WTA Files Comments On ACAM Location Adjustment Procedures

On July 19, WTA filed comments in response to the location adjustment procedures portion of the Public Notice released by the Wireline Competition Bureau on June 5, 2019. WTA argued that that there are significant differences between the Connect America Fund Phase II auction process and the Alternative Connect America Cost Model I and II processes, which make it unnecessary and counter-productive to use the CAF Phase II location adjustment procedures. WTA also opposes a reduction in ACAM funding due to an overestimation of serviceable locations in the model since a reduction in locations does not necessarily mean there is a reduction in total cost. Finally, WTA believes that past and future fluctuations in location data make it inefficient for the Commission to set a deadline of 2021 for ACAM recipients to petition for location adjustments.