header5


ERTA Filings

 

January 9, 2014  –  FCC Comments Opposing Cable Filing

ERTA joined with NTCA, NECA, and WTA in filing comments at the FCC opposing a request from the National Cable & Telecommunications Association (NCTA) to weaken the broadband service requirements their members would need to meet in order to prevent broadband USF from going to price cap ILECs in rural areas they compete in.  The FCC had adopted rules requiring minimum broadband speeds and other service quality objectives.  NCTA members can meet the speed requirement and wanted the FCC to eliminate the other service quality objectives so their members would not have to meet them too.


January 17, 2014  –  FCC Comments on Rural Call Completion 

ERTA joined with NECA, NTCA, and WTA in filing comments at the FCC that responded to a Further Notice of Proposed Rulemaking on rural call completion.  The FCC had asked for comments on several possible solutions to the problem with long distance calls not being sent by intermediate carriers to rural areas to complete.  The comments agreed with some proposals and disagreed with others.  The comments did ask the FCC to use existing rules and authority to put a stop to the problem.



January 20, 2014  –  FCC Reply Comments Opposing Cable Filing

ERTA joined with NTCA, NECA, and WTA in filing reply comments at the FCC opposing a filing made by the Wireless Internet Service Providers Association (WISPA).  WISPA recently filed comments supporting a request from the National Cable & Telecommunications Association (NCTA) for the FCC to weaken the broadband service requirements their members would need to meet in order to prevent broadband USF from going to price cap ILECs in rural areas they compete in.  The associations asked the FCC to disregard WISPA’s request.



February 18, 2014  –  Rural Call Completion – FCC Reply Commen
ts

ERTA joined with NECA, NTCA, and WTA in filing reply comments at the FCC responding to a Further Notice of Proposed Rulemaking on rural call completion.  The FCC had proposed several possible solutions to the problem of long distance calls not being sent by intermediate carriers to rural areas to complete.  These proposals were in addition to rules the FCC announced last year that have not gone into effect yet.  The comments did agree that intermediate carrier registration or certification would help.  The comments also encouraged the FCC to use existing rules and enforcement authority to put a stop to the problem being encountered by customers in both urban and rural areas.



March 5, 2014  –  Opposed to Rural Call Completion Rule Changes

ERTA joined with NECA, NTCA, and WTA in a FCC filing opposing requests that the FCC reconsider its rural call completion rules.  The filing opposed changes requested by Sprint and Transcom (you may recall that Transcom was a partner of Halo Wireless in their access charge scheme).



March 11, 2014  –  FCC Regulatory Fee Fairness

ERTA joined with ITTA and WTA in an Ex Parte meeting with the FCC Chairman’s office to discuss the annual FCC regulatory fee assessment.  A FCC regulatory fee is assessed each year to companies that the FCC regulates, it pays their bills.  Historically the fee was allocated to industries based on the staffing levels at the FCC.  The wireline industry has been assessed its fees based on 1998 staffing levels at the FCC which means that ERTA members have helped provide almost 50% of annual funding even though only 29% of staff in 2012 worked in the Wireline Bureau.  Last year the FCC started a multi-year transition to reallocate the fees.  The meeting requested the FCC to complete the reallocation this year.



March 12, 2014  –  Local Rate Floor Petition

The FCC is scheduled to increase the residential local rate floor in 2014 from the current $14.  ERTA members below the new floor would need to increase rates to be in effect on June 1 to avoid losing high cost loop support.  For many members it is not easy or quick to increase local rates, especially when the projected increase is expected to be large.

ERTA joined with ITTA, NECA, NTCA, USTelecom, and WTA in filing a petition at the FCC asking for more time before local rates are required to increase.  The petition asked the FCC to delay the required date until next January.


April 2, 2014  –  Local Rate Floor

This week ERTA joined with NECA, NTCA, and WTA in filing reply comments at the FCC concerning a proposed increase in the residential rate floor from $14.00 to $20.46.  The FCC asked for comments in response to an association petition asking for a delay.  The associations supported a delay in the effective date from July to January and asked the FCC to delay an increase even longer while it reevaluates its policy to increase rates so dramatically.


April 2, 2014  –  Rural Broadband Experiments

This week ERTA joined with NECA and NTCA in filing comments at the FCC concerning proposed Rural Broadband experiments.  The associations support these experiments as long as the FCC fully considers the impact on existing USF programs and obligations to be carriers of last resort.  Whatever the FCC does should not cause detrimental impacts on members.


April 14, 2014  –  Rural Broadband Experiments

This week ERTA joined with NECA, NTCA, and WTA in filing reply comments at the FCC concerning proposed Rural Broadband experiments.  The associations support experiments and reiterated that RLECs need a right of first refusal if others propose experiments in their service areas.  The associations also support requirements that recipients be designated as ETCs.  Finally the associations stressed that the FCC not let experiments take away from making changes to help modernize existing USF rules.


April 17, 2014  –  ERTA Supports Separations Freeze Extension

This week ERTA joined with NECA, NTCA, ITTA, and WTA in filing comments at the FCC supporting a FCC proposal to extend the separations freeze currently set to expire June 30.  The associations support the FCC’s proposal to extend the freeze for three years instead of the one year extensions they had been offering in the past.  The associations also support the chance for companies that froze category relationships in 2001 to be able to calculate new categories and then freeze them again.


May 13, 2014  –  Response to Rural Call Completion Rule Waivers

ERTA joined with NECA, NTCA, and WTA in comments filed at the FCC in response to petitions seeking waivers of the new rural call completion rules.  Both AT&T Services and Midcontinent Communications filed petitions seeking a waiver of some aspect of the new rules.  While not opposing the waivers the associations reminded the FCC that call completion problems are still ongoing.  The associations stated a waiver should only be granted if the petitioner can prove that customers are not being harmed.


July 8, 2014  –  FCC Regulatory Fee Fairness

ERTA joined with ITTA and Windstream in comments filed at the FCC responding to proposed changes to the annual FCC Regulatory Fee.  For many years wireline companies have paid a majority of regulatory fees based on revenues even though our industry has been dwarfed in size by others.  Wireless companies are charged based on handsets and pay less per year.  We asked the FCC change wireless from a handset assessment to a revenues assessment.  We also asked the FCC to announce annual regulatory fees much earlier in the year than they do so that information could be used in annual tariff filing support if applicable.


 

July 8, 2014  –  FCC Originating VoIP Petition

ERTA joined with NTCA, NECA, ITTA, WTA, Frontier, and Windstream in an Emergency Petition for Waiver filed at the FCC.  The petition asked the FCC to pause the effective date of July 1, 2014 for interstate rates to apply to originating intrastate VoIP traffic until the FCC’s reform catches up and address the large originating revenue losses.


August  8, 2014  –  FCC CAF Comments Filed Today

Along with signing onto comments filed by NECA, NTCA, WTA, and 12 state associations, ERTA also filed the attached set of comments today at the FCC.  The comments were filed in response to several proposals the FCC released in June, these proposals would impact universal service and cost recovery for RLECs across the country.  ERTA filed this short set of comments to add some extra support to the joint comments and to add some additional thoughts.


September 5, 2014  –  Response to Broadband Progress Questions

ERTA joined with NECA, NTCA, and WTA in comments filed in response to questions asked by the FCC.  The FCC asks questions on a regular basis about broadband deployment across the country and this was their tenth set of questions.  The joint comments pointed to results from two recent RLEC surveys showing increases in speeds and customer adoption of services.  The comments also highlighted the fact that FCC policies on universal service and cost recovery will have either a positive or negative impact on RLEC broadband deployment and customer adoption rates.


September 8, 2014  –  Reply Comments on CAF Proposals

ERTA joined with NECA, NTCA, WTA, and 11 state associations in reply comments filed at the FCC.  The reply comments were filed in response to several proposals the FCC released in June that would impact universal service and cost recovery for RLECs across the country.


September 26, 2014  –  Reply Comments on Halo Petition

ERTA filed reply comments at the FCC in support of a petition filed by Wilkes Telephone Membership Corporation.  Wilkes asked the FCC for approval to include amounts billed to and unpaid by Halo in its Base Period Revenues.


November 14, 2014  –  Comments on Part 32 Changes

ERTA joined with NECA, NTCA, and WTA in comments filed at the FCC in response to proposed changes to reform Part 32 rules.   The FCC proposed changes that would impact price cap carriers and asked if the same changes should apply to rate of return carriers too.  The associations support proposed changes to simplify rules and reduce burdens and expenses.  The associations urged further study because many of the proposed changes could have unknown impacts on USF and the NECA Pool if they were applied to rate of return carriers.


December 23, 2014 –  Broadband Testing

ERTA joined with NECA, NTCA, and WTA in comments filed at the FCC about proposed broadband testing rules.  The FCC wants items such as broadband speed and latency to be tested.  The FCC had asked if broadband parameter testing methods adopted for larger price cap carriers should be used for rate-of-return carriers.  The comments pointed out that because testing methods for price cap carriers are not technology neutral and are very burdensome, they would be too burdensome for smaller carriers and should not be adopted.


January 14, 2015  –  Rural Call Completion Reporting Rules

ERTA joined with NTCA, NECA, and WTA in reply comments filed this week with the Office of Management and Budget (OMB).  The FCC had issued rules in 2013 requiring IXCs to report call completion statistics to help the FCC gauge and monitor the rural call completion problem that continues to plague the country.  The rules require OMB approval before they can go into effect and the OMB has not approved the rules.  Several companies let OMB know they opposed the rules.  The associations encouraged OMB to approve the rules.


January 23, 2015  –  Method to Increase Residential Rate Floor

ERTA joined with NTCA, NECA, and WTA in filing an Application for Review (AFR) with the FCC.  Last August the associations had asked the FCC to reconsider the method used to raise the residential benchmark rate floor to $20.46.  The associations suggested that using a method other than calculating an average would be more fair and accurate.  The Wireline Bureau refused to take another look and simply said the associations’ petition was not filed in time.  This AFR was filed in an attempt to hold the Wireline Bureau accountable for its decisions and to evaluate the facts instead of simply dismissing an alternative that was not their idea.


February 10, 2015  –  IntraMTA Comments

ERTA joined with NTCA, NECA, and WTA in filing comments with the FCC on February 9.  The comments supported a petition that had been filed by a group of ILECs and CLECs.  The petition asked the FCC to rule that IXCs should not receive refunds for wireless intraMTA traffic they carried on their networks.  Many ILECs and CLECs have been sued by Sprint and/or Verizon seeking refunds for intraMTA traffic they carried.  The petition was filed in response to these lawsuits.  The associations agreed that refunds should not be allowed.  Even if the FCC rules allow them to terminate this traffic to LECs for free, wireless and IXC companies did nothing in advance to negotiate any agreements.