Work ‘Immediately’ on Phantom Traffic, Traffic Pumping, But ‘Careful Transitions’ Needed for USF, USTelecom Says
The FCC should “immediately” tackle phantom traffic and traffic pumping but should provide “careful transitions” as it reforms the Universal Service Fund and intercarrier compensation regimes with “great care,” USTelecom said in comments posted to dockets 10-90, 09-51, 07-135, 05-337, 01-92, 96-45 and 03-109. “Until targeted universal service support provides sufficient explicit funding for networks in high-cost areas, any mandated rate reductions must be coupled with a reasonable opportunity for providers to replace the revenues lost … through a combination of increased retail rate flexibility and a supplement fund,” USTelecom said. USTelecom is leading talks to try to come up with an industry-wide reform. But the commission has made clear that it wants to move to orders on USF and intercarrier comp distribution by the end of the summer. “Intercarrier compensation reform must be accomplished by providing opportunities for carriers to replace lost revenues in order to allow the continuation of support for networks, particularly those in high-cost rural areas,” USTelecom said in Monday’s comments.
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But the commission must move quickly on “sweeping” reforms, said AT&T Vice President Hank Hulquist on his company’s website. “The overriding goal of the FCC’s National Broadband Plan -- to ensure that all Americans have access to, and use, broadband services -- will not be achieved unless sweeping reforms of USF and ICC are enacted,” Hultquist said: “The business model upon which the current universal service system is built is dying before our very eyes. More than a quarter of U.S. households have ‘cut the cord’ and abandoned last century’s technology altogether. Consumers are dropping traditional phone company POTS services -- legacy, circuit-switched, wireline phones lines -- at an astonishing rate, around 10% each year. In fact, approximately 700,000 lines are lost to newer technologies every month. With this historic transformation, we need similarly historic changes in our regulatory model."
But CompTel said the commission ought to focus on contribution reform first. “One recurring theme that appears throughout the NPRM is the Commission’s desire to accelerate the transition to IP technology,” CompTel said. “Reforming intercarrier compensation is not going to accomplish that.” Instead, the FCC “must act affirmatively to safeguard the rights of requesting carriers to interconnect with one another as technology evolves by clarifying that IP-to-IP interconnection is governed by Sections 251 and 252 of the [Telecom] Act,” CompTel said. The FCC also ought to fix its own management of the current system before trying to transform USF to a broadband fund, CompTel said. “Over the years, the [Government Accountability Office] repeatedly has told the Commission what it needs to do to improve the internal controls and management of the fund and increase accountability for the use of the funds, but the Commission has yet to take effective action,” CompTel said in its comments.
CompTel also argued that the commission can’t move USF to a broadband fund because USF is only for telecom services, not information services. It also urged the commission to classify VoIP traffic as a telecom service and to avoid a “bill and keep” mandate. “Individual carriers’ business plans will dictate the timing of network upgrades, but the Commission should ensure that the transition is not stymied by interconnection roadblocks unilaterally established by the Regional Bell Operating Companies,” CompTel said.
Lawyers for the Shone-Bannock Tribes and for Smith, Bagley -- a mobile carrier that operates in Native American reservations and areas -- each urged the commission to provide special exemptions to any USF and intercarrier reforms, especially on matters such as a cap and deployment schedules, Smith, Bagley said in its comments.
Internet2, a nonprofit group made up of universities, government agencies and labs as well as companies that serve them, urged the commission requiring any new broadband subsidy recipients “connect to community anchors in the relevant geographic area.”