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Blog Washington Watch 04/14/2014

Washington Watch 04/14/2014

April 14, 2014

Back Issues

Contents USF/ICC Transformation Order NTCA Discusses Potential High-Cost Universal Service Reforms Nex-Tech Discusses Standalone Broadband Support, QRA, Reporting Requirements Partner Communications, NTCA Discuss Parent Trap Rule Concerns CenturyLink Discusses Upcoming FNPRM, CAF Phase II Support ACA Responds to CenturyLink Network Engineering Analysis of CAF Phase II Build Cost GCI Suggests Remote Alaska Fund IP Transition INS Discusses Proposed IP Transition Experiment for Centralized Equal Access Open Internet Benton Foundation Files Comments on Open Internet Public Knowledge Discusses Open Internet Remand Universal Service EducationSuperHighway Discusses Modernization of E-rate FCC Adopts Consent Decree in USF Contribution Investigation Broadband FCC to Hold Workshop in Honor of Older Americans Month International FCC Releases 2012 International Traffic Data

USF/ICC Transformation Order

NTCA Discusses Potential High-Cost Universal Service Reforms NTCA met with Chairman Wheeler’s Legal Advisor and Wireline Competition Bureau staff on April 9, 2014, to encourage the FCC to implement updates to the existing high-cost support rules to ensure that predictable and sufficient support is available both for recovery of prior investments consistent with rules in place at the time those investments were made and for the additional future investments that are essential to ensure access by rural consumers to reasonably comparable services at reasonably comparable rates. NTCA also met with Legal Advisors to Commissioners Pai, Rosenworcel, O’Rielly and Clyburn on April 9, 2014, to discuss the same issues and to urge the FCC to proceed with caution on any policies that might be based upon or affected by the purported presence of an unsubsidized competitor.  NTCA also asked the FCC to take action with respect to the local rate floor consistent with recent correspondence.   Nex-Tech Discusses Standalone Broadband Support, QRA, Reporting Requirements Nex-Tech met with Commissioner Rosenworcel’s Legal Advisor on April 8, 2014, to discuss how providing support for loops that are used for standalone broadband services would promote and accelerate the ongoing IP evolution and provide the basis for a CAF that supports broadband-capable networks in all rural areas. It also discussed continuing concerns with the QRA-based caps pending further clarification of the Commission’s recent announcement to eliminate these caps and the underlying model. Nex-Tech also highlighted the cumulative effect of reporting requirements on small service providers, noting it was subject to several hundred reports each year.   Partner Communications, NTCA Discuss Parent Trap Rule Concerns Partner Communications Cooperative and NTCA met with Legal Advisors to Commissioners Rosenworcel, Pai and O’Rielly on April 8, 2014, to discuss Partner’s concerns about the FCC’s parent trap rule. Partner asserted the parent trap rule has created a subset of rural, high-cost exchanges that fall neither under price cap rules nor under rate-of-return rules. Partner stated that these parent trap exchanges should not be left behind as the Commission pursues universal service reform and promotes the provision of broadband services. Partner discussed the possibility of eliminating or suspending the parent trap rule or allowing the use of CAF II funding for such exchanges.   CenturyLink Discusses Upcoming FNPRM, CAF Phase II Support CenturyLink met with Legal Advisors to Chairman Wheeler, and Commissioners Pai, Clyburn, O’Rielly, and Wireline Competition Bureau staff on April 8 - 10, 2014, to discuss the FNPRM on USF high-cost issues on circulation and scheduled to be considered at the FCC’s April Open Meeting.  CenturyLink cautioned against a potential increase in the broadband speed requirement without concurrent changes in other terms for CAF Phase II support, and discussed the need for consistency in the obligations of CAF II recipients and the definition of an unsubsidized broadband competitor that serves to preclude CAF II support in a high-cost area. It also discussed its recently-filed Preliminary Network Engineering Analysis of CAF Phase II Build Cost.   ACA Responds to CenturyLink Network Engineering Analysis of CAF Phase II Build Cost ACA filed a letter on April 11, 2014, responding to CenturyLink’s Preliminary Network Engineering Analysis of CAF Phase II Build Cost, filed on March 31, 2014. ACA asserted there is no proof that CACM 4.1 does not provide adequate support for CenturyLink to build to and serve the eligible unserved locations. ACA claimed CenturyLink’s baseline for Remote Areas Fund locations is incorrect because it was not based on a run of the CAM and because it did not account for census blocks ineligible for CAF Phase II support.   GCI Suggests Remote Alaska Fund GCI filed a letter on April 10, 2014, to suggest the FCC remove Alaska from Mobility Fund Phase II and Tribal Mobility Fund Phase II and establish a separate Remote Alaska Fund into which all Alaska CETC support would migrate over time. GCI suggested the FCC restart the CETC transition for all Alaska non-remote CETC support for fixed lines effective July 1, 2014, and increase the Remote Alaska Cap to offset the phasedown of Alaska non-remote CETC support. GCI also suggested the FCC begin to phase down all remote Alaska support for fixed lines over five years, effective July 1, 2014.

IP Transition

INS Discusses Proposed IP Transition Experiment for Centralized Equal Access Iowa Network Services met with Wireline Competition Bureau staff on April 9, 2014, to discuss additional details regarding the three phases of its proposed IP transition experiment for centralized equal access service. INS said its network needs to be upgraded for the experiment to enable the functionality of its switch, and said other carriers would likely have to do the same to participate. It also clarified that the points of interconnection with the LECs would not need to be moved. INS responded to FCC staff questions on rates INS would charge carriers to participate in the IP CEA experiment, saying it would charge the same rate for IP traffic as it does for TDM traffic.

Open Internet

Benton Foundation Files Comments on Open Internet In addition to comments listed in previous editions of Washington Watch, the Benton Foundation filed comments on April 11, 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 Benton Foundation asserted the FCC’s current proposal to adopt new rules under its Section 706 authority is problematic, stating the D.C. Circuit Court’s restrictions on Section 706 authority prevents the FCC from effectuating the core principles of an Open Network. Benton suggests the FCC strongly consider the merits of protecting the Open Network through Title II reclassification. List of all comments filed   Public Knowledge Discusses Open Internet Remand Public Knowledge met with Legal Advisors to Commissioners Clyburn and Rosenworcel on April 8, 2014, to discuss the Open Internet remand proceeding and comments they submitted in response to the Commission’s Public Notice following the D.C. Circuit Court’s decision in the Verizon v. FCC Opinion. Public Knowledge suggested the Commission refresh the record on Section 706 and Title II authority over broadband, develop a record on peering, interconnection and wholesale access, and properly classify services offered by ISPs to edge service providers as Title II telecommunications services.

Universal Service

EducationSuperHighway Discusses Modernization of E-rate EducationSuperHighway spoke with Wireline Competition Bureau and Office of Strategic Planning and Policy Analysis staff on April 8, 2014, to provide an overview of the results of its E-rate Form 471 Item 21 analysis via a webinar presentation. It also provided a copy of the Item 21 results presentation, an executive summary of the results, and a white paper on E-rate spending.  The Item 21 attachment to the Form 471 asks districts to provide detailed information on the specific services being submitted for reimbursement, including service type, service provider, quantity, and cost.   FCC Adopts Consent Decree in USF Contribution Investigation The FCC’s Enforcement Bureau issued an Order adopting a Consent Decree between it and Vast Communications. The Consent Decree resolves and terminates investigations by the FCC against the carrier for possible violations of certain sections 52.17, 52.32, 54.706, 54.711, 64.604, and 64.1195 of the Commission’s rules governing USF contribution and reporting requirements.  Vast agrees to make a voluntary contribution to the U.S Treasury in the amount of $90,000.

Broadband

FCC to Hold Workshop in Honor of Older Americans Month The FCC announced it will hold a workshop on May 22, 2014, in recognition of Older Americans Month.  The workshop will provide information on online safety, communicating during emergencies, and how broadband and other technologies can be used to facilitate aging in place and telehealth, and will include technology demonstrations.

International

FCC Releases 2012 International Traffic Data The FCC released its 2012 International Telecommunications Data Report on April 11, 2014, on international message telephone, private line and miscellaneous services between the United States and other countries.

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

 

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