The NTCA–The Rural Broadband Association filed comments with the Federal Communications Commission (FCC) in response to the commission’s Notice of Proposed Rulemaking (NPRM) aimed at changing rules to accelerate the transition to all-IP networks.
The filing raises three points regarding the impact of the change in rules on rural local exchange carriers (RLECs).
The NTCA’s first point focuses on the impact on rural providers of the NPRM’s proposed shift to a “full bill-and-keep framework” — in which networks terminate each other’s calls at no charge — for intercarrier compensation, interexchange service, and end-user charges.
“Rather than eliminate this vital funding, the Commission should acknowledge that this funding is the key to completing the ongoing work to transition from legacy networks to all IP,” the filing reads. “To do so, and to allow small and rural carriers to complete their transitions, NTCA urges the Commission to retain the existing CAF ICC support mechanism and indeed rechristen it as a new IP-transition fund.”
The second point in the comments is that the FCC must “take great care in addressing the ‘network edge,’” because it is the point at which a carrier delivers its traffic. The comments note that the point’s location can impact the costs to rural providers.
The third point recommends that the FCC “abandon its proposal to eliminate ex ante pricing regulation and tariffing of Telephone Access Charges.” The organization suggests that doing so would destabilize RLECs. The NTCA points out that the FCC has sought comments on this twice, and a “diverse cross section of the industry” concluded that they remain critical for RLECs.
In March, the FCC reached what chairman Brendan Carr said at the time was “a good old-fashioned, bipartisan, collaborative compromise” on ways to streamline the transition from copper to all-IP networks.
