Four rural telco associations on Friday urged the FCC not to take any further action on inter-carrier compensation (ICC) reform beyond the measures already included in the Connect America Fund order adopted in October. The comments were made in response to a further notice of proposed rulemaking (FNPRM) that was included in the order. Signing the comments were representatives of the National Exchange Carrier Association, the National Telecommunications Cooperative Association, the Organization for the Promotion and Advancement of Small Telecommunications Companies and the Western Telecommunications Alliance.
The per-minute access charges that one carrier pays another for connecting calls to end user customers traditionally have helped keep the cost of phone service affordable in rural areas where the costs of delivering telecommunications services are higher.
“The inter-carrier compensation system has been an essential component of universal service for decades,” argued NTCA Senior Vice President of Policy Michael Romano in an announcement about the joint filing. “Thoughtful measured ICC reform is required to sustain the core statutory mission of universal service, establish a level playing field between smaller and larger carriers and avoid foisting even greater costs on rural consumers and businesses.”
The ICC system has come under attack as the industry transitions to newer alternatives such as VOIP and wireless—and the Connect America Fund order includes a plan for dramatically reducing ICC charges over a period of several years. The order stipulates the creation of a recovery mechanism that would replace some but not all of rural carriers’ lost ICC revenues.
The FNPRM sought comment on additional measures the FCC might take in reforming ICC. But the rural groups are asking the FCC not to make any additional changes to the system at this time.
Specifically the groups asked the FCC to:
- Decline to compel any migration to bill-and-keep for additional switched service rate elements until there is time to evaluate reforms already made and address complexities related to additional reforms
- Cap current transit service rates and then regulate the prices for such services consistent with functionally equivalent transport and tandem switching services
- Ensure well-defined interconnection obligations to minimize further inter-carrier disputes and preclude the imposition of arbitrary and uncontrollable expenses on rural consumers
- Permit the continued use of tariffs as a means of establishing the rates, terms and conditions of network interconnection and traffic exchange
- Recognize that it is premature to consider phase-outs or accelerated reductions in end-user access recovery charges and Connect America Fund ICC support
- Strengthen call signaling rules to address continuing concerns about phantom traffic
“It is essential that the FCC make the effects on rural consumers a primary consideration as they proceed with ICC reform, and that they carefully coordinate those reforms with ongoing high-cost USF reform,” said OPASTCO Vice President of Regulatory Policy and Business Development Stuart Polikoff. “If rural carriers are left without sufficient and predictable sources of network cost recovery, then rural consumers will be left behind in the broadband revolution.”
The rural telco groups’ filing came just one week after the groups submitted comments asking the FCC not to make additional changes to reforms to the Universal Service program that were also outlined in the Connect America Fund order.