NTCA Continues Advocacy Work On USF Reform

In a recent Washington Report from NTCA–The Rural Broadband Association, Sr. Vice President of Policy Michael Romano shared the following update on USF reform (Note: Some links lead to areas of NTCA’s website that require a password):

NTCA–The Rural Broadband Association has conducted a series of ex parte meetings with FCC staff over the last 10 days as the debate over Universal Service Fund (USF) reform continues.

On February 1–2, NTCA and USTelecom held multiple meetings with Chairman Tom Wheeler, Commissioner Michael O’Rielly and Rebekah Goodheart, legal adviser for Commissioner Mignon Clyburn. The group discussed the commission’s USF reform proposals and alternative ideas.

Also on February 2, NTCA and Denny Law, general manager and chief executive officer of Golden West Telecommunications (Wall, S.D.), held separate meetings with Nicholas Degani, legal adviser to Commissioner Ajit Pai; Travis Litman, legal adviser to Commissioner Jessica Rosenworcel; Amy Bender, legal adviser to Commissioner Michael O’Rielly; and Carol Mattey, deputy chief of the Wireline Competition Bureau. During each meeting, the group discussed options for reforming existing universal service support mechanisms to provide standalone broadband support.

NTCA held an additional ex parte meeting February 3 with Stephanie Weiner, legal adviser to Wheeler. During that conversation, the association discussed how processes to identify competitive overlap should operate and the importance of reasonable and sufficient transitions to enable recovery of costs associated with long-term investments consistent with rules in place at the time such investments were made [Washington Report, February 4, 2016].

Then, on February 5, NTCA submitted an ex parte letter to the commission outlining specific proposals for a process for implementation of competitive overlap policies and specific disaggregation options. The proposals included in the letter suggested further details on specific implementation of competitive overlap policies, consistent with prior commission processes, as well as an update to prior NTCA proposals in connection with review of such issues [WashingtonReport, July 23, 2015].

Also on February 5, NTCA and USTelecom met again with Weiner, Goodheart, Bender and Mattey to address potential buildout obligations that would apply to use of future projected USF support. During that conversation, the parties raised questions about how individual carrier buildout obligations would be designed and, in particular, how a carrier’s costs to deploy at least 10/1 broadband to additional locations in its study area might be identified. The associations proposed a structure as a proxy for identifying such costs on a per-loop basis.

On February 10, NTCA and USTelecom filed an amended proposal with respect to how a given rate-of-return-regulated rural local exchange carrier should be allowed to choose on a voluntary basis from among simple alternatives for purposes of any potential buildout commitments that may be adopted in this proceeding. NTCA also submitted further details and explanations February 10 dealing with a density-based disaggregation methodology, as originally included with the aforementioned February 5 filing.