WTA Supports Tribal Letter of Credit Proposal
On August 19, WTA filed reply comments in support of the National Tribal Telecommunications Association’s (NTTA) proposals to address and reduce the disadvantages imposed upon Tribal governments and Tribally-owned carriers by the FCC’s current and future Letter of Credit requirements.
WTA agrees with NTTA that the unique circumstances of the relatively small number of Tribal governments and Tribally-owned carriers, as well as the severe limitations imposed by LOC requirements upon their ability to obtain the funding needed to deploy broadband, require substantial changes to the LOC and LOC-like rules that may be imposed upon them as a condition of receiving current or future USF support. NTTA has proposed practicable substitutes, such as performance bonds, Tribal government guarantees, and Tribal government resolutions, that can allow Tribal entities to provide reasonable assurances of financial capability and default recovery to the Commission, which WTA supports.