rate that appears to be non-compensatory for small carriers serving high-cost areas.”  NPSC calls the $0.0007 rate “an arbitrary rate for the convenience of the industry rather than one that reflects real costs.”  Third, NPSC believes the ABC Plan’s proposed Access Recovery Mechanism (ARM) is not addressed sufficiently, and the industry should provide more information about the impact on consumer rates.

Overall, NPSC provides a great deal of detailed information in response to many of the questions proposed in the FCC’s Public Notice.  NPSC clearly sees states as having an important role in the future of universal service and intercarrier compensation, contrary to the diminished state role that the ABC Plan parties are pushing.  NPSC provides some thoughtful comments about the need for state regulators for both consumers and carriers, and Nebraska is certainly a great example of a state that has worked very hard to implement its own universal service and intercarrier compensation reforms in the best interest of its constituents.  If adopted, it remains to be seen how the ABC Plan will impact those states like Nebraska which have been progressive in USF reform.  What do you think is the appropriate role of state regulators, and how can state and federal roles be balanced appropriately so that consumers in rural areas will have access to quality and affordable broadband?

NPSC’s full comments are available here.

ACA: ABC Plan Inconsistent with FCC’s Goals for USF/ICC Reform

Cable Association Argues ILEC Proposals are “Salvageable,” Provides Recommendations

Comments on the FCC’s Further Inquiry in the Universal Service-Intercarrier Compensation Transformation Proceeding were due on August 24. The American Cable Association (ACA) voiced its concerns with the price cap ILECs' ABC Plan and provided their recommendations about how the ABC Plan can be improved in order to meet the FCC’s goals of fiscally responsible and competitively neutral USF/ICC reform.  Although ACA was critical of the ABC Plan, it appeared to have a somewhat sympathetic position towards RLECs.  Cablecos were not involved in the industry negotiations that led to the ABC Plan and Consensus Framework with the RLEC Plan; therefore ACA warns the FCC that these proposals “are far from an industry consensus balancing diverse interests, a basic fact that the Commission should consider when determining whether these plans are in the public interest.”  

ACA believes that the ABC Plan is “deeply flawed: it would enable universal service funding to grow significantly and would tilt the competitive landscape in favor of the Price Cap incumbents.”  ACA argues that the ABC Plan is not competitively neutral, and it will not fix the myriad current problems with USF/ICC.  ACA states, “Rather than being ‘transformational,’ these proposals merely continue, if not exacerbate, current flaws in the universal service fund and intercarrier compensation regimes.  They also directly and materially harm ACA members, who provide telecommunications and broadband service in competition with these Price Cap carriers.”  Despite being peppered with problems, ACA is convinced that the ABC Plan’s proposals are “salvageable” with “targeted fixes.”

First of all, ACA believes that there needs to be a hard cap on the Connect America Fund (CAF) at the 2010 level.  Without a hard cap, ACA argues that the contributions burden on consumers will become unreasonable.  ACA further argues that the Consensus Framework proposal to limit the fund at $4.5b is actually “riddled with loopholes,” because it would allow rate-of-return carrier support to increase by $300m and the budget only remains in effect for 6 years.  As a result, “under the ABC and RLEC Plans, there is abundant opportunity for the fund to grow, which the Commission should not permit.”

ACA’s second recommendation is to distribute USF support in a “competitively neutral manner,” meaning reverse auctions.  ACA’s members believe that they could help extend broadband in rural areas with USF support, and they “are eager to see the Commission provide competitively neutral and efficient support for universal broadband so they can seek to serve these areas.”  ACA argues that the ABC Plan will effectively grant the price cap ILECs “a new government entitlement” to unserved areas, and the Rights of First Refusal proposal would especially give the ILECs an unfair competitive advantage.  ACA challenges the ILECs to accept reverse auctions, and “if they are in fact the most effective and efficient providers of broadband to unserved or underserved areas, the Price Cap incumbents would have nothing to fear from a competitively neutral distribution process.”

ACA’s next proposed fix for the ABC Plan’s flaws is a significantly limited access replacement mechanism (ARM), where carriers would only receive this support “where harm is demonstrable and severe.”  ACA ideally would like for there to be no ARM, but if the FCC decides to adopt a revenue recovery mechanism, then such funding should end after 3 years and the funding level should be less than 100% and reduced each year in the 3 year period.  ACA reasons that “transitional mechanisms like an ARM have a way of becoming permanent rights,” speculating that price cap carriers could ultimately end up collecting ARM support long past a reasonable timeframe.

When it comes to RLECs, ACA seemed understanding of the challenges that small rural companies will face if High Cost funding is reduced or eliminated: “These smaller providers are most reliant on current High-Cost funding to provide service to consumers and will suffer most if funding is reduced significantly and precipitously.  Further, these smaller telephone companies have generally demonstrated competence in providing service and have a deep commitment to their customers.”

ACA recommends that incumbent ETCs with less than 100,000 lines should have the option to continue receiving high cost support for 8 years, “so long as they agree to commit to provide broadband service in all their service areas,” at 4/1 Mbps initially and 16/4 Mbps within 6 years.  ACA’s recommendation to make funding for small companies somewhat contingent on broadband speeds provided is interesting, but the key here is that funding must be available, sufficient and predictable. Whether phasing out high-cost funding after 8 years will meet the sufficient and predictable principles, especially if large network investments must be made by year 6.

Overall, the ACA presented some interesting arguements, challenges to the proposed plans, and recommendations for USF reform.  There is growing opposition to the Consensus Framework by parties who were not directly involved with its development, but with $4.5b per year at stake, one can’t blame the dissenters for doing whatever they can to try to influence the FCC in this eleveth hour comment cycle.  Do you think the FCC will be accomodating to the parties who were not involved in the industry negotiations?

ACA’s full comments are available to read here.

$300m Mobility Fund is Arbitrary and Inadequate, Claims RTG

Rural Wireless Carriers Call RLEC-ILEC Consensus Framework for USF “Highly Flawed”

Comments on the FCC’s Further Inquiry in the Universal Service-Intercarrier Compensation Transformation Proceeding were due on August 24, and the rural wireless industry did not hold back any criticism of the wireline ILEC’s ABC Plan or the Consensus Framework negotiated by the Rural Associations and the ABC Plan participants. I have been looking forward to hearing the wireless response to the ABC Plan’s proposed $300m Advanced Mobility/Satellite Fund (AMF), and the Rural Telecommunications Group (RTG) comments did not disappoint. RTG slams the $300m amount for mobility funding as arbitrary, insufficient, inadequate, meager and measly; and they argue that the Consensus Framework “shows that the landline authors of the RLEC and ABC Plans are oblivious to the rapid changes taking place in the marketplace or have chosen to ignore them.”

Wireless carriers had no part in the industry negotiations that led to the Consensus Framework, which I think seems rather irresponsible given the significant role that wireless plays in the broadband market. Wireless broadband critics may argue that mobile broadband is not equal to wired broadband in terms of speed, service quality and capacity; but the market speaks clearly that wireless broadband is both a compliment and a substitute for wired broadband, depending on an individual consumer’s needs. Wireless service critiques aside, I can’t help but agree with RTG’s assertion that “it is a given that mobile wireless will play the most important role in the country’s broadband future and any order resulting from this proceeding should ensure the continued growth of wireless broadband.” The question then comes down to this: how much USF support should be dedicated specifically to wireless broadband, especially when the FCC is intent on keeping the size of the fund at or near the current level?

RTG unfortunately does not offer a specific amount of ideal funding, rather they argue that the funding should be based on actual costs, and “the size of the mobility fund would have to be substantially larger than $300 million and should reflect specific, ongoing support in order to spur investment and ensure the availability of existing wireless services and the expansion of mobile broadband networks.” I wonder, what constitutes a “substantially larger” mobility fund: $600m? $1b? More? There are a lot of costs involved in building and maintaining a wireless network (especially when spectrum acquisition is factored in), and I think we have all learned a thing or two about this from watching the recent drama with the AT&T/T-Mobile merger unfold. AT&T allegedly could build out 4G wireless to nearly the entire country for an additional $3.9b—equal to 13 x’s the proposed annual budget for the AMF.  I certainly do not expect the AMF to cover all costs to deploy wireless broadband in rural areas, but when put in perspective, $300m indeed seems like a pittance.

In addition to the size of the AMF, RTG is concerned about the disproportionate amount of money that wireless carriers pay into the USF while proposals on the table call for shifting support away from competitive ETCs. According to RTG, “Competitive ETCs would lose approximately 75% of their current support. In contrast, incumbent wireline carriers would lose only one third of their current support.” RTG is worried about the outcome of this proposal on rural wireless carriers, and “the consequence of applying such a large reduction of support to competitive ETCs will be a shrinking or elimination of many rural wireless networks.” RTG further argues for a transitional phase-out of CETC support of at least 10 years and a sufficient recovery mechanism to offset the lost funding.

RTG also raises concerns about including satellite support in the $300m AMF. They believe that funding for satellite broadband should come from the ILEC’s slice of the USF pie, because “satellite carriers provide a fixed Internet access service, and should not receive support from a fund proposed for ensuring that consumers enjoy the benefits of mobility.” RTG points out that the ABC Plan participants wish to partner with satellite providers and “rely on satellite in order to avoid having to serve the highest-cost areas.”

I have been highly critical of this particular large-carrier proposal in the past, and I agree with RTG that if wireline ILECs want to hand off the responsibility for serving especially remote areas to satellite providers, then the funding should come from the ILEC portion of USF. I think it is also important to look at the difference in market demand for mobile broadband and satellite broadband as an indicator that perhaps grouping these two services in the AMF is not reflective of actual consumer trends. I rarely hear of anyone clamoring for satellite broadband service, but there are stories every day about the dire need for improving mobile broadband. Expanding wireless broadband to 98% of America is a key component of the Obama Administration’s goals for universal broadband, and it is interestingly also a major point of debate in the AT&T/T-Mobile merger controversy.

RTG definitely covered some of the most contentious issues in this proceeding, and it will be interesting to see if, or how, the FCC responds to the wireless industry’s demands for a larger Mobility Fund. I imagine that RLECs would be concerned that a larger Mobility Fund could mean a smaller RLEC fund, but what do rural telecom providers who have a stake in both wireless and wireline think?

Read RTG’s comments here.

Western RLECs Support “Separate but Integrated” RLEC and ABC Plans

Western Associations Urge FCC to Adopt Consensus Framework and Strict Call Termination Rules

On August 24, 2011, the Western Associations (comprised of state telecom associations from California, Colorado, Idaho, Montana, Oregon, Washington and Wyoming) filed joint comments on the Further Inquiry in the Universal Service-Intercarrier Compensation Transformation Proceeding. In their comments, the Western Associations voiced support for the Rural Associations’ RLEC Plan for rate-of-return companies and presented some rather convincing arguments for strong call termination rules.

The Western Associations argued that the RLEC Plan is “a well thought out, integrated and comprehensive plan that represents significant compromise on the part of rural telecommunications companies across the nation,” and RLECs would experience less financial loss under the Consensus Framework of the RLEC Plan and ABC Plan than they would under the FCC’s initial USF/ICC NPRM framework. The Western Associations seem to understand that RLECs need to let go of some of the USF-enabled financial security of the past, for “the landscape is changing, and members of the Western Associations recognize the change must come” regarding USF and ICC. I found this notable, because the physical landscape of the states in the Western Associations is arguably the most expensive and challenging in the nation to build wired broadband, and I think this particular comment illustrates that these companies are being very realistic and reasonable about the future of USF.

The Western Associations emphasize that if the FCC adopts the Consensus Framework, two conditions must exist: the FCC should not pick and choose specific components of the RLEC Plan to adopt, and “it would not be appropriate to comingle aspects of the ABC Plan with the RLEC Plan and apply the comingled set of outcomes to the rural incumbent local exchange industry.” Although the ABC Plan was the result of broad industry negotiations including RLECs, it is really only applicable to large price cap carriers—the Western Associations note that “The ABC Plan and the RLEC Plan are carefully balanced to work together on separate, but parallel tracks taking into account very real differences between price cap and rate of return companies.”

The Western Associations provided some examples to illustrate how the RLEC Plan would result in revenue reductions, but not nearly as dramatic as the revenue reductions estimated under the FCC’s National Broadband Plan framework. Toledo Telephone Company calculated that it would see annual revenue reductions of $975,000 by 2015 under the FCC’s plan and annual revenue reductions of $275,000 under the RLEC Plan. I personally feel that $275,000 is still a substantial hit in revenue for a small company, but if it means the difference between defaulting on loans and laying off half the employees, then clearly the $275k hit might not the end of the world. The Western Associations agree, arguing, “while the RLEC Plan changes the support a rural company will receive, the change is manageable. The financial shocks of the NPRM proposals are not.”

I thought the Western Associations made an interesting point about the size of revenue reduction as a result of USF and ICC reform—they argued that companies should not lose more than 5% of their current USF support in a given year. They reason, “such a provision would also avoid losses in revenue that could negatively impact business plans, negatively affect the ability of a company to repay loans or have the negative consequence of preventing a company from obtaining new debt financing to pursue broadband deployment.” Although I agree with this reasoning in theory, I question how such a 5% annual reduction cap would work under the final rules. I also feel as though the FCC intends to make more significant USF reductions for companies that have been allegedly abusing the system, so a 5% reduction might not be sufficient to bring such companies in line. In other words, the bad actors might get a hall pass to continue receiving more USF support than needed.

The Western Associations took the opportunity to bring up an especially vexing ICC-related issue in their comments: least-cost routing abuse and call termination arbitrage. This is becoming a serious problem in rural areas, where calls are not being completed or experiencing quality problems to customers in rural areas, primarily RLEC customers. The Western Associations argue, “This abuse of telecommunications providers’ responsibility to complete calls is causing substantial economic and personal harm. Rural businesses are losing customers. Families, sometimes with sick loved ones, are unable to complete calls to one another.” They provided several convincing examples of this problem: a state patrol office in the Wahkiakum West Telephone Company service area repeatedly experiences calls not coming through; medical workers and pharmacies are not able to reach patients in rural areas; and a son of an elderly woman in the St. John Telephone Company service area could not reach his elderly mother, which resulted in emergency crews being sent to her home twice (for no reason). The Western Associations sternly state, “Someone in a rural community should not have to die to get this problem addressed.”

What is the solution to the call termination problem? The Western Associations urge the FCC to adopt the traffic signaling rules outlined by the Rural Associations, which “require complete population and end-to-end transport without alteration of call signaling records.” Furthermore, they encourage the FCC to equate call termination problems with call blocking, and issue severe penalties for companies who engage in this type of arbitrage. I personally feel that there is no technological excuse for any provider preventing calls from being completed in a rural area—it comes down to money and greed, and the problem has escalated to the point where regulatory intervention is now needed to correct a market failure.

Overall, I thought the Western Associations provided some convincing arguments and examples in favor of the RLEC Plan and Consensus Framework. The Western Associations appear to have a forward-looking and reasonable attitude towards USF/ICC reform, and they clearly are bracing for change and revenue reductions as a result of the reforms.

The Western Association’s comments are available here.

The End is Near on USF Reform Rulemaking

This Week: One Last Supersonic Comment Cycle before Final Rules

The FCC has made it very clear that it hopes to release the final rules for USF and ICC reform sometimes this fall—tentatively in October—but not before one final, and very aggressively-paced, comment-and-reply cycle on certain aspects of alternative proposals submitted by industry stakeholders. In preparation for the mountain of comments which will roll in Wednesday, August 24, I thought I would go back and review the August 3 Public Notice and see what some of the industry players have been saying in ex parte filings this month. Although the July 29 price cap carriers’ “ABC Plan” has been touted as an industry consensus with RLECs, there are definitely other industry groups who have questioned the actual level of consensus in this alternative plan. Therefore, I am excepting some hard-hitting comments from the groups excluded from the ABC Plan negotiations. I am also concerned about the August 31 deadline for reply comments, as the industry will only have one week to “speak now or forever hold its peace.”

The overall purpose of this final round of comments is basically to seek input on how three alternative plans (the Rural Association’s RLEC Plan, the Federal-State Joint Board’s proposal, and the 6 price cap carrier’s ABC Plan) “comport with the Commission’s articulated objectives and statutory requirements.” Beyond this, the FCC asks plenty of high-level questions about specific aspects of the different alternative plans, and they are looking for hard data to support arguments against or in favor of certain proposals. There is basically something for everyone in the telecom sector to respond to in the Public Notice, but I anticipate that RLEC comments will be primarily focused on the following questions and issues:

• Should the FCC eliminate the distinction between rural and non-rural carriers, if so, what are the policy implications?
• What role (if any) do states have in the revamped USF/ICC methodology?
• What is the appropriate reduced rate-of-return for RLECs? The Rural Associations and price cap carriers negotiated it down to 10% but the Joint Board recommended 8.5%.
• What impact will the Corporate Operations Expense Limitation Formula have on HCLS, ICLS and LSS recovery?
• Should support be reduced or eliminated in areas where an unsubsidized facilities-based competitor provides service to at least 95% of the households?
• Should USF support be calculated based on a total company earnings review to limit support levels, as suggested by the Joint Board for a Provider of Last Resort Fund?
• Should the highest-cost areas be served by satellite providers, supported by ViaSat’s proposed Competitive Technologies Fund utilizing reverse auctions and consumer vouchers?
• How will access rate recovery be ensured? The ABC Plan recommends a “rate benchmark” of $25-$30 as a ceiling on SLC and consumer rate increases, and the Joint Board suggests that states contribute $2 per line to help offset reduced access revenues.
• What is the “appropriate recovery mechanisms for ICC reform,” for RLECs, “that would maintain the predictable revenue stream associated with rate of return principles while also providing carriers with better incentives for efficient investment and operations?”
• What consumer benefits can be derived from reducing ICC rates to $0.0007?

In terms of responses to these questions, I predict that there will be some controversy in the diverging opinions among RLECs. With over 1,000 small companies spread across the country, I would never expect that each one would rubberstamp frameworks proposed by the associations. Therefore, I will be interested to see if differences are put aside in the comments, or if some RLEC groups will continue to hold their ground for other alternative proposals not identified specifically in the Public Notice.

We will have to wait until later this week for the “good stuff,” but a number of stakeholders have been expressing both concern and support for the ABC Plan and other frameworks this month in a flurry of ex parte filings and letters. So, I have grabbed a selection of quotes from various rural stakeholders’ recent filings to serve as a preview of what’s to come in the comments and replies.

• Consolidated Communications, which operates as both a price cap and rate-of-return carrier and was not involved in the ABC Plan negotiations, “has a number of unanswered questions regarding the proposal, as well as concerns about how it will impact smaller companies, especially those that have recently and voluntarily converted to price cap regulation.” Consolidated is concerned about the forward-looking cost model proposed in the ABC Plan and the $0.0007 target access rate, among other issues.
• The Iowa Association of Municipal Utilities described the success that Iowa municipal broadband providers have experienced in the state, and they urge the FCC “to establish a priority or preference for funding for municipal utilities in states such as Iowa that have taken a more active role in supporting broadband or have established a high-cost program.” IAMU supports the adoption of a “transition revenue recovery mechanism…that mirrors the recovery mechanism proposed for rate-of-return carriers and to adopt long-term reform proposals that ensure adequate recovery and also minimize the prospect of the municipal business model failure as a result of lost Intercarrier compensation reform.”  
• LARIAT, a rural WISP, argued that none of the three plans identified in the Public Notice “were fair to, much less favorable to, terrestrial fixed wireless Internet service providers (WISPs)—despite the fact that WISPs have proven to be the most cost-effective way of reaching unserved residents.” LARIAT is also concerned that the ABC Plan’s rights of first refusal proposal “grants a monopoly on USF/CAF funding to any incumbent which serves a mere 35% of the population covered by a wire center.”
• The Rural Broadband Alliance and Rural Independent Competitive Alliance are concerned that the ABC Plan is “insufficient,” and if used in conjunction with the RLEC Plan, the FCC will “[effectively prevent] rural rate-of-return carriers from having an opportunity to recover even their established lawful expenses without raising basic consumer rates to inordinate levels.” They conclude, “In contrast to the fact-based and actual cost-supported proposals of both the RBA and RICA, the proposed ABC Plan: dramatically reduces rate-of-return carrier cost recovery without any basis, places rural companies in financial jeopardy, stifling rural infrastructure investment and resulting in job loss in the areas of rural America served by the rural rate-of-return carriers; and rewards access users with millions of dollars of expense savings realized from diminished access rates, but provides for no commensurate benefits for rural consumers.”
• The Rural Cellular Association expressed “deep concerns” with the ABC Plan, claiming that “The ABC Plan purports to advance such principles [of competitive and technological neutrality] and to reflect an ‘industry consensus,’ but in fact it represents a self-serving ILEC proposal that would misallocate USF support, undermine competition, and deprive rural consumers of access to high-quality wireless services.” RCA calls the ABC Plan “deeply biased in favor of wireline carriers,” and claims that it “would put wireless providers at a decided disadvantage even in those relatively rare instances where the ILEC is ineligible to receive CAF support or refuses it.”

As illustrated by these examples, it appears as though “industry consensus” is indeed a stretch to describe the current climate in this final stage of the USF and ICC reform odyssey. Although I believe that RLECs and price cap carriers have come a long way in the last few months towards a consensus, it is clear that the favored plans at the FCC are not all-inclusive for every rural telecom stakeholder outside of wireline incumbents. Will everyone be able to resolve their differences in just a few short weeks, and will the FCC be able to accommodate every reasonable request in the final rules? I’m doubtful; but I am trying to remain optimistic that there will ultimately be more winners than losers in the end.

The FCC’s Public Notice is available to read here.