WTA Responds to FCC on Intercarrier Compensation and IP Transition

Today, WTA expressed concerns that the FCC’s proposal to move to a full bill-and-keep system, along with eliminating Telephone Access Charges and phasing out CAF-ICC, support would adversely affect customers in rural areas by increasing their rates unless a sufficient support mechanism and a reasonable transition period is provided.

WTA also argued that the FCC’s contention that these support mechanisms are the primary factors delaying the IP transition is unwarranted. In addition, two of the major barriers to WTA member companies not completely moving to an all-IP network is the necessity to connect to Public Safety Answering Points using TDM and large ILECs insisting on small RLECs connecting to their access tandems via TDM.

WTA recommended that any transition to bill-and-keep be accomplished over a sufficiently long period of time to allow carriers to adopt, and accompanied by direct subsidies to ensure that rates in rural areas remain comparable to rates and services in urban areas. WTA also suggested setting a tiered deadline by which all carriers must transition to IP, whereby the largest carriers would complete their transition to IP networks within three years, mid-sized carriers would complete the network upgrades within five years, and small carriers would have up to seven years to transition to IP networks.  The FCC also indicated that it was hopeful there could be an industry consensus for moving forward, and suggested it might convene an industry study group.  WTA looks forward to representing its members in that process.