WTA Files Comments on CBOL, Competitive Overlap and Tribal Broadband Factor

On March 8, WTA filed comments on the FCC’s Further Notice of Proposed Rulemaking seeking comment on using reverse auctions to distribute USF support in areas deemed competitive, how to address conversations to broadband-only loops, and providing additional USF support to Tribal areas served by cost-based rate-of-return carriers.

In its comments, WTA opposes the CAF Phase II auction procedures in particular, as well as reverse auction approaches in general, as ways for determining high-cost support for existing broadband service RLEC study areas that are entirely or almost entirely overlapped by alleged unsubsidized competitors.

WTA also recommends that the FCC limit the increase in Consumer Broadband-Only Loop conversions for which a cost-based RLEC may receive the broadband-only portion of CAF-BLS to 10 percent of that carrier’s voice lines as of December 31 of the prior year, with any such limit expiring through an absolute sunset at the earlier of December 31, 2024, or the date on which the contemplated five-year budget review is completed.

Finally, in regards to Tribal areas, WTA proposes that cost-based RLECs and their customers should have access to a Tribal Broadband Factor that adjusts their high-cost support comparable to that provided to RLECs receiving ACAM support.