RLEC Replies Resist Push to Scrap Remaining FCC Rural Call Completion Data Duties

Rural telcos opposed FCC elimination of the two remaining rural call completion duties of providers covered by a 2013 RCC order, a proposal that received much industry support in initial comments (see 1806050043). The data recording and retention rules helped reduce the number of "dropped and otherwise deliberately non-completed calls," replied WTA this week in docket 13-39. "Sunsetting the rules without a suitable alternative monitoring and enforcement mechanism in place will only undercut the previous progress." NTCA (here), the South Dakota Telecommunications Association (here) and Alarm Industry Communications Committee (here) also filed opposition. NTCA urged the FCC to broadly define "intermediate providers" whose RCC performance would be subject to covered provider monitoring and oversight under an April order. NCTA also opposed and ITTA backed a recent USTelecom request that the FCC stay the monitoring rule (see 1806130086). USTelecom (here), Verizon (here) and ATIS (here) backed eliminating the two rules. Verizon and ATIS opposed mandating industry best practices, with Verizon urging flexible intermediate-provider service-quality standards and full implementation of the Improving Rural Call Quality and Reliability Act and all RCC rules before compliance deadlines. USTelecom sought a broad intermediate-provider definition. NCTA said covered providers should have to only "monitor the performance and registration status of intermediate providers with which they have a contractual relationship." The American Cable Association said a covered-provider definition should be retained, particularly a 100,000-subscriber line threshold. Incompas urged a "flexible" approach to implementing the new law and consideration of "the role that access arbitrage" plays. West Telecom Services said the FCC shouldn't "micromanage" intermediate-provider duties and proposed eliminating a safe harbor's "two-hop cap on use of intermediate providers" by covered providers. HD Tandem backed "transparency mechanisms" to allow regulators "to root out illegal cost shifting or other routing behaviors that impair high-quality call completion." Inteliquent endorsed mandating best-practice compliance.