Category Archives: Washington Watch

Members of the Alaska Rural Coalition spoke with Wireline Competition Bureau staff on April 3, 2014, to discuss removal of the Quantile Regression Analysis Benchmarks and future calculation of high-cost support without these benchmarks. They also discussed: modification of the Safety Net Additive, further guidance on what constitutes a reasonable request for broadband in a rural area, phase-in of an increase in the local service rate floor, possible revisions to broadband performance criteria, Mobility Fund issues and phasedown of CETC support in Tribal areas, consideration of offering high-cost support to broadband-only lines, and competitive broadband trials designed to provide specific support for middle mile infrastructure in Alaska and other Tribal areas.

ACA, et al. Discuss CAF Phase II, Broadband Experiments

ACA, MCTV, Troy Cablevision and Armstrong met with Wireline Competition Bureau staff on April 3, 2014, to discuss CAF Phase II and the rural broadband experiments. They said build-outs to more remote areas can be further justified where there are anchor customers requiring substantial capacity. They are interested in building new infrastructure to reach unserved locations and in participating in the CAF Phase II competitive bidding process, but said their participation will depend on whether the Commission addresses existing barriers to entry, such as the ETC designation process. They asserted that from the perspective of non-incumbent providers, the state process to become an ETC is often time-consuming, burdensome, and may involve unnecessary obligations.

CenturyLink Discusses Network Engineering Analysis of CAF Phase II Build Cost

CenturyLink met with Jon Sallet, FCC Acting General Counsel, on April 3, 2014, to discuss its Preliminary Network Engineering Analysis of CAF Phase II Build Cost for CenturyLink, filed on March 31, 2014. CenturyLink urged the FCC to consider, among other things: making partially-served high-cost census blocks eligible for CAF II; enhancing the operation of the substitution rule; freezing the extremely high-cost benchmark and allowing the high-cost benchmark to adjust to meet the CAF II budget; granting waivers of the build-out obligations to sparsely-populated sites and isolated routes; and relaxing the build-out obligation.

IP Transition

Public Knowledge, NCLC Challenge Confidential Portions of AT&T Proposed IP Trials

Public Knowledge and National Consumer Law Center filed a Challenge on April 8, 2014, to the portions of AT&T’s proposed IP transition trials that AT&T designated as confidential. They asserted the information designated as confidential by AT&T pertains to the basic operation of the proposed trials, is critical to public discourse, and does not fall within the disclosure exemption mandate of the Freedom of Information Act as it does not qualify as either trade secrets or confidential commercial information. They seek to have AT&T remove the confidential designations and resubmit this information, noting AT&T has already publicly disclosed the confidential information to TR Daily.

Merger

FCC Announces Comcast and Time Warner Cable Filed Application to Merge

The FCC issued a Public Notice on April 8, 2014, announcing Comcast and Time Warner Cable filed applications seeking Commission approval to the transfer of control of the licenses and authorizations held by Time Warner Cable and its wholly owned and controlled subsidiaries to Comcast. The FCC noted the applications have not yet been accepted for filing, and when they are, it will issue a separate public notice setting forth a pleading schedule.

Universal Service

Comments Filed on E-rate Modernization

In addition to comments listed in a previous edition of Washington Watch, comments were filed on April 7, 2014, on issues raised in the E-rate Modernization NPRM, including how best to focus E-rate funds on high-capacity broadband and whether and how the FCC should begin to phase down or phase out support for traditional voice services in order to focus more funding on broadband. WTA said E-rate reform should fully utilize RLECs’ existing infrastructure investments in the most efficient manner, and the use of E-rate funding to build duplicative last-mile fiber connections should be prohibited. Verizon said the FCC should adopt a sensible approach to distributing internal connections support and enact certain proposals that would streamline administration of the E-rate program. It also said if the Commission elects to phase out support for voice services, it should do so on a gradual basis. ITTA said the FCC should continue to support traditional voice services as a priority one service through the E-rate program and that forcing schools and libraries to adopt VoIP service in order to continue receiving E-rate funding would require unnecessary additional expenditures that many schools and libraries cannot afford. Replies are due April 21. Public Notice | List of all comments filed

Other comments filed by:

ALA

ASCA

Bright House Networks

Brocade Communications Systems

California Dept. of Education

California Emerging Technologies Fund

CenturyLink

City of Boston

City of Chicago

Clear Rate Communications

Comcast

Consortium for School Networking

Ednetics

Education Coalition

EducationSuperHighway

Fatbeam

Free Library of Philadelphia

Miami-Dade County Public Schools

Partnership for 21^st Century Skills

SouthernLinc Wireless

State of Nebraska

State of Nebraska, Office of the CIO

Telepak Networks

The Quilt

Tribal Telecommunications Companies and Tribal Organizations

ULC

West Virginia Dept. of Education

Wisconsin Dept. of Public Instruction

Zayo Group

Funds for Learning, Miami-Dade County Schools Discuss E-rate Modernization

Funds for Learning and the Miami-Dade County Public Schools met with Chairman Wheeler’s staff and the FCC’s Director of Digital Learning on April 3, 2014, to discuss the school district’s ongoing deployment of technology-related educational resources. They discussed the need for predictable, regular and on-going internal connections funding, and described their use of caching hardware and networking management tools to reduce network bandwidth requirements. They encouraged the Commission to reduce the restrictions on the types of networking equipment eligible for E-rate support, and expressed concern about the potential “1-in-5” rule for internal connections support. They also met with Commissioner Rosenworcel and her Legal Advisor to discuss the same issues.

Comments Due May 8 on CenturyLink Request for Review of USAC Decision

The Wireline Competition Bureau released a Public Notice on April 8, 2014, seeking comment on CenturyLink’s Request for Review of a USAC decision on certain audit findings of CenturyLink’s USF contributions reported on its 2012 FCC Form 499-A. Comments are due May 8; replies due May 13.

LNP

Neustar Offers Suggestions on LNP Administrator Selection Process

Neustar filed a letter on April 8, 2014, to address the procedures the Commission should follow in evaluating the recommendation of the NANC for selection of the LNP Administrator for the contract period scheduled to begin in July 2015. Neustar suggested the Commission apply a notice-and-comment process that frames the relevant procedural and substantive issues. It also suggested the Commission place in the record all documents related to the selection process to date and not delegate the selection of the next LNPA to the Wireline Competition Bureau.

Today’s News Clips

Google Fiber targets 34 more cities as potential FTTH recipients

By Sean Buckley

Fierce Telecom

Google Fiber (Nasdaq: GOOG) plans to explore the idea of bringing its 1 Gbps fiber to the home (FTTH) service to an additional 34 cities across 9 U.S. metro areas, a move the provider decided to make in the wake of the experience it gained through deployments in Kansas City, Austin and Provo.

“We’ve long believed that the Internet’s next chapter will be built on gigabit speeds, so it’s fantastic to see this momentum,” wrote Milo Medin, VP for Google Access Services, in a blog post. “And now that we’ve learned a lot from our Google Fiber projects in Kansas City, Austin and Provo, we want to help build more ultra-fast networks. So we’ve invited cities in nine metro areas around the U.S.–34 cities altogether–to work with us to explore what it would take to bring them Google Fiber.”

http://www.fiercetelecom.com/story/google-fiber-targets-34-more-cities-potential-ftth-recipients/2014-02-19

Los Angeles pursues city-wide broadband plan

By Sean Buckley

Fierce Telecom

Los Angeles may be home to movie stars and rock stars, but according to residents, it lacks enough high-speed broadband options. City officials have launched an initiative to bring service to all of its residents, reports the Los Angeles Daily News.

Led by Councilman Bob Blumenfield, the city has put forth a request for information (RFI) focused on bringing broadband connectivity via a wireless or wireline connection to all of the city’s households and businesses. Interested parties have seven weeks to respond to the RFI.

http://www.fiercetelecom.com/story/los-angeles-pursues-city-wide-broadband-plan/2014-04-08?utm_medium=nl&utm_source=internal

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 04/08/2014

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April 8, 2014

Back Issues

Contents

USF/ICC Transformation Order

CoBank Discusses Quantile Regression Model

USTelecom, Price Cap Carriers Discuss Transformation Order FNPRM on Circulation

ACS Discusses Connect America Cost Model

IP Transition

Vermont DPS Files Comments Expressing Concerns with AT&T Proposed IP Trials

COMPTEL, et al. Express Concern With AT&T Proposed IP Transition Trial

ATIS Proposes Common Reference Points for Numbering Testbed Requirements

AICC Discusses Alarm Industry IP Transition Concerns

Utilities Discuss Rural Broadband Experiments

Call Completion

TelePacific Discusses Rural Call Completion Reporting Rules

Universal Service

Comments Filed on E-rate Modernization

GCI Discusses E-rate Modernization

ACA, Shentel, Metrocast Discuss E-rate Modernization

Funds for Learning Provides Additional Information on E-rate Reform Proposal

Texas Health Information Network Collaborative Discusses Rural Healthcare Pilot

Disclosure Requirements

Public Knowledge Discusses Party Interest Disclosure Requirement

TCPA

FCC Seeks Comment on TextMe Petition for Clarification

Today’s News Clips

TDS’ Stimulus Program Will Breathe Broadband Life Into 27,000 Rural Households

USF/ICC Transformation Order

CoBank Discusses Quantile Regression Model

CoBank met with Chairman Wheeler’s Legal Advisor on April 3, 2014, to explain that a few of its borrowers were under threat of severe financial distress that potentially jeopardized their ability to repay their loans under the Quantile Regression Model regime. CoBank expressed its gratitude with Chairman Wheeler’s decision to revise and eliminate the use of this model. CoBank also met with Legal Advisors to Commissioners Pai, Clyburn, O’Rielly, and Rosenworcel, and Wireline Competition Bureau staff to discuss the same issues. CoBank also filed its annual report and its report card on the Transformation Order.

USTelecom, Price Cap Carriers Discuss Transformation Order FNPRM on Circulation

USTelecom, Verizon, CenturyLink, AT&T, Windstream, and Frontier met with Chairman Wheeler’s Legal Advisor on April 3, 2014, to discuss the FNPRM on universal service high-cost issues currently on circulation and scheduled to be considered at the Commission’s April 23, 2014 Open Meeting. They expressed concern about a potential increase in the broadband speed requirement for CAF Phase II without concurrent changes in other terms for carriers electing cost-model based support, and discussed whether other elements of CAF II, such as the definition of areas served by unsubsidized broadband providers, should change based on a revised broadband speed requirement. They also discussed the relationship between the E-rate program and the high-cost program.

ACS Discusses Connect America Cost Model

ACS met with Commissioners Rosenworcel and O’Rielly and their staff and Wireline Competition Bureau staff on April 3-4, 2014, to discuss CAF Phase II. ACS said as noted in its March 28, 2014 letter, the Connect America Cost Model version 4.1 grossly miscalculates the costs of serving Alaska. ACS asserted the model allocates far too little high-cost support for remote areas and for Alaska price cap areas on the whole. ACS asks the FCC to: modify the model to incorporate Alaska-specific costs; absent adequate funding, to designate unserved off-road locations as eligible for the Remote Areas Fund and exempt from areas that must be served under CAF II; or permit the ILEC the option of accepting the amount of frozen support it currently receives in CAF Phase I on a continuing basis, for the duration of CAF Phase II.

IP Transition

Vermont DPS Files Comments Expressing Concerns with AT&T Proposed IP Trials

In addition to comments listed in previous editions of Washington Watch, the Vermont DPS filed comments on April 7, 2014, on AT&T’s proposed IP transition trials, as called for by the IP Transition Order. VDPS is concerned that AT&T U-Verse voice service would not be subject to common carrier or state regulation and that U-Verse voice service consumers will have no choice of long distance providers. Vermont opposes AT&T’s assertion that as a VoIP provider it is not providing common carrier services, and noted the FCC has refused to define VoIP-based services as information services. List of all comments filed

COMPTEL, et al. Express Concern With AT&T Proposed IP Transition Trial

COMPTEL, AARP, the National Consumer Law Center, Public Knowledge, et al. met with Commissioners Pai and Rosenworcel and their Legal Advisors on April 2, 2014, to suggest the FCC only approve AT&T’s two proposed trials if the following issues are adequately addressed: the availability, affordability, and substitutability of the services for residential, business, and wholesale consumers; the limitations of the proposed trial locations, as neither reflects the diverse issues the nation will face during the technology transitions; the replacement products for TDM services, as AT&T indicates many are still TBD; the adequacy of the information AT&T plans to collect and whether a third party should be designated to collect and report on the relevant information; and the submission of some of the information about AT&T’s trials confidentially, including the schedule for the trials.

ATIS Proposes Common Reference Points for Numbering Testbed Requirements

ATIS filed a letter on April 4, 2014, suggesting six common reference points be created during the development of technical requirements for the IP numbering testbeds. ATIS proposes that, for each testbed, the stakeholders involved in the testbed should define specific functions and relate these to a common reference model so that there is a clear understanding of what functions are provided and where. ATIS said it is volunteering to lead an activity open to all numbering testbed(s) participants that would define the above items and produce documented technical requirements.

AICC Discusses Alarm Industry IP Transition Concerns

The Alarm Industry Communications Committee and the Carmen Group met with Commissioners Clyburn, O’Rielly, Rosenworcel, and Pai and their staff on April 3, 2014, to discuss IP transition concerns impacting the alarm industry. AICC urged the FCC to ensure a smooth transition for the alarm industry sector and that compliance with the National Fire Alarm and Signaling Code be required.

Utilities Discuss Rural Broadband Experiments

The Utilities Telecom Council and its Rural Broadband Council, Midwest Energy Cooperative, Dykema Gossett, ONI Consulting, and BARC Electric Cooperative met with Office of Strategic Planning and Policy Analysis staff on April 2, 2014, to discuss utility participation in rural broadband experiments and their access to support from the CAF to provide broadband to unserved and underserved areas.

Call Completion

TelePacific Discusses Rural Call Completion Reporting Rules

TelePacific Telecommunications met with Wireline Competition Bureau and Enforcement Bureau staff on April 2, 2014, to discuss rules and reporting of call completion rates, and expressed support for Comptel’s Petition for Reconsideration of the 100,000 subscriber line de minimis threshold. TelePacific discussed the limitations of originating and terminating switch records and the difficulties of using SS7 signaling data, and claimed it was not designed for recording call completion or information needed for billing purposes. TelePacific also said switch upgrades typically cost tens of thousands of dollars per switch and the business has no need for such information other than to comply with these reporting obligations.

Universal Service

Comments Filed on E-rate Modernization

Comments were filed on April 7, 2014, on issues raised in the E-rate Modernization NPRM, including how best to focus E-rate funds on high-capacity broadband and whether and how the FCC should begin to phase down or phase out support for traditional voice services to focus more funding on broadband. NTCA said improving the quality of broadband connections both to and within schools and libraries will require a carefully coordinated effort that avoids consuming the E-rate budget for any one objective at the expense of the other. NTCA said such an effort also requires rejection of one-size-fits-all solutions that would fail to direct limited E-rate funds to where they are needed the most. USTelecom said the FCC should identify and target support to the narrow range of schools and libraries that are unable to obtain adequate (or any) high-speed broadband connections, and establish an assessment process to identify the schools with the most acute needs for broadband upgrades. AT&T said the FCC should: prioritize funding for broadband deployment and internal connections that support broadband connectivity, include all aspects of the E-rate process in its streamlining review, further streamline the disbursement process, phase out funding for voice services, fund demonstration projects if applicants demonstrate a need, and support off-campus mobile learning. Replies are due April 21. Public Notice

Other comments filed by:

ACS

Alliance for Excellent Education

Council of the Great City Schools

Cox Communications

CVIN dba Vast Networks

EdLiNC

Education Networks of America

E-rate Provider Services

GCI

Hewlett-Packard

Illinois Dept of Central Management Services

Kentucky Department for Library and Archives

Mississippi Educational Technology Leaders Association

Missouri Research and Education Network

NCTA
NNTRC

Ohio E-rate Consortium

School Superintendents Association and Association of Educational Service Agencies

Sprint

Sunesys

TIA

GCI Discusses E-rate Modernization

GCI met with Wireline Competition Bureau staff on April 2, 2014, to provide the FCC with information on Alaska schools other than in the Anchorage, Fairbanks, Juneau, Matanuska-Susitna and Kenai districts, which it said shows how bandwidth usage has expanded in rural schools, driven by mobile data, video conferencing, Internet access and cloud applications. GCI said because much of Alaska is not located on fiber backbones, it is critical to maintain support for middle-mile transport necessary to connect rural, remote communities to the fiber backbones and, ultimately, the Internet. It suggested, therefore, the Commission should adopt GCI’s Priority 0 proposal to ensure that E-rate reforms do not end up making it harder for schools in remote rural areas to reach the Internet.

ACA, Shentel, Metrocast Discuss E-rate Modernization

The American Cable Association, Shentel and Metrocast met with Wireline Competition Bureau staff on April 3, 2014, to discuss E-rate modernization. Shentel said most schools and libraries served by Shentel have migrated from lower speed broadband Internet access services and dedicated T-1 services to much higher speed Ethernet services, which are provided over all-fiber connections. Metrocast said while the cost of providing connectivity to an individual school or library can differ greatly because so many factors are in play, the provision of Wi-Fi within an institution largely turns on coverage and throughput.

Funds for Learning Provides Additional Information on E-rate Reform Proposal

Funds for Learning met with Office of Strategic Planning and Policy Analysis and Wireline Competition Bureau staff on April 2, 2014, to discuss E-rate modernization and clarify its proposal to establish annual, per-applicant E-rate budgets. FFL said under its proposal, small numbers of applicants would no longer be able to take advantage of the E-rate program’s blank check feature to walk away with a disproportionate amount of funding, leaving other applicants underfunded or without any funding at all. FFL said, instead, all applicants would receive funding every year, small schools would be protected, and remote rural schools would receive additional funding to accommodate their unique needs.

Texas Health Information Network Collaborative Discusses Rural Healthcare Pilot

The Texas Health Information Network Collaborative met with Wireline Competition Bureau staff on April 3, 2014, to discuss the challenges it is overcoming as it implements its Rural Health Care pilot program network in Texas. It also expressed support for the Commission’s interest in funding healthcare-focused rural broadband experiments.

Disclosure Requirements

Public Knowledge Discusses Party Interest Disclosure Requirement

Public Knowledge spoke with Jonathan Sallet, General Counsel, on April 2, 2014, to express support for a general party interest disclosure requirement and discussed the mechanics of how 501(c)(3) organizations keep books and report income. PK suggested, for 501(c)(3)s, parties filing should certify they did not receive financial support for the specific filing or representation made. PK said if they did receive a direct contribution for the specific filing or presentation, then they should disclose the source, and said the FCC should find a mechanism to use the IRS Form 990s filed by every 501(c)(3) to capture information regarding long-term relationships between 501(c)(3)s and other interested parties.

TCPA

FCC Seeks Comment on TextMe Petition for Clarification

The Consumer & Governmental Affairs Bureau issued a Public Notice on April 7, 2014, seeking comment on TextMe’s Petition requesting the FCC clarify certain aspects of the Telephone Consumer Protection Act. TextMe asked the FCC to clarify the meaning of the term “capacity” as used in the TCPA’s definition of “automatic telephone dialing system,” and to clarify that users of TextMe’s service, instead of TextMe itself, make or send calls or text messages for purposes of the TCPA. In the alternative, TextMe requests the FCC to clarify that third party consent obtained through an intermediary satisfies the TCPA’s prior express consent requirement for calls and texts to wireless numbers. Comments are due May 7; replies due May 22.

Today’s News Clips

TDS’ stimulus program will breathe broadband life into 27,000 rural households

By Sean Buckley

Fierce Telecom

Out of all of the telcos that applied for the U.S. Department of Agriculture’s (USDA) Rural Utilities Service (RUS) grants as part of the ARRA broadband stimulus funding program in 2009 and 2010, TDS Telecom (NYSE: TDS) was the most aggressive. After applying for over 46 grants, it received a total of 42 in the second round.

In addition to the initial group of 39 grants it won, TDS Telecom secured funding for three additional projects in Colorado, Florida/Georgia, and Oklahoma. The projects for TDS’ Delta County Tele-Comm, Quincy Telephone Company, and Oklahoma Communications subsidiaries, will serve 540, 430, and 900 residents, respectively.

http://www.fiercetelecom.com/special-reports/tds-stimulus-program-will-breathe-broadband-life-27000-rural-households

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 04/07/2014

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April 7, 2014

Back Issues

Contents

USF/ICC Transformation Order

NTCA Discusses High-Cost, E-rate Universal Service Updates

TDS Discusses Petition for Limited Waiver of Part 51 Rule

Wireline Competition Bureau Submits Cost Model Documentation Into Record

Call Completion

Vonage Notifies FCC of Call Ringing Solution Status

Open Internet

Internet Association Files Comments on Open Internet

CPNI

FCC Seeks PRA Comments on CPNI Information Collection

USF/ICC Transformation Order

NTCA Discusses High Cost, E-rate Universal Service Updates

NTCA met with Commissioner O’Rielly’s Legal Advisor on April 2, 2014, to discuss updates to the high-cost and e-rate universal service programs. NTCA said its discussion was consistent with those stated in prior filings on: the context and legal framework within which rural broadband experiments should be undertaken; adoption of an updated, broadband-focused support mechanism tailored for the operations of smaller providers that serve exclusively rural areas; and the structural framework for use of E-rate resources to support sufficient and affordable capacity and services at individual schools and libraries.

TDS Discusses Petition for Limited Waiver of Part 51 Rule

TDS met with the Legal Advisors to Chairman Wheeler and Commissioners Rosenworcel, Pai, Clyburn and O’Rielly on April 1-2, 2014, to ask the FCC to grant its Petition for Waiver to permit it to include within its 2011 Base Period Revenues unpaid amounts billed to Halo Wireless for intrastate usage during Fiscal Year 2011, thereby rendering those amounts eligible for recovery pursuant to the FCC’s eligible recovery mechanism. TDS asks that its Petition be granted in a way that enables it to include in its eligible recovery baseline the full amount it was unable to collect from Halo Wireless, pursuant to the process set forth in footnote 1745 of the Transformation Order due to Halo’s bankruptcy filing.

Wireline Competition Bureau Submits Cost Model Documentation Into Record

The Wireline Competition Bureau filed a letter on April 4, 2014, to formally submit into the record the model documentation for the Connect America Cost Model version 4.1. The Bureau said it also may consider as part of this proceeding Leonardo R. Giacchino and Jonathan Lesser, Principles of Utility Corporate Finance, 2011 at pp. 217-44.

Call Completion

Vonage Notifies FCC of Call Ringing Solution Status

Vonage filed a letter on April 3, 2014, in compliance with the Order granting Vonage’s second waiver request of the ring signaling rule adopted in the Rural Call Completion Order. Vonage noted it recently filed a Petition requesting an additional 15-day extension, until April 17, 2014, to comply with the ring signaling rule. Vonage said it expects to activate the necessary software at its remaining two call processing centers by April 17, 2014, and intends to notify the FCC of its compliance by April 18, 2014.

Open Internet

Internet Association Files Comments on Open Internet

In addition to comments listed in previous editions of Washington Watch, the Internet Association filed comments on April 3, 2014, in response to the Public Notice which asked for input on how the Commission should proceed on the Open Internet rules in light of the D.C. Circuit Court’s guidance in the Verizon v. FCC Opinion. The Internet Association supports a transparency rule that requires Internet access providers to provide information regarding their network management practices, performance, and the commercial terms of their broadband services, and supports an enforceable rule that precludes Internet access providers from blocking or degrading access to content. List of all comments filed

CPNI

FCC Seeks PRA Comments on CPNI Information Collection

The FCC issued a Notice in the Federal Register on April 7, 2014, seeking Paperwork Reduction Act comments on an extension of currently approved collection related to Customer Proprietary Network Information. PRA comments are due June 6.

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 04/04/2014

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April 4, 2014

Back Issues

Contents

USF/ICC Transformation Order

Wireline Competition Bureau Files Rate Floor Data

FCC Seeks PRA Comments on Information Collection for Forms 507, 508, 509

Call Completion

NTCA Supports Congressional Rural Call Completion Resolution

Vonage Seeks More Time to Comply With Call Ringing Rules

Universal Service

FCC Launches Lifeline Database

FCC Releases Final Lifeline Biennial Audit Plan

Urban Libraries Council, SHLB Coalition Discuss E-rate

Foundation for Excellence in Education Discusses E-rate Issues

Open Internet

NetAccess Futures Files Comments on Open Internet

Retransmission Consent

WTA Discusses Retransmission Consent Concerns

Pole Attachments

Florida Power and Light Discusses Pole Attachment Issues

FCC Reporting

Senate Committee to Hold Hearing on FCC Reporting Act

Today’s News Clips

EU Parliament Votes to End Roaming, Protect ‘Net Neutrality’

USF/ICC Transformation Order

Wireline Competition Bureau Files Rate Floor Data

The Wireline Competition Bureau submitted a letter into the record on April 3, 2014, containing staff analysis showing aggregated information regarding the number of

ETC lines that receive High-Cost Loop Support or frozen High-Cost Model Support that had rates below the $14 rate floor as of July 1, 2013 and January 2, 2014, and the monthly reductions in HCLS or High-Cost Model Support as a result of implementation of the rate floor as of January 2, 2014. The Bureau also provided information on the number of lines, study areas, and states at or below $5 per line as of January 2, 2014.

FCC Seeks PRA Comments on Information Collection for Forms 507, 508, 509

The FCC issued a Notice in the Federal Register on April 4, 2014, seeking Paperwork Reduction Act comments on its proposal to add FCC Forms 507, 508 and 509, Competitive Carrier Line Count Report and Self-Certification as a Rural Carrier, currently approved under collection 3060–0972, to the information collection under 3060–0986. There are no changes to the currently approved FCC Forms 507, 508 and 509. There are also no changes to the FCC Forms 525 or 481, which are part of this information collection. The FCC noted it has received OMB approval for most of the information collections required by the Transformation Order, and at a later date will submit additional revisions for OMB review to address other reforms adopted in the Order (e.g., 47 CFR 54.313(a)(11)). Comments are due May 5.

Call Completion

NTCA Supports Congressional Rural Call Completion Resolution

NTCA issued a press release on April 3, 2014, announcing its support for the resolution introduced by Representatives Bob Latta (R-Ohio) and Peter Welch (D-Vt.), Co-Chairmen of the Rural Telecommunications Working Group, outlining steps the FCC can take to improve telephone service in rural areas. NTCA said it is “hopeful that this resolution, in conjunction with comparable measures introduced in the Senate, can help put a stop to rural consumers’ ongoing inability to receive phone calls.”

Vonage Seeks More Time to Comply With Call Ringing Rule

Vonage filed a Second Petition for Further Extension of Time and Limited Waiver on April 2, 2014, requesting an additional 15-day extension, until April 17, 2014, to comply with the ring signaling rule adopted in the Rural Call Completion Order. It said due to the discovery of additional problems in the software designed to deploy Vonage’s solution, the company has recently determined that it will be unable to comply fully with the rule by the April 2, 2014 deadline pursuant to the Order granting Vonage’s second waiver request. It also requests a 15-day extension of time, until April 18, 2014, to comply with the requirement to file a letter notifying the FCC that it has come into compliance with the rule.

Universal Service

FCC Launches Lifeline Database

The FCC issued a News Release on April 3, 2014, announcing that the National Lifeline Accountability Database is now operational. The Commission said now that the database is on-line, no Lifeline provider can enroll a new subscriber without first confirming that the subscriber’s household does not already receive Lifeline service.

FCC Releases Final Lifeline Biennial Audit Plan

The Wireline Competition Bureau released a Public Notice on April 3, 2014, announcing release of the final Lifeline Biennial Audit Plan. ETCs receiving $5 million or more from the low-income program, as determined on a holding company basis taking into account all operating companies and affiliates, for calendar year 2013 will be subject to the first round of biennial audits. Changes were also made to the plan, including the audit period, submission of attestation reports, confidentiality of ETCs’ information, and subscriber data for testing.

Urban Libraries Council, SHLB Coalition Discuss E-rate

The Urban Libraries Council and SHLB Coalition met with Office of Managing Director, Wireline Competition Bureau and Office of Strategic Planning and Policy staff on March 31, 2014, to provide an overview of the challenges and the importance of E-rate funding to libraries. They said the FCC should define a desired state of library access for high-speed circuits to each library building and internal wireless broadband connectivity. They also said if the FCC believes it lacks sufficient information regarding the current state of library connectivity, it could request that libraries provide this data in a statistically significant manner. They also discussed a number of pilot programs that the FCC should consider funding.

Foundation for Excellence in Education Discusses E-rate Issues

The Foundation for Excellence in Education met with Wireline Competition Bureau and Office of Strategic Planning and Policy Analysis staff on April 1, 2014, to discuss E-rate issues. It discussed the importance of providing as much certainty and flexibility for schools as possible as the FCC explores a potential recalibration of the priority system to allocate a set amount of E-rate funds for LANs and Wi-Fi networks, and how consortia could serve as a means to negotiate better pricing as well as aggregating demand to help commercial providers justify building out fiber networks to underserved areas.

Open Internet

NetAccess Futures Files Comments on Open Internet

In addition to comments listed in previous editions of Washington Watch, NetAccess Futures filed comments on April 2, 2014, in response to the Public Notice, which asked for input on how the Commission should proceed on the Open Internet rules in light of the D.C. Circuit Court’s guidance in the Verizon v. FCC Opinion. NetAccess does not agree with those commenters suggesting reclassification of broadband Internet providers under Title II of the Act, and claimed that reclassification would be difficult to accomplish, attract negative attention from Congress, and would result in a number of forbearance proceedings. List of all comments filed

Retransmission Consent

WTA Discusses Retransmission Consent Concerns

WTA met with Commissioner Pai’s Legal Advisor on April 1, 2014, to discuss multi-channel video distribution issues. WTA said the following FCC actions would help alleviate problems rural providers face: requiring the pricing and terms of all retransmission consent agreements and satellite channel agreements to be transparent and available for review; requiring uniform per-subscriber prices for agreements, or limiting the amount by which a content provider’s highest per-subscriber price can exceed its lowest; adopting additional requirements or best practices for good faith negotiation of agreements; and adopting streamlined procedures that permit MVPDs to change their Designated Market Area in response to customers.

Pole Attachments

Florida Power and Light Discusses Pole Attachment Issues

Florida Power and Light met with Wireline Competition Bureau staff on March 31, 2014,

to discuss what it says is the failure of ILECs to report and demonstrate the consumer benefits flowing from the lower pole attachment rates in the 2011 Pole Attachment Order. FPL said it is considering filing a petition for declaratory ruling requesting that the Commission examine whether the ILECs have delivered the specific consumer benefits, as promised.

FCC Reporting

Senate Committee to Hold Hearing on FCC Reporting Act

The U.S. Senate Committee on Commerce, Science, and Transportation announced it will hold an executive session on April 9, 2014, to consider among other things, S. 1379, the Federal Communications Commission Consolidated Reporting Act of 2013. The bill proposes to amend the Communications Act of 1934 to consolidate the FCC’s reporting obligations in order to improve congressional oversight and reduce reporting burdens.

Today’s News Clips

EU Parliament votes to end roaming, protect ‘net neutrality’

By Foo Yun Chee

Reuters

The European Parliament voted to end mobile phone roaming fees by 2016 and barred telecoms operators from prioritizing some Internet traffic over others, moves that will cheer Europe’s consumers and frustrate industry seeking new forms of revenue.

In a session in Brussels, lawmakers backed telecom reform legislation that will phase out roaming fees across the 28-country European Union by December 2015, bolster consumer protections on mobile and broadband contracts and seek to make the sale of mobile licenses more uniform across Europe.

http://www.reuters.com/article/2014/04/03/us-eu-telecomunications-parliament-idUSBREA320S520140403

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 04/03/2014

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April 3, 2014

Back Issues

Contents

Open Meeting

FCC Issues Tentative Agenda for April Open Meeting

Call Completion

Representatives Introduce Rural Call Completion Resolution

ZipDX Offers Suggestions on Addressing Call Completion Problems

USF/ICC Transformation Order

Pioneer Discusses Local Rate Floor Issues

FCC Releases Connect America Cost Model v. 4.1 Methodology

IP Transition

COMPTEL Proposes Framework to Address Issues From TDM-to-IP Transition

AARP Discusses Transparency, Confidentiality Concerns in IP Transition

Open Meeting

FCC Issues Tentative Agenda for April Open Meeting

The FCC issued the tentative agenda for its April 23, 2014 Open Meeting. The FCC will consider a Report and Order, Declaratory Ruling, Order, Memorandum Opinion and Order, and Seventh Order on Reconsideration that continue the implementation of the reforms adopted in the USF/ICC Transformation Order to modernize universal service. An accompanying FNPRM proposes measures to update and further implement the framework adopted by the FCC in 2011. The FCC will also consider an FNPRM that would implement an innovative three-tier spectrum sharing approach to make up to 150 megahertz of spectrum available for wireless broadband use in the 3550-3700 MHz band.

Call Completion

Representatives Introduce Rural Call Completion Resolution

Representatives Bob Latta (R-Ohio) and Peter Welch (D-Vt.), Co-Chairmen of the Rural Telecommunications Working Group, announced on April 2, 2014, that they introduced a bipartisan resolution outlining steps the FCC can take to improve telephone service in rural areas. They said one of the main causes of poor rural call completion stems from retail long-distance providers’ increasing use of third parties to deliver calls to rural areas at reduced rates. The resolution states no entity should unreasonably discriminate against telephone users in these areas, and encouraged the Commission to aggressively pursue entities that violate FCC call completion rules. WTA expressed support for the resolution.

ZipDX Offers Suggestions on Addressing Call Completion Problems

ZipDX filed a letter on April 2, 2014, to offer suggestions on how to address call completion problems. ZipDX said the service providers (“intermediaries”) it claims are the most liable for rural call completion issues are not participating in this proceeding, and are unlikely to engage in good-faith compliance with the new rules. ZipDX claimed the data and reports mandated in this rulemaking will not be actionable, and said industry expenditures incurred to comply with these rules would be better used on capabilities that would result in resolution of real rural call completion issues.

USF/ICC Transformation Order

Pioneer Discusses Local Rate Floor Issues

Pioneer Communications spoke with Commissioner Pai’s Legal Advisor on April 1, 2014, to discuss its reply comments on the Associations’ Petition asking the Bureau to extend the deadline for compliance with the 2014 local service rate floor from July 1, 2014, to January 2, 2015. Pioneer discussed the administrative and regulatory barriers to raising local rates in Kansas as compared to other states, and reiterated its position that there should be an indefinite freeze of the FCC’s rate floor until the FCC and the states can reconcile state-based rate floor disparities.

FCC Releases Connect America Cost Model v. 4.1 Methodology

The FCC released the methodology for the CAF Phase II Connect America Cost Model version 4.1 on April 2, 2014. The CACM estimates the cost to provide voice and broadband-capable network connections to all locations in the country, and provides specific details at the Census Block level, for both the forward-looking cost to deploy and operate carrier grade VoIP service and a broadband-capable network and universal service support levels for that voice and broadband-capable network.

IP Transition

COMPTEL Proposes Framework to Address Issues From TDM-to-IP Transition

COMPTEL filed a letter on April 2, 2014, proposing a managerial framework to address issues arising from the TDM-to-IP transition that affect competitive carriers serving retail business customers. COMPTEL asserted the absence of a technology-neutral framework for wholesale access to key inputs from ILECs threatens competition, innovation and investment in business broadband. COMPTEL also claimed the FCC should adopt reform of its wholesale policies to promote robust competition in the business broadband market during and after the IP Transition, and asserted the FCC should make clear ILECs have an enforceable duty to provide VoIP interconnection under Section 251(c)(2).

AARP Discusses Transparency, Confidentiality Concerns in IP Transition

The AARP filed a letter notifying that it participated in the Consumer Advisory Committee meeting on March 28, 2014. AARP said at the meeting it asked a question about transparency and the confidential status of information associated with the IP Transition, and expressed concerns about the confidential nature of the consumer timelines in AT&T’s proposal.

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 04/02/2014

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April 2, 2014

Back Issues

Contents

IP Transition

COMPTEL, et al. Express Concern With AT&T Proposed IP Transition Trial

ATIS Proposes Numbering Testbed Requirements

JSI Responds to Neustar Numbering Testbed Proposal

Subsentio Discusses Applicability of CALEA to IP Transition Initiative

Separations

Comments Due April 16 on Separations Freeze Extension and RoR Carrier Waivers Proposal

Joint Board State Members Support Extension of Jurisdictional Separations Freeze

USF/ICC Transformation Order

CenturyLink Files Preliminary Network Engineering Analysis of CAF Phase II Build Cost

Lumos Telephone Files Supplement to Previous Waiver Request

Universal Service

Madison Telephone, JSI, NTCA Discuss Petition Seeking Safety Valve Support

Ad Hoc Coalition Seeks Changes to USF Rules

FCC Consumer Advisory Committee Adopts E-rate Recommendations

Telecommunications Access Policy Division Submits Bureau of Indian Education Documents

USAC Files 2013 Annual Report

Broadband

Carriers to Offer WBIAS on a Common-Carriage Non-Tariffed Basis

Internet

Commissioner O’Rielly Discusses Internet Governance at FCBA

FCC Process Reform

Samsung Files Comments on FCC Process Reform Report

IP Transition

COMPTEL, et al. Express Concern With AT&T Proposed IP Transition Trial

COMPTEL, AARP, National Consumer Law Center, Public Knowledge, et al. met with Office of General Counsel, Wireline Competition Bureau, Office of Strategic Planning and Policy, Public Safety and Homeland Security Bureau, Wireless Telecommunications Bureau, and Office of Engineering and Technology staff on March 27, 2014, to express concerns with AT&T’s proposed technology transition trials. They asserted neither of the wire centers reflects the diverse issues the nation will face during the technology transitions, and said the trials should also encompass urban areas. They said while AT&T stresses the voluntary nature of these trials for wholesale customers, they asserted it is important that AT&T actually propose replacement arrangements, test them and prove their viability prior to discontinuance of established services. They also said the information AT&T plans to collect is inadequate, and suggested that a third party should be designated to collect and report on the relevant information.

ATIS Proposes Numbering Testbed Requirements

ATIS, on behalf of its Industry Numbering Committee, filed a letter on March 31, 2014, to say it has been working on high-level functional requirements for the numbering testbed and is sharing them to ensure the industry’s alignment with Commission expectations. ATIS shared eleven high-level functional requirements that it believes must be preserved in the testbed environment, emphasizing the need for security in the various processes.

JSI Responds to Neustar Numbering Testbed Proposal

JSI filed a letter on March 31, 2014, in response to discussions held at the FCC’s Numbering Testbed Workshop on March 25, 2014, regarding Neustar’s recommendation to grant consumers direct access to telephone number assignments. JSI said it believes consumers should not be provided direct access to telephone numbers unless consumers also assume the burden and responsibilities associated with the number assignment. JSI believes that service providers should remain responsible for assigning numbers to their customers.

Subsentio Discusses Applicability of CALEA to IP Transition Initiative

Subsentio met with Public Safety and Homeland Security Bureau staff on March 31, 2014, to discuss the applicability of the Communications Assistance for Law Enforcement Act in the IP transition. It said any implementation of CALEA in the IP transition should fulfill all three purposes of CALEA, which are to provide lawful intercept technical capabilities to law enforcement, permit communication service providers the freedom to launch new services and service features without hindrance or delay, and protect security and privacy. They also suggested ways the Commission could raise awareness of CALEA and monitor the progress of the mandate consistent with these goals.

Separations

Comments Due April 16 on Separations Freeze Extension and RoR Carrier Waivers Proposal

The FCC published in the Federal Register on April 2, 2014, a Further Notice of Proposed Rulemaking proposing to extend the freeze of jurisdictional separations category relationships and cost allocation factors in Part 36 for three years, through June 30, 2017. The FCC also proposed to direct the Wireline Competition Bureau to open a filing window for rate-of-return ILECs to file waiver requests to unfreeze their jurisdictional separations category relationships. The FCC said such petitions must contain the necessary documentation to support a waiver, and to prevent over-recovery the Bureau will require carriers to file certain revised 2011 rate-of-return Base Period Revenue data reflecting changes in category relationships the carrier makes pursuant to any relief granted. Comments are due April 16; replies due April 23.

Joint Board State Members Support Extension of Jurisdictional Separations Freeze

John D. Burke, State Chair of the Federal-State Joint Board on Jurisdictional Separations, sent a letter to Commissioner Rosenworcel on March 31, 2014, expressing the support of the state members of the Joint Board on the Wireline Competition Bureau’s plans to address two pending Petitions for Waiver that would allow frozen rate-of-return LECs to reset/unfreeze their category relationships during a specified filing period of time. Chairman Burke indicated the state members are prepared to support an extension of the freeze through June 30, 2017, based on their understanding that the states retain the ability to adopt any reasonable allocation of costs between intrastate and interstate jurisdictions for state ratemaking purposes.

USF/ICC Transformation Order

CenturyLink Files Preliminary Network Engineering Analysis of CAF Phase II Build Cost

CenturyLink filed a Preliminary Network Engineering Analysis of CAF Phase II Build Cost for CenturyLink on March 31, 2014. CenturyLink said these results raise several points the Bureau should consider as it proceeds with implementation of the CAF Phase II, including adoption of the Connect America Cost Model that will be used to allocate CAF II support. CenturyLink said its analysis found: the newly eligible CAF II locations are extremely high-cost, both in terms of low-density and isolation from other network facilities; there are economic challenges to sharing network cost in these remote areas and the funding period may be too short; and the cost problems appear to be associated with the recently-added extremely high-cost census blocks.

Lumos Telephone Files Supplement to Previous Waiver Request

JSI, on behalf of Lumos Telephone and Lumos Telephone of Botetourt, filed a supplement on March 31, 2014, at the request of Commission staff, to their November 6, 2013 Petition for Limited Waiver of section 51.917(b)(7)(ii), 2011 Rate of Return Carrier Base Period Revenue. The supplement provides support information in the form of redacted Tariff Review Plan spreadsheets for both companies for 2012 and 2013 filings pertaining to fiscal years 2011 and 2012 respectively.

Universal Service

Madison Telephone, JSI, NTCA Discuss Petition Seeking Safety Valve Support

Madison Telephone, JSI, and NTCA met with Legal Advisors to Commissioners O’Rielly,

Rosenworcel and Pai, and Wireline Competition Bureau staff on March 27-28, 2014, to discuss Madison’s Petition for Waiver of sections 54.305 and 36.612 rules so it can receive Safety Valve Support for acquisition of two exchanges in 2001. Madison seeks to resubmit its SVS eligibility and election notification to establish a calendar index year of Jan 1 – Dec. 31, 2002, to align the index year with the data that has already been submitted. Madison asserted in its Petition that if clarity and instructions regarding the data requirements had been provided when it sought guidance on the filing requirements, it would have received over $2 million in SVS between 2005 and 2013.

Ad Hoc Coalition Seeks Changes to USF Rules

The Ad Hoc Coalition of International Telecommunications Companies filed Comments and, alternatively, a Petition for Rulemaking on April 1, 2014, asking the FCC to open a rulemaking proceeding to adopt new rules relating to administration of the USF by USAC. The Coalition asked the FCC to adopt rules to allow telecommunications carriers to request guidance from USAC on an anonymous and hypothetical basis, establish a five-year look-back period for all USAC audits and contribution obligations, and create amnesty and voluntary disclosure agreement programs for well-intentioned telecommunications and interconnected VoIP service providers who may not be in compliance with the Commission’s USF regulations.

FCC Consumer Advisory Committee Adopts E-rate Recommendations

The FCC’s Consumer Advisory Committee released recommendations on April 1, 2014, on improving the E-rate program. The CAC recommended the FCC include certain priorities in its efforts to improve the program and promote more efficient use of E-rate funds, including making broadband connectivity to schools and libraries a priority, distributing funds that promote fair and equitable service and adequate speeds, and consider whether Priority 2 funding adequately addresses the unique needs of rural communities. The CAC also said data collection and monitoring of the E-rate program should be improved, an electronic filing system should be implemented, and the application and disbursement processes should be simplified.

Telecommunications Access Policy Division Submits Bureau of Indian Education Documents

The Wireline Competition Bureau’s Telecommunications Access Policy Division filed a letter on April 1, 2014, submitting for the record Bureau of Indian Education documents on E-rate it received from the Department of Interior. The documents included: BIE Schools’ E-rate Success Stories, BIE Schools’ Bandwidth, BIE Schools’ Circuit Speeds and Official School Directory for Data Submissions.

USAC Files 2013 Annual Report

USAC filed its 2013 Annual Report on March 31, 2014, highlighting its operations, activities and accomplishments for 2013 and its financial standing.

Broadband

Carriers to Offer WBIAS on a Common-Carriage Non-Tariffed Basis

JSI, on behalf of Otelco Telephone, Adams Telephone, and Alpine Communications, filed notices on April 1, 2014, of their intent to discontinue their Wireline Broadband Internet Access Service (WBIAS) offerings pursuant to NECA Tariff F.C.C. No. 5. Effective July 1, 2014, the carriers will provide WBIAS on a common-carriage non-tariffed basis. Pioneer Communications also filed a notice on April 1, 2014, that as of May 1, 2014, it will discontinue its WBIAS under NECA Tariff F.C.C. No. 5, and will provide WBIAS on a common-carriage, non-tariffed basis.

Internet

Commissioner O’Rielly Discusses Internet Governance at FCBA

Commissioner O’Rielly spoke before the Federal Communications Commission Bar Association on April 1, 2014, and discussed NTIA’s recent announcement that it plans to end its oversight of the Internet Assigned Names Authority function of the Internet Corporation for Assigned Names and Numbers. Commissioner O’Rielly said transitioning domain name functions to a new, global multi-stakeholder community raises some serious concerns that must be addressed prior to moving forward, and expressed concern that this could lead to the involvement of foreign governments or quasi-governmental bodies in Internet governance.

FCC Process Reform

Samsung Files Comments on FCC Process Reform Report

In addition to the comments listed in a previous edition of Washington Watch, Samsung filed comments on March 31, 2014, on the Report on FCC Process Reform. The Report seeks to further the goal of having the FCC operate in the most effective, efficient and transparent way possible, and examines the FCC’s internal operations with the aim of improving the overall functioning of the agency and its service to the public. Samsung agrees with the FCC’s recommendation to add additional technical experts to keep pace with commercial advances in technology. Public Notice | List of all comments filed

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 04/01/2014

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April 1, 2014

Back Issues

Contents

IP Transition

NECA, NTCA, ERTA Support Rural Broadband Experiments

Comments Filed on Rural Broadband Experiments FNPRM

Comments Filed on AT&T Proposed IP Transition Trial

Replies Filed on INS Service-Based IP Transition Trial

CenturyLink Files Comments on IP Numbering Testbed FNPRM

FCC Consumer Advisory Committee Adopts Recommendations on IP Transition Trials

USF/ICC Transformation Order

FCC Issues Order Clarifying ICC Rules

Associations File Reply on Petition to Extend Compliance Deadline for 2014 Rate Floor

Replies Filed on Petition to Extend Compliance Deadline for 2014 Rate Floor

NECA, NTCA, USTelecom, WTA File Supplement on RLEC CAF Mechanism Proposal

FCC Process Reform

Comments Filed on FCC Process Reform Report

Retransmission Consent

FCC Revises Retransmission Consent Rules, Issues FNPRM

Broadband

FCC Adopts Spectrum Items at March Open Meeting

Today’s News Clips

FCC Report: Small Telco Broadband Subscribers Doubled in Two Years

Sprint Joins Forces With Rural America on LTE

IP Transition

NECA, NTCA, ERTA Support Rural Broadband Experiments

NECA, NTCA and ERTA filed comments on March 31, 2014, supporting the rural broadband experiments proposed in the FNPRM adopted in the IP Transition Order. The Associations urged the FCC to: clarify how rural broadband experiments will be integrated and coordinated with existing federal USF programs; not allow these experiments to distract from updating existing USF support mechanisms so that rural broadband can remain reasonably comparable in price and quality; adopt a mechanism such as proposed by the Rural Associations to ensure rural consumers will not lose access to broadband services; and enforce existing COLR and ETC obligations. The Associations highlighted that RLECs, based on their Expressions of Interest filings, remain an effective solution for the continued deployment of broadband and should be given the right-of-first-refusal to obtain approval for experiments in their incumbent areas.

Comments Filed on Rural Broadband Experiments FNPRM

In addition to comments listed in a previous edition of Washington Watch, comments were filed on March 31, 2014, on the FNPRM proposing rural broadband experiments, including: the budget for the rural broadband experiments, experiments in rate-of-return ILEC areas, and the selection criteria for rural broadband experiments. WTA supports the FCC’s rural broadband experiment program, saying the existing $2 billion in annual RLEC high-cost funding is insufficient to bring broadband services to all RLEC areas. WTA supports separate experimental rural broadband programs or allocations for price cap service areas and for rate-of-return service areas, and said all applicants should be designated ETCs. USTelecom recommended a budget of $50-$100 million for rural broadband experiments with awards based solely on the cost-effectiveness of the experiment. USTelecom said service requirements should mirror (or exceed) CAF Phase II requirements, and funding should not be allotted to areas where broadband is already available. The Massachusetts DTC supports the FCC’s decision to move forward with a competitive bidding trial before implementing such a mechanism under CAF Phase II, and said such an approach will provide insight into the interest and ability of a range of entities to provide universal service in unserved areas. NCTA asserted the FCC’s program should incorporate the same principles incorporated in CAF, including cost effectiveness, competitive and technological neutrality and no overbuilding, and said there should be no preferential or exclusive access awarded to ILECs. Replies are due April 14. FR

Other comments filed by:

ACA

Alaska Rural Coalition

Atlantic Tele-Network

Competitive Carriers Association

CooperSoft

Douglas Electric Coop

Evangelical Lutheran Good Samaritan Society

Fiber to the Home Council Americas

Lake Region Electric Cooperative

Midwest Energy Cooperative

Navajo Nation Telecom Regulatory Commission

Utilities Telecom Council

ValleyNet

Vermont Telecommunications Authority

WISPA

List of all comments filed

Comments Filed on AT&T Proposed IP Transition Trial

Comments were filed March 31, 2014, on AT&T’s proposed IP transition trials, as called for by the IP Transition Order, for a wire center in Florida and a wire center in Alabama. NASUCA said AT&T’s comments on INS’ proposed IP trial raise significant concerns for the treatment of consumers in AT&T’s Alabama and Florida trials, and noted that customers’ voluntary participation in AT&T’s trials is limited and shortlived as AT&T has said it anticipates a complete migration to its IP services. NASUCA pointed out AT&T appears to expect to have divested itself of the carrier of last resort obligation and any responsibility to be a Lifeline provider, and pointed out that AT&T suggested the FCC’s rules will not stand in its way. NASUCA said these assertions should not be accepted at face value by the FCC, and it urged the Commission to make it clear that the authorization of AT&T’s trial is not an approval for AT&T on any of the legal and policy issues in play. The Alabama PSC said it recognizes the AT&T IP Transition Trial in Carbon Hill, Alabama, as an opportunity to further its understanding of the technical issues confronting providers and the implications for consumers, and said the most important byproduct of the trial is a thorough, written record of the entire transition experience, including failures, successes and recommendations for improvement. It proposed the establishment of a Consumer Advisory Council to meet monthly in Carbon Hill and a Technical Issues Workgroup composed of representatives from AT&T, the PSC, an IXC, a rural ILEC serving Walker County, a CLEC serving Carbon Hill and a non-AT&T wireless provider. Windstream expressed concern about the impact AT&T’s IP trial will have on its small business customers in Kings Point, Florida, that are served by TDM-based products. Windstream urged the Commission to require AT&T to meet all of the Commission’s requirements with respect to wholesale services used to enable communications connectivity for these customers, noting of particular concern are the requirements that: comparable services must be available at equivalent prices, terms and conditions; replacement wholesale inputs must offer substantially similar wholesale access to AT&T’s network; and the trial plan must ensure that customers are not penalized as a result of the experiment. Replies are due April 10. Public Notice

Other comments filed by:

AARP

ACN Communications Services et al.

Alarm Industry Communications Committee

Cbeyond et al.

CenturyLink

Communications Workers of America

Competitive Carriers Association

COMPTEL

Ericsson

Granite Telecommunications

Harris Corporation

Hypercube

Interisle Competitive Carriers Group

Metropolitan Telecommunications

Michigan PSC

National Consumer Law Center

Pennsylvania PUC

Public Knowledge et al.

Replies Filed on INS Service-Based IP Transition Trial

Reply comments were filed on March 31, 2014, on Iowa Network Services’ proposal to conduct an IP transition trial, as called for by the IP Transition Order, to transition its centralized equal access services from TDM to IP. NTCA said AT&T’s request for clarification and its comments regarding the INS proposal indicate that AT&T is actually seeking to use the IP trial process to confirm that various legal and policy issues surrounding IP interconnection have been resolved in AT&T’s favor, but it said INS’ proposal merely assumes the status quo. NTCA said a voluntary experiment such as that proposed by INS should not be precluded in this trial process, nor should AT&T be permitted to use the trial process to confirm that the FCC has already adopted its preferred resolution of the many legal and policy issues still surrounding IP interconnection and compensation arrangements. INS said contrary to the assertions of AT&T, CenturyLink and Sprint, INS does not seek to change the regulatory treatment of any of the traffic sent to its CEA network for routing to other carriers. INS said if the traffic would have been treated as CEA traffic subject to intercarrier compensation before the experiment, it will be treated the same way during and after the experiment. Verizon said if the FCC is inclined to proceed with the INS proposal at all, the FCC should require INS to provide additional information about what INS expects to achieve through a trial and how such a trial would benefit the IP transition.

Other replies filed by:

South Dakota Network

Public Knowledge, et al.

CenturyLink Files Comments on IP Numbering Testbed FNPRM

CenturyLink filed comments on March 31, 2014, on the FNPRM proposing a testbed for telephone numbering in an all-IP network, which was adopted in the Commission’s IP Transition Order. CenturyLink supports the concept of a testbed for investigating the mechanics and management of numbering in an all-IP environment, rather than experimenting with those ideas in the live PSTN. It suggested once reliable information regarding the costs of a national numbering testbed is established, a strategy for sharing the funding obligation should be developed so that all participants in the testbed contribute resources, and said extraordinary contributions from participants who would stand to gain financially from any ultimate industry decision should not be allowed.

FCC Consumer Advisory Committee Adopts Recommendations on IP Transition Trials

The FCC’s Consumer Advisory Committee adopted recommendations on IP transition trials at their March 28, 2014 meeting. The CAC urged the FCC to develop a series of metrics to serve as a checklist for evaluating successful execution of the IP-transition trials before they begin, and encourage the development of best-in-class benchmarks for future trials. The CAC also recommended the FCC review public outreach and conduct surveys of customer experiences in order to provide consumers information throughout the trials.

USF/ICC Transformation Order

FCC Issues Order Clarifying ICC Rules

The Wireline Competition Bureau issued an Order on March 31, 2014, clarifying and correcting certain rules relating to implementation of the intercarrier compensation transition adopted in the USF/ICC Transformation Order. The Bureau clarified language in sections 51.907 and 51.909 to reflect that achieving ongoing rate parity for the access rates themselves, not the composite rate for price cap and rate-of-return LECs, was the intent of the Transformation Order. It said carriers may continue to establish interstate terminating end office access rate caps that do not exceed the target composite terminating end office access rate for each year in the transition in the manner the adopted rules require. The Bureau also clarified certain aspects of the rules on the transition of terminating end office access rates and the calculation of Eligible Recovery for price cap and rate-of-return carriers beginning in 2014. The Bureau said calculation of the 2011 Baseline Composite Terminating End Office Access Rate should only include 2011 FY interstate demand and rates, and it revised section 51.907(d)(2)(i) to eliminate any ambiguity and to facilitate the annual tariff filing process. The Bureau also made corrections and clarifications to rules on recovery mechanism calculations, ARC true-ups, true-up of regulatory fees, duplicative recovery, single per-minute rate element for terminating end office access service, and revenue true-ups. The Bureau also agreed with NECA’s request that, in making the true-up calculations, it use the difference between projected revenues and realized revenues.

Associations File Reply on Petition to Extend Compliance Deadline for 2014 Rate Floor

NECA, NTCA, ERTA and WTA filed a Reply on March 31, 2014, on their Petition filed with ITTA and USTelecom, which asked the Bureau to extend the deadline for compliance with the 2014 local service rate floor from July 1, 2014, to January 2, 2015, and that subsequent adjustments to the local rate floor be made annually on January 2 and mid-year rate updates should be permitted on July 1 of each succeeding year. The Associations said delaying the annual increase in the local rate floor and undertaking a further review of the policy affects neither payers into the USF nor the overall budget of the high-cost fund. They said the FCC and the Bureau can and should take the time afforded by the delay in the implementation of any increases requested by the Petition to evaluate what reasonable comparability truly means for rural rates as a measure both above and below urban average rates. They also urged the release publicly of the data obtained via the urban rate survey to enable validation of the Bureau’s calculations. Public Notice

Replies Filed on Petition to Extend Compliance Deadline for 2014 Rate Floor

In addition to GVNW’s Reply that was reported in a previous edition of Washington Watch, replies were filed on March 31, 2014, on ERTA, ITTA, NECA, NTCA, USTelecom and WTA’s Petition asking the Bureau to extend the deadline for compliance with the 2014 local service rate floor from July 1, 2014, to January 2, 2015, and that subsequent adjustments to the local rate floor be made annually on January 2 and mid-year rate updates should be permitted on July 1 of each succeeding year. ITTA and USTelecom said the FCC should promptly adopt the schedule for certification of compliance with the local rate floor requirement proposed by the Associations, and said increases in the local rate floor should be capped at $2.00 per year. They also said the FCC should disclose the underlying data and methodology used to calculate the new rate floor before it is allowed to take effect. The Montana PSC supported the Associations’ Petition, and said the FCC should implement the rate floor in two increments, instead of requiring a 46 percent increase in local rates in one step. The Montana Telecom Association also supported the Petition, and asked the FCC to provide ETCs with the option to phase in rate increases over two or more years, without reductions in universal service support for rates that are below the rate floor while ETCs phase in their rate increases; and adopt a more flexible interpretation of reasonably comparable to include rates that are both above and below the average urban rate. Public Notice

Other replies filed by:

ACS

Concerned Rural ILECs

Frontier

Hot Springs Telephone and Ronan Telephone

ICORE Consulting

JSI and JSI High Cost Loop Support Clients

Minn. Dept. of Commerce

Missouri Small Telephone Company Group

Montana Independent Telecommunications Systems

Ohio PUC

Pioneer Telephone Company

Small Company Committee of Louisiana Telecom Association

Texas Statewide Telephone Coop

Washington UTC

WITA et al.

List of all replies filed

NECA, NTCA, USTelecom, WTA File Supplement on RLEC CAF Mechanism Proposal

NECA, NTCA, USTelecom and WTA filed a letter on March 31, 2014, in response to questions from FCC staff, to provide further information on the Associations’ proposal for a targeted CAF program to refine and update universal service support mechanisms in areas served by rate-of-return-regulated RLECs. The information supplements materials that have been provided in a series of filings over the past several months.

FCC Process Reform

Comments Filed on FCC Process Reform Report

Comments were filed on March 31, 2014, on the Report on FCC Process Reform. The Report seeks to further the goal of having the FCC operate in the most effective, efficient and transparent way possible, and examines the FCC’s internal operations with the aim of improving the overall functioning of the agency and its service to the public. NTCA said while there is no requirement in the Administrative Procedure Act or in the Communications Act that the text of proposed rules be included in an NPRM, it should be the general policy of the Commission to do so. NTCA also agreed with the FCC that comment rounds be focused in large dockets. Verizon supported the proposal to put out Petitions for Rulemaking and Petitions for Declaratory Rulings for comment immediately upon receipt if procedurally sound. Verizon also said parties aggrieved by a USAC decision already have the option to seek review from USAC before seeking Commission review. Verizon said it should remain an option, but disagrees that it should become a mandatory step. CenturyLink said the FCC should adopt a firm outside deadline of 180 days for Petitions for Reconsideration and Applications for Review, while endeavoring to complete items more quickly where possible. CenturyLink also said the FCC should establish unique procedures for ensuring that Petitions for Forbearance generally are resolved within the twelve-month statutory period. Public Notice

Other comments filed by:

Alexicon Telecom Consulting

ARRL

Center for Competitive Politics

Cheryl B. Williams – FCC International Bureau

Comcast

Competitive Carriers Association

COMPTEL

Consumer Electronics Association

EchoStar & Hughes Network

EMRadiaition Policy Institute

Hispanic Technology and Telecommunications Partnership et al.

Mobile Manufacturers Forum

NASUCA

NARUC

National Association of Broadcasters

National Tribal Telecommunications Association

PCIA

Pennsylvania PUC

Samuelson-Glushko Technology Law and Policy Clinic

SES Americom

Small Company Coalition

Taxpayers Protection Alliance

The Boeing Company

T-Mobile

U.S. Chamber of Commerce

Marcus Spectrum Solutions

Retransmission Consent

FCC Revises Retransmission Consent Rules, Issues FNPRM

The FCC issued a Report and Order and FNPRM on March 31, 2014, revising its retransmission consent rules to make joint negotiation by stations that are ranked among the top four stations in a market as measured by audience share and are not commonly owned a violation of the statutory duty to negotiate retransmission consent in good faith. The Order also defines joint negotiations in order to target collusive behavior effectively. The accompanying FNPRM seeks comment on whether to modify or eliminate the FCC’s network non-duplication and syndicated exclusivity rules in light of changes in the video marketplace. News Release | Comments are due 30 days after Federal Register publication; replies due 60 days after FR.

Broadband

FCC Adopts Spectrum Items at March Open Meeting

The FCC adopted a Report and Order on March 31, 2014, that advances ongoing efforts to make more spectrum available for flexible-use wireless services, including mobile broadband. The Report and Order sets flexible-use regulatory, licensing and technical rules for 65 megahertz of spectrum in the AWS-3 band, which includes the 1695-1710 MHz, 1755-1780 MHz, and 2155-2180 MHz bands. The FCC also adopted a separate Report and Order modifying the rules governing the operation of Unlicensed National Information Infrastructure (U-NII) devices operating in the 5 GHz band.

Today’s News Clips

FCC Report: Small Telco Broadband Subscribers Doubled in Two Years

By Joan Engebretson

Telecompetitor

The number of residential customers taking broadband service from the nation’s smaller rate of return carriers more than doubled between December 2010 and December 2012 – increasing 114%, according to a report released from the FCC this week. In comparison, the number of residential customers taking broadband service from the nation’s largest price cap carriers increased 61% over the same period.

The report from the Wireline Competition Bureau, titled “Universal Service Implementation Progress Report,” was based on data collected from carriers. Broadband was defined as any landline connection providing data rates of 3 Mbps downstream and 768 kbps upstream.

http://www.telecompetitor.com/fcc-report-small-telco-broadband-subscribers-doubled-two-years/

Sprint Joins Forces With Rural America on LTE

By Sarah Reedy

Light Reading

Through a partnership that’s been years in the making, Sprint is joining forces with the Competitive Carriers Association and NetAmerica Alliance to accelerate 4G LTE deployments — and device availability — in rural America and to help Sprint fill in the gaps of its own LTE network.

Sprint Corp. (NYSE: S), the Competitive Carriers Association (CCA) and NetAmerica Alliance LLC , announced the partnership called Small Market Alliance for Rural Transformation (SMART) on Wednesday in San Antonio, making good on SoftBank Corp. CEO Masayoshi Son’s promise to bring mobile broadband to underserved areas and fight the big two US carriers.

http://www.lightreading.com/mobile/spectrum/sprint-joins-forces-with-rural-america-on-lte/d/d-id/708400

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 03/28/2014

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March 28, 2014

Back Issues

Contents

Separations

FCC Proposes to Extend Separations Freeze for Three Years and Consider Waivers for RoR Carriers

USF/ICC Transformation Order

Senator Pryor Expresses Concerns With Rate Floor Increase

IP Transition

AT&T Discusses Data Transport Services Market

Colorado Technology Law & Policy Clinic Discusses Accessibility in IP Transition

Broadband

FCC Announces New Form 477 Data Collection Interface

Consumer Advisory Committee

Agenda Issued for FCC Consumer Advisory Committee Meeting on March 28

Universal Service

Bureau Grants Waivers of High-Cost Filing Deadlines

CenturyLink Seeks Review of USAC Decision

Cisco WebEx Discusses its Audio Services

TracFone Discusses Mobile Healthcare Telecommunications Service

Funds for Learning Discusses E-rate Modernization

FCC Budget

Senate Subcommittee Holds Hearing on FCC Budget

Today’s News Clips

House Republicans Move to Block Internet Management Switch

Separations

FCC Proposes to Extend Separations Freeze for Three Years and Consider Waivers for RoR Carriers

The FCC issued a Further Notice of Proposed Rulemaking on March 27, 2014, proposing to extend the freeze of jurisdictional separations category relationships and cost allocation factors in Part 36 for three years, through June 30, 2017. The FCC said an extension would allow the Joint Board to consider reforms made in the 2011 Transformation Order and ongoing separations reform before it issues a Recommended Decision. The FCC also proposes to direct the Wireline Competition Bureau to open a filing window for rate-of-return ILECs to file waiver requests to unfreeze their jurisdictional separations category relationships. The FCC said such petitions must contain the necessary documentation to support a waiver, and to prevent over-recovery, the Bureau will require carriers to file certain revised 2011 rate-of-return Base Period Revenue data reflecting changes in category relationships the carrier makes pursuant to any relief granted. Comments are due 14 days after date of publication in the Federal Register; replies due 21 days after FR publication.

USF/ICC Transformation Order

Senator Pryor Expresses Concerns With Rate Floor Increase

Senator Mark Pryor (D-Ark.), Chairman of the Subcommittee on Communications, Technology and the Internet, sent a letter to Chairman Wheeler on March 26, 2014, expressing concerns with the Wireline Competition Bureau’s announcement that it will modify the rate floor for phone rates of rural consumers from $14 to over $20 on July 1, 2014. Senator Pryor said the FCC should reconsider actions that lead to significant rate increases for vulnerable, rural consumers. Senator Pryor also said it is imperative that the FCC act to delay these increases, and said should an increase in the rate floor be necessary, that increase should be phased-in.

IP Transition

AT&T Discusses Data Transport Services Market

AT&T met with FCC staff on March 25, 2014, to discuss the current status of, and expectations for further development and deployment of, replacements for AT&T’s current DSn services, including switched and dedicated Ethernet service, as well as the capabilities of those replacement services. AT&T noted Ethernet has become the de facto industry choice for replacing T1, T3, and SONET, and provided information on AT&T’s Ethernet product portfolio and the data transport services market.

Colorado Technology Law & Policy Clinic Discusses Accessibility in IP Transition

The Colorado Law Samuelson-Glushko Technology Law & Policy Clinic met separately with Commissioner Pai and his staff, Gigi Sohn of Chairman Wheeler’s office, General Counsel Jon Sallet, and Office of General Counsel and Public Safety and Homeland Security Bureau staff on March 24, 2014, to discuss the potential tensions in the proceeding on Globalstar’s proposal to build a Terrestrial Low Power Service at 2.4 GHz using both unlicensed and licensed spectrum. It also discussed some of the potential implications of the IP transition on individuals with disabilities, and submitted a copy of an abstract on Accessibility and the TDM to IP Transition.

Broadband

FCC Announces New Form 477 Data Collection Interface

The Wireline Competition Bureau issued a Public Notice on March 27, 2014, to provide additional information on the new Form 477 data collection interface, including guidance on which data filers must submit by file upload, by interactive data entry, or a choice of the two methods. The Bureau stated modifications to the Form 477 data collection are subject to approval by the Office of Management and Budget, and the Bureau will announce in a subsequent Public Notice the specific filing deadlines and other procedures for submitting Form 477 under the revised rules, as well as instructions on how to prepare the data and navigate the new filing interface. Until the rule changes in the June 2013 Order take effect, providers should continue to submit Form 477 data as required under the existing rules.

Consumer Advisory Committee

Agenda Issued for FCC Consumer Advisory Committee Meeting on March 28

The FCC issued the agenda for the March 28, 2014 Consumer Advisory Committee meeting. The Committee will discuss Lifeline, IP Transition, and Open Internet issues. The Committee was established in November 2000 to make recommendations to the Commission on consumer issues.

Universal Service

Bureau Grants Waivers of High-Cost Filing Deadlines

The Wireline Competition Bureau released an Order on March 27, 2014, granting Petitions filed by MTA Wireless/Matanuska-Kenai and Cordova Wireless for waiver of sections 54.307 and 54.802(a), which require CTECs to report the number of lines they serve, on a quarterly basis, in order to receive USF support. The Bureau said because both companies promptly filed the required data after the initial deadline, and have instituted revisions to their internal processes to prevent future late filings, good cause exists to waive the Commission’s rules, and it directed USAC to reinstitute any high-cost support for both carriers.

CenturyLink Seeks Review of USAC Decision

CenturyLink filed a Request for Review on March 26, 2014, of a USAC decision on certain audit findings of CenturyLink’s USF contributions reported on its 2012 FCC Form 499-A. CenturyLink seeks review of USAC’s finding that it understated its USF contribution base, and USAC’s determination that its contribution based should not be reduced to account for revenues improperly included in the contribution base. CenturyLink also claimed, despite USAC’s finding, this audit finding leads to a double payment of Federal USF contributions and falls within the scope of this audit.

Cisco WebEx Discusses its Audio Services

Cisco WebEx filed a letter on March 26, 2014, to provide additional detail on the audio services WebEx offered before and after the USAC audit period, and its reasons for making a good faith effort to identify telecommunications revenue during that period. WebEx refuted InterCall’s claim that WebEx permits its customers to bring their own audio inputs, and that this flexibility means that WebEx is not an integrated information service, arguing this ignores the integration between WebEx audio and WebEx online collaboration capabilities. WebEx also disagreed with InterCall’s claim that it charges an above-market rate for WebEx audio and should contribute to the USF on the basis of this mark-up.

TracFone Discusses Mobile Healthcare Telecommunications Service

TracFone Wireless met separately with Commissioner Clyburn’s Legal Advisor, and Office of Strategic Planning and Policy Analysis and Wireline Competition Bureau staff on March 20, 2014, to discuss TracFone’ s provision of mobile healthcare telecommunications service. TracFone said the service is offered as part of its SafeLink Wireless^® Lifeline program, and is offered in cooperation with several partners to provide mobile access, including unlimited SMS text messaging between Medicaid patients and healthcare providers.

Funds for Learning Discusses E-rate Modernization

Funds for Learning met with Wireline Competition Bureau staff on March 25, 2014, to discuss modernization of the E-rate program. FFL said there are opportunities to improve the underlying efficacy of the program separate and apart from changes to the priority rules and eligibility guidelines. FFL also said easier access to information, more transparent data, and the use of current communication technologies can ease the administrative burden and bring about new opportunities for cost-savings.

FCC Budget

Senate Subcommittee Holds Hearing on FCC Budget

Chairman Wheeler and Commissioner Pai testified at the March 27, 2014 Senate Subcommittee on Financial Services and General Government hearing on the President’s Fiscal Year 2015 funding request and budget justification for the FCC. Chairman Wheeler said a major spending target is USF modernization and oversight, and said USF employees will likely be distributed among Wireline Competition Bureau, the Enforcement Bureau, Office of Inspector General and Office of Managing Director.

Today’s News Clips

House Republicans move to block Internet management switch

By Kate Tummarello

The Hill

A group of House Republicans introduced a bill Thursday that would prohibit the Obama administration from moving forward with its announced plans to relinquish oversight of the technical side of the Internet’s Web address system.

“America shouldn’t surrender its leadership on the world stage to a ‘multistakeholder model’ that’s controlled by foreign governments,” Rep. Marsha Blackburn (R-Tenn.), one of six cosponsors of the Domain Openness Through Continued Oversight Matters, or DOTCOM, Act.

http://thehill.com/blogs/hillicon-valley/technology/201991-house-republicans-move-to-block-internet-management-switch

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 03/27/2014

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March 27, 2014

Back Issues

Contents

USF/ICC Transformation Order

GVNW Files Reply on Associations Petition to Extend Compliance Deadline for 2014 Rate Floor

E.N.M.R. Telephone Files Waiver Petition to Adjust 2011 Base Period ICC Revenues

IP Transition

AT&T Responds to FCC Questions on IP Transition Trial

Competitive Carriers/Consumer Groups Discuss AT&T IP Trials

Open Internet

Comments Filed in Open Internet Proceeding

Universal Service

FCC Seeks PRA Comments on Information Collection for ETC Additional Requirements

Guidance to ETCs on Process for Lifeline Recertification Effective March 27

Smith Bagley Discusses Duplicate Resolution Process for Lifeline

National Consumer Law Center Discusses Lifeline Documentation Retention

New Mexico PRC Provides Lifeline Certification Information

Alliance for Excellence in Education Discusses Modernization of the E-rate Program

Education Networks of America Discusses Modernization of the E-rate Program

Forbearance

FCC Approves CenturyLink Cost Assignment Forbearance Compliance Plan

LNP

Neustar Files Analysis on LNP Administrator Transition

Retransmission Consent

WTA Discusses Retransmission Consent Concerns

USTelecom, CenturyLink Discuss Retransmission Consent

NCTA Discusses Spectrum, Retransmission Consent

Relay Service

FCC Grants Partial Waiver of Filing Deadline of TRS Waiver Status Reports

FCC Staff

New Acting Deputy General Counsel Announced

USF/ICC Transformation Order

GVNW Files Reply on Associations Petition to Extend Compliance Deadline for 2014 Rate Floor

GVNW filed an early Reply on March 26, 2014, on the Petition filed by NECA, ERTA, ITTA, NTCA, USTelecom and WTA, asking the Bureau to extend the deadline for compliance with the 2014 local service rate floor from July 1, 2014 to January 2, 2015, and that subsequent adjustments to the local rate floor be made annually on January 2 and mid-year corrections should be permitted on July 1 of each succeeding year. GVNW agreed this latest rate increase should be phased in and the date by which this increase needs to be implemented should be delayed. GVNW suggested the FCC implement for the 2014 benchmark a low-end rate level at $17.25, and the step up to the $20.46 local rate level would then occur with the setting of the 2015 target level. GVNW also suggested the Commission revisit its definition of reasonable comparability, saying it should not and does not require that rates in urban and rural areas be precisely the same, especial as local voice rates in many rural areas should, if anything, be lower than those charged in urban areas given the relative populations within a particular rural local calling area. Replies are due March 31. Public Notice

E.N.M.R. Telephone Files Waiver Petition to Adjust 2011 Base Period ICC Revenues

E.N.M.R. Telephone Cooperative filed a redacted Petition for Limited Waiver on March 26, 2014, of section 51.917(b)(7)(ii) to allow it to correct inadvertent, administrative errors that resulted in under-reporting of billed and collected revenue for Intrastate Access Service for Fiscal Year 2011 that should have been included in the calculation of the 2011 Rate-of-Return Carrier Base Period Revenue. ENMR noted the errors were brought to its attention by a NECA representative during the NECA process of gathering CAF ICC information for the annual true-up of CAF ICC support. It said grant of this limited waiver will serve the public interest by allowing ENMR to continue serving its customers consistent with the Commission’s National Broadband Plan goals, and it seeks confidential treatment of the revenue data under the Third Protective Order in this proceeding.

IP Transition

AT&T Responds to FCC Questions on IP Transition Trial

AT&T met with Commission staff on March 21, 2014, to respond to questions about its proposed IP transition trials at two wire centers. AT&T attached the list of questions and its redacted responses, which it said contain highly confidential information and are entitled to protection under the terms of the Protective Order and Second Protective Order in these dockets. AT&T filed a follow-up letter on March 26, 2014, to file a corrected copy of the questions and responses, noting it had inadvertently omitted its response to Question 16.

Competitive Carriers/Consumer Groups Discuss AT&T IP Trials

AARP, the National Consumer Law Center, Public Knowledge, Free Press, Windstream, Cbeyond, XO Communications and COMPTEL met with Chairman Wheeler and Commissioner O’Rielly’s staff, and were joined by representatives of EarthLink, Integra Telecom, Level 3, tw telecom and the Open Technology Institute at the New America Foundation in a meeting with Commissioner Rosenworcel and her Legal Advisor, on March 24, 2014, to suggest the Commission only approve AT&T’s two proposed trials if the following issues are adequately addressed: the availability, affordability, and substitutability of the services for residential, business, and wholesale consumers; the limitations of the proposed trial locations, as neither reflects the diverse issues the nation will face during the technology transitions; the replacement products for TDM services, as AT&T indicates many are still TBD; the adequacy of the information AT&T plans to collect and whether a third party should be designated to collect and report on the relevant information; and the submission of some of the information about AT&T’s trials confidentially, including the schedule for the trials.

Open Internet

Comments Filed in Open Internet Proceeding

In addition to comments listed in previous editions of Washington Watch, NCTA and the Center for Democracy and Technology filed comments on March 26, 2014, in response to the Public Notice, which asked for input on how the Commission should proceed on the Open Internet rules in light of the D.C. Circuit Court’s guidance in the Verizon v. FCC Opinion. NCTA said there is no need for the Commission to establish overly prescriptive Open Internet mandates unless concrete evidence of market failure or actual consumer harm emerges. It suggested if the Commission initiates rulemaking proceedings on reinstating certain limits on blocking access to lawful content and services and/or on potentially harmful discrimination, the Commission should: undertake a fresh assessment of how to harmonize the regulatory requirements for fixed and mobile broadband services; explore the ability of edge providers to frustrate its open Internet objectives; reaffirm its longstanding view that open Internet principles do not justify the extension of regulation to the competitive marketplace of Internet peering or transit arrangements; and decline to pursue Title II reclassification proposals. The Center for Democracy and Technology stressed: the Commission’s approach to its authority over broadband Internet access is closely related to other priorities, action to protect the open Internet is needed now, nondiscrimination is an essential element of such protection, and the Commission should expressly disclaim authority over Internet content and over-the-top services. List of all comments filed

Universal Service

FCC Seeks PRA Comments on Information Collection for ETC Additional Requirements

The FCC issued a Notice in the Federal Register on March 27, 2014, seeking Paperwork Reduction Act comments on a revision to a currently approved information collection associated with the Part 54 rules on additional requirements for ETCs, including the submission of an application that certifies they will comply with the service requirement applicable to the USF support that it receives and a five-year plan that describes with specificity proposed improvements or upgrades to the applicant’s network throughout its proposed service area. Comments are due May 27.

Guidance to ETCs on Process for Lifeline Recertification Effective March 27

The FCC published a Public Notice in the Federal Register on March 27, 2014, providing guidance regarding the process for ETCs to elect USAC to perform Lifeline recertification for their subscribers in 2014. Pursuant to the 2012 Lifeline Reform Order, ETCs are required to recertify the eligibility of their base of subscribers annually, and starting in 2013, ETCs had the option of having USAC conduct the annual recertification process on their behalf. The Notice is effective March 27.

Smith Bagley Discusses Duplicate Resolution Process for Lifeline

Smith Bagley d/b/a/ Cellular One spoke with Wireline Competition Bureau staff on March 21, 2014, to discuss Lifeline duplicate resolution processes. It discussed problems with proposals to resolve duplicates, saying that notifying customers by mail could have potential problems due to lack of mail service, lack of mailing addresses in the NLAD, difficulty of returning the multi-household worksheet (MHW) to the ETC, and language or cultural communication barriers. It suggested the FCC instead allow ETCs to obtain MHWs from their own customers, give them sufficient time to return the MHW, and give carriers advance notice of the start of the 35-day carrier selection period.

National Consumer Law Center Discusses Lifeline Documentation Retention

The National Consumer Law Center and National Hispanic Media Coalition met with Wireline Competition Bureau staff on March 24, 2014, to discuss safeguarding sensitive Lifeline customer data. They said if the FCC decides to allow document retention by ETCs, it must only be allowed in very limited and controlled circumstances to protect customer privacy and protect from ID theft. They also discussed the impact of the loss of toll-free calling for prepaid wireless Lifeline customers, and expressed concern about the inconsistent level of training among sales representatives, providing a copy of a letter from an organization in Boston that has encountered poorly trained representatives.

New Mexico PRC Provides Lifeline Certification Information

The New Mexico Public Regulation Commission sent a letter to the FCC on March 25, 2014, responding to its request for state notifications of Lifeline recertification. The PRC said New Mexico’s ETCs conduct their own subscribership recertification at this time.

Alliance for Excellence in Education Discusses Modernization of the E-rate Program

The Alliance for Excellent Education filed a letter on March 25, 2014, discussing an informational meeting it organized with Wireline Competition Bureau staff on March 12, 2014, for organizations and parties representing various points of view concerning the E-rate program. The Alliance said the meeting focused primarily on educating the attendees on the recent call for focused comments.

Education Networks of America Discusses Modernization of the E-rate Program

Education Networks of America spoke with Wireline Competition Bureau staff on March 24, 2014, to discuss modernization of the E-rate program. ENA discussed its experience regarding bandwidth demand and usage for K-12 schools and libraries, its managed wireless (Wi-Fi) solution deployment experience and general pricing strategy, and a potential submission to the FCC of data regarding connectivity for schools and libraries connected to ENA’s network.

Forbearance

FCC Approves CenturyLink Cost Assignment Forbearance Compliance Plan

The FCC issued a Public Notice on March 26, 2014, announcing it approved CenturyLink’s Cost Assignment Forbearance Compliance Plan for its ILEC Operations, as required by the USTelecom Forbearance Order. CenturyLink’s Compliance Plan describes how it will comply with continuing accounting requirements under the Act and the FCC’s rules. The Bureau noted since CenturyLink’s compliance plan did not contain commitments on the separate affiliate rule, CenturyLink must submit a compliance plan explaining compliance with that condition in accordance with the terms of the Order if it wishes to take advantage of forbearance relief from that rule.

LNP

Neustar Files Analysis on LNP Administrator Transition

Neustar filed a paper by its Vice President of Numbering Services, analyzing the LNP Administrator transition. The paper finds a transition of LNP Administrator services would consume industry resources for a minimum period of two years, starting from the date of selection – even under optimal conditions. The paper stated the industry could not conceivably be at full readiness and connected to a new LNPA prior to mid 2016, over one year after the FCC’s expected start of a new LNPA contract and a significant duration into the 5-year term implied by the RFP. Neustar said, at a minimum, the consideration of such a transition should include a full evaluation of impacts on stakeholders, including the impacts of serious delay, outright failure, and the potential pressure to move quickly at the expense of quality and stability.

Retransmission Consent

WTA Discusses Retransmission Consent Concerns

WTA met with Commissioner Clyburn’s Chief of Staff and Legal Advisor on March 24, 2014, to discuss multi-channel video distribution issues of interest to its members. WTA said the following FCC actions would help alleviate problems rural providers face: requiring the pricing and terms of all retransmission consent agreements and satellite channel agreements to be transparent and available for review; requiring uniform per-subscriber prices for agreements, or limiting the amount by which a content provider’s highest per-subscriber price can exceed its lowest; adopting additional requirements or best practices for good faith negotiation of agreements; and adopting streamlined procedures that permit MVPDs to change their Designated Market Area in response to customers.

USTelecom, CenturyLink Discuss Retransmission Consent

USTelecom and CenturyLink met with Commissioner O’Rielly’s staff on March 21, 2014, to express support for a proposal to prohibit two or more of the big four local broadcasters from banding together to jointly negotiate retransmission consent agreements, and for adoption of a rebuttable presumption that other station combinations within a market violate the FCC’s good faith negotiating requirement. They said while USTelecom has not taken a formal position on the broader aspects of Shared Services Agreements and Joint Sales Agreements, it encourages the FCC to address the significant problems that occur when MVPDs are required to negotiate retransmission consent rights for multiple local stations as a single package.

NCTA Discusses Spectrum, Retransmission Consent

NCTA met with Commissioner Clyburn and her staff on March 24, 2014, to discuss spectrum and retransmission consent issues. NCTA urged the Commission to act on the proposal to make the U-NII-1 sub-band at 5 GHz usable by Wi-Fi. NCTA expressed support for a rule prohibiting non-commonly owned broadcast stations in the same local market from jointly negotiating for retransmission consent, and reiterated its view that joint negotiations by competing broadcasters in a local market have serious anticompetitive effects on consumers. NCTA also urged the FCC to narrowly define the circumstances in which two commonly owned broadcast stations may be exempt from the prohibition on joint negotiations.

Relay Service

FCC Grants Partial Waiver of Filing Deadline of TRS Waiver Status Reports

The FCC’s Consumer and Governmental Affairs Bureau released an Order on March 26, 2014, granting a partial waiver of the requirement for iTRS providers to file waiver status reports by April 16, 2014. The Bureau said it is currently considering action that would make permanent exemptions to certain TRS mandatory minimum standards, and that it is unlikely that this proceeding will be concluded prior to the April 16, 2014 filing deadline for the annual reports.

FCC Staff

New Acting Deputy General Counsel Announced

The FCC issued a News Release announcing that the Office of General Counsel named David M. Gossett as Acting Deputy General Counsel for Litigation. Mr. Gossett joins the FCC from the Consumer Financial Protection Bureau, where he was Assistant General Counsel for Litigation.

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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Washington Watch 03/25/2014

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March 25, 2014

Back Issues

Contents

Open Meeting

FCC Issues Agenda for March 31 Open Meeting

USF/ICC Transformation Order

FCC Releases Transformation Order Progress Report

U.S. Cellular Asks FCC to Award Unclaimed Mobility Fund Support to Next-in-Line Bidders

IP Transition

Comments Filed on INS Service-Based IP Transition Trial

AT&T Discusses IP Numbering Testbed

VCXC Discusses Petition for HD Voice NOI

Call Completion

Verizon Discusses Call Completion Data Retention/Reporting Requirements

Open Internet

Vermont PSB Files Comments on Open Internet Order Remand

Verizon Suggests FCC Address Open Internet Problems on Case-by-Case Basis

Video/Retransmission

Comments Filed on State of Video Programming Competition

USTelecom, et al. Discuss Retransmission Consent

Frontier, CenturyLink, Mercury Strategies Discuss Retransmission Consent

NCTA Discusses Retransmission Consent

LNP

Frontier Asks FCC to Consider Mid-Size, Small Carrier Concerns in LNP Administrator Selection

Competitive Carriers Association Expresses Concerns With LNP Administrator Selection Process

Universal Service

Montana Office of Public Instruction Discusses E-rate, Broadband Connectivity

Today’s News Clips

Apple, Comcast in Talks to Stream New TV Service

Open Meeting

FCC Issues Agenda for March 31 Open Meeting

The FCC issued the agenda for its March 31, 2014 Open Meeting. The FCC will consider: an Order on retransmission consent negotiations and a FNPRM on whether to eliminate the network non-duplication and syndicated exclusivity rules; a FNPRM initiating the 2014 Quadrennial Review of broadcast ownership rules, a NPRM to define and require the disclosure of a category of sharing agreements between broadcast television stations, and an Order that determines certain television joint sales agreements are attributable; an Order revising rules to make 100 megahertz of 5 GHz UNII-1 band unlicensed spectrum more useful for consumers and businesses; and an Order adopting allocation, licensing, service, and technical rules to make available for auction 65 megahertz of AWS-3 spectrum for flexible use services, including mobile broadband.

USF/ICC Transformation Order

FCC Releases Transformation Order Progress Report

The Wireline Competition Bureau released an Implementation Progress Report on March 24, 2014, which enumerates the actions the Commission has taken to implement the universal service and ICC reforms adopted in the 2011 Transformation Order, and contains information on the impact of the reforms on ETCs that are incumbent telecommunications carriers. The report provides information and data on CAF Phases I and II, phase out of Safety Net Additive, QRA benchmarking rule, study area boundary collection, and the local rate floor. The report also notes Chairman Wheeler has circulated to his fellow Commissioners an Order that would eliminate the benchmarking rule.

U.S. Cellular Asks FCC to Award Unclaimed Mobility Fund Support to Next-in-Line Bidders

U.S. Cellular filed a Petition for Declaratory Ruling on March 21, 2014, requesting the FCC award unclaimed Mobility Fund Phase I support, originally awarded in Auction 901, to next-in-line bidders. USCC said more than $68 million of the $300 million originally made available for funding mobile broadband investments in unserved areas remains unclaimed due to winning bidders defaulting on their bids. USCC said these defaulted amounts can and should be awarded to the next-in-line bidders who remain ready, willing and able to expand the reach of mobile broadband into areas that remain unserved and which were eligible for funding under the rules of Auction 901.

IP Transition

Comments Filed on INS Service-Based IP Transition Trial

In addition to comments listed in previous editions of Washington Watch, comments were filed March 21, 2014, on Iowa Network Services’ proposal to conduct a service-based IP transition trial, as called for by the IP Transition Order, to transition its centralized equal access services from TDM to IP. AT&T said the Commission should require INS to provide additional detail and clarification before authorizing the experiment to proceed, explaining that although the Commission indicated in the Technology Transition Trials Order it was not intending to resolve the legal and policy issues that attend the transition in the context of the trials, AT&T claims INS’ proposal appears to do just that. AT&T said the relevance and the legality of centralized equal access in an all-IP environment are both questionable, and said most significantly, INS’ proposal makes a fundamental policy assumption concerning the nature of compensation for traffic exchange in an all-IP environment that AT&T, for one, certainly does not share. Marashlian and Donahue supports INS’ proposal, saying the dearth of similar service trial applications from other rural and small carriers effectively demonstrates serious problems with the FCC’s phase-out of intercarrier compensation. It suggested the Commission provide such carriers, including CLECs and interconnected VoIP providers, with additional incentive to participate in trials by granting them specific permission to recover their operating, but not capital, costs for IP service trials in interstate access charges, as it is likely smaller participants cannot afford to absorb additional operating costs in existing budgets, absent some temporary relief from the Commission. Replies are due March 31. Public Notice | List of all comments filed

AT&T Discusses IP Numbering Testbed

AT&T met with Office of Strategic Planning and Policy Analysis and Wireline Competition Bureau staff on March 24, 2014, to discuss the numbering testbed workshop scheduled for March 25, 2014. AT&T said it is important to maintain the role of the service provider in number management and common industry infrastructure should be minimized. AT&T suggested the testbed should examine thin registry, distributed database approaches and how SP-customer relationship can be leveraged for identity assurance. AT&T also discussed number assignment/provisioning, basic routing and call number verification.

VCXC Discusses Petition for HD Voice NOI

The Voice Communication Exchange Committee met with FCC Chief Technology Officer Henning Schulzrinne and Wireline Competition Bureau and Office of General Counsel staff on March 24, 2014, to discuss its Petition for an NOI on the migration to HD voice, filed on February 25, 2014. It answered questions from Commission staff about the benefits of addressing HD voice in connection with the transition to all-IP networks and the relationship between the Petition and the technical trials, experiments and numbering testbed research program initiated by the IP Transition Order.

Call Completion

Verizon Discusses Call Completion Data Retention/Reporting Requirements

Verizon met with Wireline Competition Bureau and Enforcement Bureau staff on March 20, 2014, to discuss the data retention and reporting requirements in the Rural Call Completion Order and USTelecom and ITTA’s Petition for Reconsideration. Verizon explained if the Commission was to revise what constitutes an answered call at this late juncture to address the inconsistency noted in Level 3’s January 29, 2014 ex parte, it would force Verizon to make significant revisions to its implementation plan, thus likely requiring an additional implementation period. Verizon further explained that using release cause codes 16 and 31, as prescribed by the Commission in Appendix C, may provide better insights into whether and under what circumstances calls are, or are not, being delivered to the terminating carriers as a result of network issues as opposed to characteristics of calling and called parties. Verizon also discussed why the Commission should grant US Telecom and ITTA’s Petition for Reconsideration and exclude intraLATA interchange/toll traffic from its retention and reporting requirements, explaining Verizon does not object to a requirement to retain and report intraLATA interexchange/toll calls for which a covered provider uses an intermediate carrier.

Open Internet

Vermont PSB Files Comments on Open Internet Order Remand

In addition to comments listed in a previous edition of Washington Watch, the Vermont PSB filed comments on March 24, 2014, in response to the Public Notice, which asked for input on how the Commission should proceed on the Open Internet rules in light of the D.C. Circuit Court’s guidance in the Verizon v. FCC Opinion. The Vermont PSB supports: reinstatement of net neutrality rules, reclassification of broadband as a telecommunications service under Title II‘ treating communications services equally that appear from the consumers’ standpoint to be the same kinds of service, and urged the FCC to consider states as laboratories for experiments for reclassifying broadband as telecommunications service. List of all comments filed

Verizon Suggests FCC Address Open Internet Problems on Case-by-Case Basis

Verizon met with the FCC’s Acting General Counsel and Associate General Counsel on March 20, 2014, to discuss the Open Internet proceeding. It cautioned against applying prescriptive rules targeted at one set of actors, arguing such rules are particularly ill-suited for a dynamic marketplace like the Internet and would likely be outdated and counter-productive as soon as they are adopted. It suggested instead that the Commission address practices that cause demonstrable harm to consumers or competition on a case-by-case basis. Verizon discussed Internet interconnection and cautioned against extending regulation to more parts of the Internet.

Video/Retransmission

Comments Filed on State of Video Programming Competition

Comments were filed on March 21, 2014, on the Notice of Inquiry seeking data, information and comment on the state of competition in the delivery of video programming for the FCC’s Sixteenth Report. NTCA said clarification of the good faith negotiating standard and repeal of non-duplication and syndicated exclusivity rules are imperative. NTCA also suggested the FCC amend its rules so that households served by rural MVPDs may consider and receive lower programming rates from alternative broadcast stations in neighboring areas. WTA urged the FCC to: eliminate the unfair regulatory advantages held by broadcasters, prohibit content owners from engaging in unfair and anticompetitive negotiation and sales practices, allow MVPDs to have more flexibility in delineating which DMA portions of their service area fall in, require broadcasters to ensure their signals actually reach consumers before they must pay retransmission consent fees, and ensure that small rural telco MVPDs are able to obtain content at comparably reasonable prices to their larger national competitors. AT&T said rising content fees threaten to undermine the FCC’s and Congress’s ambitious broadband deployment and adoption objectives, and said absent FCC (or Congressional) action to remove the manufactured and unnecessary regulatory advantages granted to TV broadcasters, there is no end in sight to this spiral of harm to the market for delivery of video programming caused by rising content fees. Replies are due April 21.

Other comments filed by:

Verizon

NCTA

National Association of Broadcasters

CenturyLink

Consumer Electronics Association

TIVO

American Cable Association

AllVid Tech Company Alliance, et al.

USTelecom, et al. Discuss Retransmission Consent

USTelecom, CenturyLink, Consolidated Communications and Shentel met with staff of Chairman Wheeler on March 20, 2014, to express support for a proposal to prohibit two or more of the big four local broadcasters from banding together to jointly negotiate retransmission consent agreements, and to adopt a rebuttable presumption that other station combinations within a market violate the FCC’s good faith negotiating requirement. USTelecom said while it has not taken a formal position on the broader aspects of Shared Services Agreements and Joint Sales Agreements, it encourages the FCC to address the significant problems that occur when MVPDs are required to negotiate retransmission consent rights for multiple local stations as a single package. USTelecom, et al. also met with Clint Odom of Commissioner Rosenworcel’s office to discuss the same issues.

Frontier, CenturyLink, Mercury Strategies Discuss Retransmission Consent

Frontier, CenturyLink, and Mercury Strategies met with Commissioner Rosenworcel’s Policy Director, Commissioner O’Rielly’s Legal Advisor, and Commissioner Clyburn’s Chief of Staff on March 20 and 24, 2014, to discuss retransmission consent issues. They discussed how a broken retransmission consent regime hinders new entrants, particularly when the cost of retransmission consent agreements has increased by nearly 8,600 percent in seven years.

NCTA Discusses Retransmission Consent

NCTA met separately with Chairman Wheeler’s, Commissioner Rosenworcel’s, and Commissioner Pai’s staff on March 19, 2014, to discuss retransmission consent issues, and expressed support for a rule that would prohibit local broadcast stations from engaging in joint negotiations for retransmission consent. NCTA also said joint negotiations by competing broadcasters in a local market have serious anticompetitive effects on consumers, and suggested the FCC clarify the procedures that a broadcaster would be required to follow to overcome the proposed presumption against joint negotiations. NCTA also urged the FCC to narrowly define the circumstances in which two commonly owned broadcast stations may be exempt from the prohibition on joint negotiations.

LNP

Frontier Asks FCC to Consider Mid-Size, Small Carrier Concerns in LNP Administrator Selection

Frontier sent a letter to Chairman Wheeler and the FCC Commissioners on March 21, 2014, to urge the FCC to ensure that the concerns of mid-size carriers like Frontier and thousands of smaller carriers are taken into consideration as part of the LNP Administrator selection process. Frontier said it is particularly troubled this process continues to move forward without input from or consideration of the needs of companies outside of the NAPM membership. Frontier said at a minimum the NPAC must retain the same level of functionality and service currently offered, and this must be provided without the need for investment in an entirely new infrastructure.

Competitive Carriers Association Expresses Concerns With LNP Administrator Selection Process

The Competitive Carriers Association sent a letter to Julie Veach, Chief of the Wireline Competition Bureau, on March 21, 2014, to express concerns with the LNP Administrator selection process. CCA asserted the LNPA selection process does not appear to have taken into account the interests of non-nationwide wireless carriers in matters such as vendor transition costs, support for IP-based numbering systems, and several of the features and functions on which the business models of competitive wireless carriers depend. CCA recommended the FCC and the NANC take into account the interests of smaller wireless carriers in administering the LNPA RFP and, if necessary, amend, modify or reissue the RFP to consider the effects of the transition and administrative costs that competitive carriers will face.

Universal Service

Montana Office of Public Instruction Discusses E-rate, Broadband Connectivity

The Montana Office of Public Instruction spoke with Office of Strategic Planning and Policy Analysis and Wireline Competition Bureau staff on March 12, 2014, to discuss available data on the broadband needs of very small rural schools in Montana, the connection speeds available to those schools and cost of those services. It said Montana has attempted several statewide educational technology surveys in the past with mixed results because many small schools do not have IT staff. It also said it would provide the Commission with data on speed tests, schools that do not have access to any broadband connection and results of a statewide survey on the number of computers available to students.

Today’s News Clips

Apple, Comcast in talks to stream new TV service

By Julian Hattem

The Hill

Apple and Comcast are reportedly discussing a deal for a new streaming television service.

According to The Wall Street Journal report published on Sunday evening, the deal would let users stream live and on-demand TV stored on the Internet, essentially replacing a normal cable box.

Service over the potential arrangement would be separated from regular Internet connections over the so-called “last mile” of connection to a consumer, where heavy traffic can slow down Web speeds. That would theoretically make the streaming video as smooth as it would be for people watching TV via a traditional set-top cable box.

http://thehill.com/blogs/hillicon-valley/technology/201493-report-apple-comcast-in-talks-over-streaming-tv

Editor: Teresa Evert | Assistant Editor: Shawn O’Brien

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