WTA Recommends FCC Continue Continuing System of Permissive, Rather than Mandatory Detariffing

In a filing today in response to the FCC’s NPRM on tariffing obligations, WTA urged the FCC not to adopt the proposed mandatory legacy BDS detariffing regime. The harms from such a policy will outweigh any possible benefits, mainly because many of WTA’s members are part of a tariff pool administered by the National Exchange Carrier Association (NECA). This pooling provides for risk sharing among the small telephone companies that make up the pool. In addition, the pooling provides for much greater efficiency in the companies’ setting of rates and prices by providing scale economies for many of the necessary regulatory and business functions. Continuing the current system of permissive, rather than mandatory detariffing, will allow the companies to assess the trade-off of the lower costs and lower risk under the current pooled tariffs versus the possible benefit of greater flexibility to respond to competition with voluntary detariffing.