Washington Watch 10/23/2013
| October 23, 2013 | |
Contents
Call Completion
NECA, NTCA Discuss Rural Call Completion Order
NTCA Discusses Rural Call Completion Rules
USTelecom Discusses Approaches to Address Call Completion Problems
American Cable Association Discusses Rural Call Completion Requirements
Sprint Discusses Rural Call Completion Reporting and Retention Issues
Broadband
Senate Subcommittee to Hold Hearing on Broadband Adoption on October 29
USF/ICC Transformation Order
NTUA Wireless Files Second Amendment to Petition for ETC Designation
Universal Service
Replies Filed on IVANS Request for Review of USF Assessment on MPLS, Frame Relay
FCC Releases E-Rate Eligible Services List for 2014
Relay Services
Comments Due December 23 on Proposals to Exempt Certain Relay Providers From Minimum Standards
Call CompletionNECA, NTCA Discuss Rural Call Completion Order NECA and NTCA met with acting Chairwoman Clyburn’s Legal Advisor and Wireline Competition Bureau staff on October 18, 2013, to discuss the proposed data collection, reporting requirements and safe harbors in the pending Order and FNPRM on rural call completion. They stressed that while it is appropriate to exclude tandem providers from the safe harbor "hop count,” the Commission must carefully define tandem providers to avoid unintentionally creating loopholes in the rules, and suggested definitions. They said to the extent the FCC decides to implement safe harbor provisions, carriers should be required not only to meet the two hop limit, but also certify compliance with other best practices outlined in the ATIS handbook. The rural representatives also agreed the Commission should further examine the role of intermediate providers in the rural call completion problem and consider regulatory solutions. They also met with Commissioner Pai’s staff to discuss the same issues. NTCA Discusses Rural Call Completion Rules NTCA spoke via telephone with Commissioner Pai’s Legal Advisor on October 21, 2013, to discuss proposed rules for data collection obligations that would help track and resolve rural call completion problems. NTCA supports the capture of additional data from intermediate providers in addition to originating carriers and VoIP providers. NTCA said it would be premature to impose a date certain for default expiration of the rules and discussed the specific performance metrics that should be included within any reports required under new rules. NTCA noted its concurrence with the recent ex parte by Verizon that as long as reporting entities were required to submit aggregate information consistent with that proposed in Figure 1 of the NPRM and to retain sufficient data on the completion of individual calls to rural locations, there should be no need to retain months of data with respect to individual non-rural calls. USTelecom Discusses Approaches to Address Call Completion Problems USTelecom met with acting Chairwoman Clyburn’s Legal Advisor and Wireline Competition Bureau staff on October 18, 2013, to express concern the proposed Order on rural call completion which is on circulation focuses on extensive industry data collection, saying it may not lead to behavioral changes in the near future that would reduce the percentage of uncompleted calls to rural exchanges. USTelecom urged the FCC to modify the pending Order to create incentives for interexchange carriers to comply with best practices for call completion, and noted the ATIS Intercarrier Call Completion/Termination Handbook identifies potential best practices that may be useful in addressing call completion problems. American Cable Association Discusses Rural Call Completion Requirements ACA met with Legal Advisors to acting Chairwoman Clyburn, Commissioners Pai and Rosenworcel, and Wireline Competition Bureau staff on October 21, 2013, to discuss rural call completion. ACA stated the Commission should not apply new regulations to local service providers, but instead apply regulations to the initial facilities-based long distance carrier who controls routing and has direct access to data on call completion. ACA also argued if the FCC imposes requirements on local service providers, it should exempt those with 100,000 or fewer retail long-distance subscribers. Sprint Discusses Rural Call Completion Reporting and Retention Issues Sprint met with acting Chairwoman Clyburn’s Legal Advisor and Wireline Competition Bureau staff on September 30, 2013, to discuss rural call completion. Sprint said it was unable to confirm there is a widespread problem with rural call completion or to review the RLEC studies which claim to document the existence of such a problem. Sprint claimed the proposed data reporting and retention requirements were onerous and suggested alternatives. Sprint also stated if the FCC did adopt reporting and retention rules it should give affected carriers sufficient time to implement required IT changes and should sunset the rules after a reasonable period of time.BroadbandSenate Subcommittee to Hold Hearing on Broadband Adoption on October 29 The U.S. Senate Committee on Commerce, Science, and Transportation’s Subcommittee on Communications, Technology, and the Internet will hold a hearing on October 29, 2013, on “Broadband Adoption: The Next Mile.” The Subcommittee will examine how to increase broadband adoption in the United States, explore challenges to broadband adoption among various demographic groups and regions, and strategies to overcome those barriers.USF/ICC Transformation OrderNTUA Wireless Files Second Amendment to Petition for ETC Designation NTUA Wireless filed a Second Amendment to its Petition for Designation as an Eligible Telecommunications Carrier on October 17, 2013, for purposes of receiving federal USF support to provide Lifeline service throughout its service area within the boundaries of the Navajo Nation, and for a conditional ETC designation to participate in the Tribal Mobility Fund Phase I Auction for unserved areas of the Navajo Nation.Universal ServiceReplies Filed on IVANS Request for Review of USF Assessment on MPLS, Frame Relay Reply Comments were filed on October 22, 2013, on IVANS’s Request for Review and Petition for Declaratory Ruling of a USAC decision on applying USF assessments to enterprise services using MPLS and Frame Relay. Verizon, Orange Business Services, et al. said it is unclear whether the FCC can determine the appropriate treatment for IVANS’s service here without the benefit of first addressing the MPLS issue more broadly. They said this proceeding is not the context to make broad pronouncements or other determinations that would prejudge the outcome of a rulemaking or otherwise affect other providers. IVANS claimed commenters support its request that a statute of limitations be applied in this case, and said USAC’s demand that IVANS file Forms 499-A back fifteen years ignores all limitations, Commission precedent and practice. IVANS also said MPLS-based services should be assessed, if at all, on a prospective basis only. Public Notice FCC Releases E-Rate Eligible Services List for 2014 The Wireline Competition Bureau issued an Order on October 22, 2013, releasing the 2014 eligible services list for funding the schools and libraries universal service support program, and authorized USAC to open the annual application filing window no earlier than December 23, 2013. The Bureau said it adopted the proposals made in the 2014 ESL Public Notice, with some minor modifications.Relay ServicesComments Due December 23 on Proposals to Exempt Certain Relay Providers From Minimum Standards Comment dates were set on the NPRM issued on September 6, 2013, which seeks comment on proposals to exempt certain iTRS and CTS providers permanently from certain mandatory minimum standards because of the technical infeasibility or inapplicability of these mandatory minimum standards to the services in question. The FCC also seeks comment on whether there is any public interest need to continue to waive various other mandatory minimum standards, given the current state of the technologies pertaining to these standards and in light of recent annual reports submitted by providers reporting the ability to comply with such mandatory minimum standards. Comments are due December 23; replies due January 21.Editor: Teresa Evert | Assistant Editor: Shawn O'Brien |
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