WTA and NTCA File Comments on ICC Reform

On October 27, NTCA and WTA filed joint comments in response to the FCC’s proceeding refreshing the record on intercarrier compensation reform. In their comments, the associations respectfully urge the Commission to move cautiously before proceeding with further ICC reforms, acting only after the Commission addresses existing high-cost USF budget shortfalls and collects data on impacts of previous reforms.

If, after taking such steps, the Commission elects to proceed with further ICC reforms, such reforms should: (1) create certainty with respect to network “edge” transport obligations, while protecting rural consumers from adverse impacts on the affordability and quality of the voice and broadband services upon which they rely; (2) ensure that RLECs are not compelled to incur substantial new costs to transport traffic on behalf of other providers; (3) facilitate IP-to- IP interconnection by providing stable and clear “rules of the road” governing all underlying network technologies without artificial distinctions; and (4) provide RLECs with reasonable opportunities to recover authorized revenue requirements via ICC charges and/or other support mechanisms that meet the predictability and sufficiency requirements of the Act.