Entries in FCC (59)

Tuesday
Nov152011

Copps on USF/ICC Reform – Lawsuits, Waiver Requests “Frivolous”

In the Midst of USF Reform News Drought, Copps Speaks out at NARUC Annual Meeting

First we thought the rules would be available last week, but no such luck.  Now the rural telecom industry is bracing for a pre-Thanksgiving release of this epic document.  As the Connect America Fund R&O and FNPRM waiting game continues, it was actually exciting today to read FCC Commissioner Michael Copps’ Nov. 15 commentary from the National Association of Regulatory Utility Commissioners (NARUC) Annual Meeting in St. Louis, MO. He didn’t give a release date for the order, but he did make interesting remarks about some aspects of the order including the controversial role of states under the new regime. He also expressed mild contempt for parties who may be tempted to file lawsuits…and waivers.

Here are some notable quotes from Copps’ speech:

  • “The old saying is, ‘If it ain’t broke, don’t fix it.’ Well, you can’t make that argument here. The system was broken—and we were left with no real option short of a major overhaul.”
  • “Now I know that not everyone here is satisfied with everything the Commission did three weeks ago. Neither am I. But I think we both made a difference. Your input did greatly inform the Commission’s deliberations and its ultimate decisions—even though we had to make difficult choices that will change some legacy state responsibilities.”
  • “We incorporated numerous ideas from the state Joint Board members’ comments, such as imposing significant reporting requirements on USF recipients and requiring all reporting data to be jointly provided to the FCC and state Commissions.”
  • “States can perform many functions better than the federal government—and by ‘many functions’ I mean a whole lot of them. And I am looking for ways to expand the state role under the reformed system.”

In his remarks at the Oct. 27 FCC Open Meeting, Copps did emphasize that he wanted to expand the states’ role, in contrast to the ILECs’ ABC Plan recommendations. Going by the next comment from Copps, he appears to be taking a solid stance against the large ILECs’ pleas for reduced state involvement in the Connect America Fund:

  • “Nothing undermines this kind of substantive state role more than the few carriers who run to state legislatures lobbying for laws that effectively put state public service commissions out of the business of public interest oversight and consumer protection. That mocks the law. It mocks good telecommunications policy. And it mocks consumers.”

Copps continued stressing a “needs of many…” attitude, and warning that he will not take kindly to lawsuits and waivers filed after the release of the Order. It will be very interesting to see what kinds of hoops-on-fire the FCC will impose on the RLECs who are hoping to file a waiver. Copps asserted:

  • “I have no illusions about what perils await the new Order, but I do want to suggest how much better off we will be if our efforts going forward focus on working together to implement these new frameworks, and working constructively to make changes where they may be called for, rather than spending precious time that the country does not have on litigation or legislative end-runs that seek to advantage factional interests at the expense of the greater good.”
  • “I contest no one’s right to take us to court, of course, but America just doesn’t have time to waste watching warring parties duke it out in courts that themselves often disagree while millions of citizens go unserved.”
  • “I think another example of time wasted would be for carriers to file frivolous waiver requests to lock in legacy support that is not really needed to ensure that consumers have a landline voice provider. All that accomplishes is the diversion of precious resources away from carriers who really do need a safety net.”

With Copps movin’ on out of the FCC at the end of the year, it is hard to tell if the hard core opponents of the Order, such as the cable industry, will be deterred from going to court by Copps’ amusing comment, “I’m thinking about conferring my own special award on the first party who takes these decisions to court – I’m calling it the ‘Great Courthouse Cop-Out’ – and it might be accompanied by a stocking full of coal if it happens around the holidays.”

Although Copps’ speech lacked any shocking revelations about the Order, it was rather revealing about his attitude toward the states’ role, large ILECs, and his expectations for the aftermath of the release. He seems to be expecting lawsuits and waivers, but would likely prefer to see the industry just accept the changes and move forward. He emphasizes this by saying, “Let’s just get at it! America works best when people pull together toward an important goal.”

Copps didn’t indicate what constitutes a “frivolous” waiver; but it is nevertheless worrisome that the FCC may be crafting a waiver process that is unreasonably difficult for small rural companies with limited resources.  An unreasonably difficult and costly waiver process could be yet another way that the FCC signals its general disregard for small rural carriers. However, this is clearly speculation at this point since the details of the Order, including the waiver process, are still locked safely inside the FCC away from the critical eyes of the entire industry and public.

What did you think of Copps’ remarks about the Connect America Fund Order? Does a soon-to-be ex-Commissioner have enough sway to deter lawsuits and waivers?

The full text of his speech is available here.

Thursday
Nov102011

Net Neutrality Resolution for Disapproval – Disapproved by Senate, 52-46

Controversial Rules Soldier On, Better Have your Net Management Disclosures Ready!

Following a heated four-hour debate on Nov. 9, a Senate resolution to halt the FCC’s Net Neutrality rules (S.J. Res. 6) failed to achieve the necessary 51-vote majority on Thursday, Nov. 10… But not by much, indicating that either the rules still aren’t very well received on The Hill; or that this has just become a big, politically polarized wrangle more focused on D vs. R than on whether the rules are actually necessary and lawful. No matter what side of this debate you happen to be on, it may come as a relief that the rules will move next to a politically “neutral” court (see The ILEC Advisor: Net Neutrality Fight Intensifies – In Washington, Anyway).

S.J. Res. 6 was spearheaded by Sen. Kay Baily Hutchison (R-TX) who argued that “Over the past 20 years, the Internet has grown and flourished,” without any regulations. Senate Republicans commented yesterday in the debate about how Internet behemoths like Facebook, Twitter, Google and Apple all emerged from small start-ups to become multi-billion dollar corporations absent any codified Open Internet rules. It is hard to disagree on this point, but the Senate Democrats held that the rules are necessary to protect consumers from anti-competitive behavior by ISPs.

Both sides seem to argue that they are looking out for the best interests of the little guy, but Senators John Barrasso (R-WY) and Marco Rubio (R-FL) both specifically mentioned that the rules will be harmful to small rural providers. Senator Barrasso referenced rural Wyoming WISP LARIAT, whose proprietor Brett Glass is very concerned that “the red tape will hurt his ability to deploy new service to currently underserved or unserved areas.” Senator Rubio added, “One small Internet provider stated that the imposition of network management rules will hinder its ability to obtain investment capital and deploy new services in unserved areas. The regulations would also increase costs and they would hamper innovation, which would only further discourage outside investment in the company.”

RLEC associations have generally remained mum on the Net Neutrality debate, albeit commenting that small rural carriers “cannot bear the costs of complying with overly burdensome or vaguely defined requirements” (The ILEC Advisor: Brace Yourself for the Net Neutrality Rules). While scanning reactions to the Senate debate and vote, I noticed that the RLEC associations were absent from the declarations of “Victory!” by left-leaning consumer groups and proclamations of “We’ll get ‘em in court!” by conservatives.  One way or the other, the fight still isn’t over yet. The question is—does it even matter to RLECs now that the bills from the consultants and lawyers for creating disclosure documents are probably in the mail at this very moment?

The rules become effective on November 20. Hopefully no rural telcos were hedging their bets on S.J. Res. 6 being approved and thus procrastinated on drafting their network management policy disclosure statements.

I got a sneak peek at the Network Management Practices Policy Disclosure for Walnut Communications which will be distributed to Internet service customers. The 5-page document basically explains that the company complies with the Open Internet rules, and “utilizes reasonable network management practices…[to prevent] its customers from being subjected to the negative effects of spam, viruses, security attacks, network congestion, and other risks that threaten to degrade service…consistent with industry standards.” The disclosure goes on to explain specific practices that the company uses, or refrains from using, for the purposes of congestion management, application-specific behavior, device attachment and network security. The disclosure describes services offered by the company and actual speeds and latencies that consumers can expect to experience based on Ookla Speedtest software.

Overall, it is a fairly straight-forward and non-threatening document, but it is hard to tell if the FCC will continue to impose additional disclosure requirements in the future now that the door has been opened, so to speak.

It certainly will be interesting to see if the Net Neutrality rules end up specifically preventing small rural providers from accessing capital to innovate and expand their networks, as Senator Rubio warned. It will also be interesting to see the “average customer” response to the disclosure policies. What do you think about the Net Neutrality rules—are they necessary, a necessary evil, or just plain evil?

Tuesday
Nov082011

The National Broadband Map: "Far from Perfect"

Study Depicts Data Limitations of Map, Implications on Policy… Like USF Reform, Perhaps?

Mentioning the National Broadband Map (NBM) is likely to bring up negative reactions in certain telecom circles, but few have gone beyond complaining to actually identifying the map’s specific data limitations and making recommendations for improving the map in future updates. Tony H. Grubesic from Drexel University’s College of Information Science and Technology gave a fascinating presentation at the September 23-25, 2011 Telecom Policy Research Conference in Arlington VA about the inaccuracies of the map; and his paper, “The U.S. National Broadband Map: Data Limitations and Implications,” was released last week.

Since attending the conference, I have been looking forward to reading Grubesic’s paper…and thinking about how some of the inaccuracies he identified will impact rural providers in the USF Order.  Grubesic’s paper does not argue that the NBM is a complete failure; rather he believes that it is a good start and a definite improvement over previous methods of disseminating broadband data (like the Form 477 database). However, “there are a number of issues associated with data integrity, spatial uncertainty and accuracy within the NBM that need to be addressed.”

It is concerning that the FCC plans to use NBM data for Connect America Fund-related decisions, and that the FCC has not really acknowledged that the map depicts an incomplete and overestimated visualization of broadband deployment—it is not out of line to anticipate that this could create problems down the road. Grubesic explains, “Although Steven Rosenberg, the chief data officer with the FCC’s Wireline Competition Bureau touts the NBM as the ‘largest and most detailed map of broadband ever created,’ it is far from perfect.”

Grubesic’s paper covers several interesting—and alarming—aspects of the NBM. His analysis primarily looks at wireline broadband service for Columbus, Ohio and nearby suburb Dublin. First, he discusses the strengths and weaknesses of using Census blocks. He evaluates the differences in the map’s data between large (greater than 2 square miles) and small (less than 2 square miles) Census blocks. Data was collected differently for large and small blocks, although the map makes no specific differentiation between them. As a result, “One outstanding problem…is whether or not the reported presence of a broadband provider in a block is truly indicative of service availability.”

For large Census blocks, “providers collected and submitted address data or road segment data where broadband service was available.” With this methodology, “providers can be overly generous in reporting their broadband coverage, resulting in a drastic overestimation of broadband availability and provider choice for many regions.” Grubesic provides an example of xDSL service, which is distance-limited to about 18,000 feet or less and is rarely deployed to 100 percent of a wirecenter. The following map illustrates a Census block, highlighted in red, which lies outside of any “best case” xDSL service range. However, “the NBM reports 18 address points or street segments within this block receive asymmetric digital subscriber line (ADSL) service from AT&T of Ohio.” Is it magic, or a case of overestimated service? Grubesic concludes that in the Columbus metro area, “empirical analysis suggests that 8,829 people reported to have xDSL service in large blocks likely do not—representing a 46% overestimate.”

For comparison, here is what the NMB shows for xDSL coverage in the Columbus, OH metro area, and wired broadband coverage for Dublin, OH. Unfortunately the blue xDSL blob overshadows the geographic indicators. The map itself is not particularly easy to navigate or even look at, but as Grubesic has pointed out, it is far from perfect!

The next issue discussed in this paper may be more relatable to RLECs- empty census blocks being reported as served, even if there is no logical reason to have a wired broadband connection to the middle of a lake or an interstate on/off ramp. I have definitely picked up on overestimated wireless coverage in remote areas where I know that barely any wireless service exists (or people, for that matter), but apparently this is not just a wireless problem. Just for fun, here is what the map says about a location in rural Iowa, 8 miles from a major highway and 6 miles from the nearest town: Verizon Wireless, 3-6 Mbps. I’ve been at this location, and I can barely make a call without wandering around the yard searching for a signal.  

Grubesic explains why completely empty blocks—with no residential population or businesses—are occasionally listed as served: “a provider may claim to serve a Census block with 0 population because they can provide service within 7 to 10 days.” Even though the reporting methodology allegedly has ways to prevent this problem, the map itself makes no differentiation between empty and populated Census blocks, or between actually served and "could be served in 7 to 10 days" Census blocks. Grubesic again refers to Dublin, OH, where “nearly 46% of the completely empty blocks are reported as having broadband availability…In other words, the NBM is reporting that 45 Census blocks which are completely devoid of residential population, businesses or shopping have broadband services available.” If you apply this logic to the entire US, the map may be reporting thousands of empty blocks with broadband—those are some lucky lakes, cows and highway intersections!

What is really interesting is that despite a clear overestimation of broadband service reported on the NBM, provider participation in the mapping process varied greatly from state to state—in Virginia, only 27% of providers participated and 14 states had participation rates under 60%. It makes me wonder how overestimated the map would be if a 100% participation rate was achieved! Furthermore, the map uses 2000 Census information, and in 2000 there were 8,262,363 Census blocks. Well, in 2010 there were 11,155,486 Census blocks—a 35% increase. Grubesic recommends that the map should be updated to reflect 2010 Census information, and “if the NTIA and FCC are truly committed to maintaining a current and realistic snapshot of broadband availability in the United States, the use of data from 2000 hinders these efforts.”

What do these data inaccuracies mean for rural broadband policy, specifically the Connect America Fund? If the FCC plans to rely on data from the map to help determine who does (and who does not) receive funding, there are sure to be problems. If the map is not updated and corrected, the FCC will essentially be using a faulty premise to make significant funding decisions. It is indeed a scary thought.

What flaws have you discovered in the NBM? How do you think the map can be improved so that the FCC can utilize the data to make informed decisions?

Grubesic’s paper is available to read here.

Thursday
Oct272011

FCC Approves Still-Unseen USF/ICC Reform Order

Executive Summary Released Minus the 493 Pages that Matter

If you were expecting the unveiling of all the juicy details of the USF/ICC-Connect America Fund Order at the FCC’s Open Meeting today, then you, like me, were probably disappointed after the 3 hour meeting that consisted primarily of the Commissioners thanking each other and their staff for all the hard work in drafting this monumental order. That’s not to say that there wasn’t any good information, but many questions will definitely remain until the allegedly 500+ page R&O and FNPRM is released.

A packed house anxiously sat through the first item on the agenda, “Modernizing Television Broadcaster Requirements to Make Information Available to the Public,” which was approved unanimously. After what seemed like an eternal wait, Wireline Competition Bureau Chief Sharon Gillett opened the discussion on USF/ICC Reform. She delivered what I felt was some of the most important information revealed in the entire meeting: the amount of funding that the various industry sectors will receive.

According to Gillett, Rate of Return carriers will receive $2b, price cap ILECs will receive $1.8b, there will be a one-time $300m Mobility Fund plus an additional annual $500m for mobile broadband, $100m for Tribal Lands mobility, and $100m per year for the super-remote households. The funding methodology for this $100m Dedicated Remote Areas Fund will be determined via future proceedings.

According to the Executive Summary that was released during the time it took me to take a cab from the FCC to my house after the meeting concluded; the FCC will establish “a firm and comprehensive budget for the high-cost programs within USF. The annual funding target is set at no more than $4.5 billion over the next six years, the same level as the high-cost program for Fiscal Year 2011, with an automatic review trigger if the budget is threatened to be exceeded.” After 6 years, the budget may be revisited. This appears to be a fairly reasonable compromise between the eternal hard cap supported by some (like the cable industry), and no cap at all supported by others.

The new Connect America Fund (CAF) will “replace all existing high-cost support mechanisms,” and “will rely on incentive-based, market-driven policies, including competitive bidding, to distribute universal service funds as efficiently and effectively as possible.” CAF support for price cap companies will be introduced in two phases. The first phase will include freezing existing support but also infusing an additional $300m to “expediently” deploy broadband to unserved price cap areas. According to the Executive Summary, “Any carrier electing to receive the additional support will be required to deploy broadband and offer service that satisfies our new public interest obligations to an unserved location for every $775 in incremental support. Specifically, carriers that elect to receive this additional support must provide broadband with actual speeds of at least 4 Mbps downstream and 1 Mbps upstream, with latency suitable for real-time applications…” This doesn’t sound much like the “Rights of First Refusal” proposal in the ABC Plan, and it does sound like the FCC is going to put a heavy emphasis on public interest obligations. The second phase of price cap CAF support “will use a combination of a forward-looking broadband cost model and competitive bidding.”

Moving on, it sounds like mobile broadband providers will get a much better deal than originally anticipated—at one point they were looking at a single $300m influx only, and now it looks like they are getting the $300m plus $500m per year. I anticipate that some wireless carriers will still say that this isn’t enough (some associations have asked for $1b per year, and even parity with wireline carriers). One interesting aspect of the Mobility Fund is that “the winners will be required to deploy 4G service within three years, or 3G service within two years, accelerating the migration to 4G.” $100m of the annual $500m will go specifically for Tribal areas, which Commissioner Copps emphasized is especially important. He said that some tribal areas have single-digit broadband adoption levels, which is a “national disgrace.” Overall, this Mobility Fund barely resembles the Mobility Fund NPRM that was released a year ago which satisfied very few stakeholders, especially rural wireless carriers.

What about the RLECs? I didn’t hear anything in the meeting that specifically signaled the immediate death of the RLEC industry which was a relief, but as almost everyone has been saying lately, “The devil is in the details.” Supposedly, the Order will “recognize the unique nature” of small rural carriers and attempt to maintain some of the stability of the current system while reasonably transitioning to CAF. According to the Executive Summary, “Rate-of-return carriers receiving legacy universal service support, or CAF support to offset lost ICC revenues, must offer broadband service meeting initial CAF requirements, with actual speeds of at least 4 Mbps downstream and 1 Mbps upstream, upon their customers’ reasonable request.” Again, the FCC is pushing hard for public interest obligations.

RLECs can likely expect limitations on capital and operating expenses starting July 1, 2012; less support for “carriers that maintain artificially low end-user voice rates;” phase-out of the Safety Net Additive and of support in areas that overlap with an unsubsidized competitor; and a cap on per-line support of $250 per month “with a gradual phase-down to that cap over a three-year period commencing July 1, 2012.” Most of these changes have been anticipated, but it sounds like the FCC will seek comment on some specific aspects of RLEC funding reductions, including the 11.25% rate-of-return, in an FNPRM.

Finally, Intercarrier Compensation: details seemed especially slim on this topic at the Open Meeting, but were explained somewhat better in the Executive Summary. The FCC will “take immediate action to curtail wasteful arbitrage practices,” specifically access stimulation and phantom traffic.  This might be good news, but the bad news comes next: “We adopt a uniform national bill-and-keep framework as the ultimate end state for all telecommunications traffic exchanged with an LEC.” In the give-and-take spirit of this Order, the FCC does “adopt a transitional recovery mechanism to mitigate the effect of reduced intercarrier compensation on carriers and facilitate continued investment in broadband infrastructure, while providing greater certainty and predictability going forward than the status quo.” I will be interested to see the gap between how much revenue RLECs stand to lose with bill-and-keep and how much the FCC is willing to give back via the recovery mechanism. LECs can also charge an Access Recovery Charge (ARC) limited at $0.50 per month for residential/small business and $1.00 per month for multi-line businesses.

At the Open Meeting, the Commissioners all relentlessly praised one another and their staff on all the hard work, and they all seemed very proud of themselves for finally releasing—and approving—this order (despite the fact that nobody has seen it yet). Copps said that today the Commission is “making telecommunications history,” and Genachowski called this a “once in a generation” achievement that will facilitate “new vistas of digital opportunity.” I will continue to hold my applause until I read the order and learn more about how the RLEC industry will be specifically impacted by the sweeping changes. What do you think—is there enough information to determine if this is a good deal for the RLEC industry? What was the biggest surprise, and the biggest disappointment, in today’s Open Meeting and USF/ICC Reform Executive Summary?

The full 7-page text of the Executive Summary is available here.

Monday
Oct242011

Rural Panelists Discuss Call Termination Problems – Causes, Effects, Solutions

A Perfect Storm of Economic Incentives and Technology Brews Arbitrage

USF/ICC reform may be the dominant rural telecom regulatory topic at the moment, but rural representatives from across the country took the initiative to come to the FCC this week and present information about rural call termination problems at a public Workshop. The purpose of the October 18 Workshop, which also included panelists from large ILECs and CLECs (but noticeably no pure VoIP providers), was to identify why these problems are occurring, what impact the problems have on companies and consumers, and how the problems can be solved with regulation, standards, enforcement or best practices.

This Workshop was the result of strong efforts by the Rural Associations and several state Commissions, who have pleaded with the FCC to address rural call termination issues throughout the year (The ILEC Advisor:  FCC Finally Gets the Message about Call Termination Problems). Commissioner Mignon Clyburn opened the Workshop by acknowledging that rural call termination problems are indeed troubling for public safety, health care, businesses and people just trying to communicate by phone. She sympathetically said, “I want my call to go through, and I know you want yours to go through as well.”

The first panel tackled the causes, scope and impact of the problems. Panelists included Robert Gnapp (NECA), Fritz Hendricks (Onvoy Voice Services), Denny Law (Golden West Telecommunications), Dave Lewis (ANPI/Zone Telecom), Kim Meola (AT&T), Dale Merten (Toledo Telephone) and Tami Spocogee (PAETEC). Gnapp summed up the situation by saying, “This is the most troubling, time consuming and frustrating problem [rural providers] have ever had to deal with.”  Hendricks added that it “vilifies” RLECs, even though he has “yet to find a rural carrier” who was at technologically at fault.

Lewis and Hendricks provided insightful comments about how the relationship between economic incentives and technology creates ripe opportunities for arbitrage. Lewis reasoned that as telephone rates increase, companies lose business, and they may look for ways to evade economic challenges and “change the cost dynamics.” Unfortunately, it costs more to terminate calls in rural areas, so companies facing economic pressure might refuse to terminate calls to high-cost areas in an effort to save money. Hendricks explained that “technology provides a vehicle for arbitrage, but economics create the incentive.”

In terms of the causes of call termination problems, many are quick to blame Least Cost Routing (LCR) technologies (and the carriers who utilize LCR). However, several panelists pointed out that LCR has been around for at least a decade, whereas these problems have dramatically increased in the last couple of years. Spocogee stated that LCR isn’t the problem if it is done correctly. Another possible troublemaker called “SIM Box Fraud” was also identified.

There was no shortage of examples of the impact on consumers and rural economies. Merten described a rural community in the Pacific Northwest with an economy based largely on tourism and charter fishing. He claimed that this rural community has been “absolutely devastated” as a result of calls not being completed to the charter fishing businesses. Merten’s company has invested significant resources and time to track and identify the source of call termination problems. In Law’s South Dakota service area, hundreds of automated calls from a school district failed to reach parents to notify them of school closings or other important news. Other panelists and audience members cited specific difficulties experienced by rural health care providers and sheriff’s offices. Gnapp explained that there have been at least 10,000 documented complaints, but the complaints are only a “small subset” of the real number of failed calls to rural areas, which could be in the millions or tens of millions.

The second panel addressed possible resolutions. Panelists included Scott Booth (Verizon), Jill Canfield (NTCA), Martin Corso (TDS Telecommunications Corp.), Penn Pfautz (AT&T) and Rick Ratliff (Sprint). The primary means to address call termination problems appear to be through regulatory intervention, enforcement, industry standards or best practices; but the panelists differed as to which solution is most appropriate. Considering how diverse the sources and causes of call termination problems are, a combination of resolution mechanisms may be the best course of action going forward.

One of the biggest challenges is actually figuring out the source of the problem—without this key information, it is indeed difficult to remedy the situation. A “carrier list” of contacts at IXCs who will help rural carriers address and resolve problems has been created, but Canfield commented that the carrier list is only helpful if the customer complains, the originating IXC can be identified, and the originating IXC is on the list. She also said that it places the burden on the consumer, and Corso later added that business customers are especially reluctant to contact their customers and then tell them to contact their originating carriers—it is definitely a lot of trouble for all parties afflicted.

I thought it was interesting that the large ILEC panelists all seemed sympathetic and dedicated to working with the RLECs on these issues, but the ILECs have the capacity to invest millions of dollars and dedicated staff specifically to monitor and track down non-compliant parties. For example, Ratliff mentioned that Sprint has an email address for call termination complaints and “several staff” who just monitor complaints and “go after bad actors.” Buying expensive monitoring technology and hiring several full time employees to address call termination problems is a luxury that few—if any—small RLECs can afford right now, yet the number of complaints can reach dozens per day. I would imagine some RLECs could keep a full time employee busy by just addressing call termination complaints.

Differences aside, Pfautz insisted that AT&T “[makes] money by completing calls, not by dropping them on the floor.” Booth added that Verizon wants calls to be completed so consumers have a “positive experience;” and Sprint and AT&T are both dedicated to shutting down arbitragers and ending relationships with non-compliant intermediaries.

Will the pledges to take a hard line on arbitrage be sufficient, or does the FCC need to intervene? The rural panelists at the Workshop seemed to agree that the upcoming ICC reforms will not be a solution in themselves, and the ideal course of action may be a combination of best practices, monitoring, reporting and enforcement. Canfield stated that best practices are a good start, but not everyone will follow them so long as there are financial incentives not to; Corso added that monitoring alone is not an appropriate solution. Canfield also argued that the FCC has the authority and ability to issue forfeitures under the current call blocking rules, and these problems could be treated as de facto call blocking.

Overall, this Workshop was very interesting and definitely an important first step in getting the FCC’s attention and moving forward towards consensus and resolution. A number of states are also conducting inquiries on this issue; so hopefully industry, government and consumer stakeholders will begin experimenting with and implementing remedies.

Meanwhile, it would be great if the “bad actors” would take note that RLECs are not going to sit back and continue to let these problems reach an epidemic scale. The fact that a number of panelist and a large portion of the audience in attendance at the FCC came from all over the country really spoke to the gravity of this matter. Indeed the significance and somberness should not be underestimated—as an audience member who traveled to DC from rural Missouri said, “One death because of this issue is not worth the billions of dollars saved.”

The full video recording of the Workshop is available here.

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