Possible FCC steps to ease nationwide number portability (NNP) got some support from WTA and full support from Incompas, with a draft order on the agenda for commissioners' July 12 meeting. WTA backs giving CLEC forbearance relief "from all remaining equal access and dialing parity requirements, but opposes elimination or modification of the current N-1 query requirement," which it said was working well, the RLEC group said in filings posted on meetings with aides to Chairman Ajit Pai and Commissioners Mike O'Rielly and Brendan Carr (here, here, here), posted Thursday in docket 17-244. "The contemplated revision of the current N-1 query requirement to allow alternative voluntary arrangements is vastly preferable to outright elimination of it, but is still likely to disrupt the current established system by increasing the possibility of confusion, disputes, and dropped calls." The group's main interest remains that the FCC hold off on wireline NNP until it addresses wireless NNP and a transition to VoIP technology is further along. Incompas backed the draft, saying both actions "represent a necessary modernization of the regulatory regime and lay important groundwork for [NNP]." It "believes that the Commission’s 'middle course' for the N-1 requirement will give competitive providers the flexibility to eliminate routing inefficiencies inherent in this practice while preserving the standardization and uniformity that has contributed to successful number portability at the local level and with nationwide carriers."
Incompas and fiber providers pressed FCC commissioners to reject a USTelecom petition to forbear from requiring large ILECs to provide competitors unbundled wholesale access discounts. The providers "leverage unbundled network elements (UNEs) in key places while they are entering a market and building out their fiber networks," said a filing on a meeting with Commissioner Mike O'Rielly attended by executives of IdeaTek, Sonic Telecommunications, Socket Telecom, Mammoth Networks, First Communications and Access One, posted Tuesday in docket 18-141: If some "experience significant price increases, similar to those they faced" after business data service deregulation, "it could eliminate their ability to provide critical services." Some met Commissioner Brendan Carr (here), an aide to Commissioner Jessica Rosenworcel (here) and Chairman Ajit Pai (see 1807020046). USTelecom and Windstream proposed to delay UNE elimination until February 2021 (see 1806260028).
Incompas and IdeaTek Telecom urged the FCC to dismiss a USTelecom petition for forbearance relief from unbundling discounts and other wholesale regulations, but Windstream and CenturyLink Link backed the petition. IdeaTek CEO Daniel Friesen told FCC Chairman Ajit Pai, a Kansas native, that his company focuses on deploying fiber to the home and small businesses in underserved areas of rural Kansas, with plans to invest "even more significantly" in coming years, said an Incompas filing posted Monday in docket 18-141. "Continued access to unbundled network elements [UNEs] is crucial to his ability to continue to provide, and expand, these vital services in unserved and underserved areas," it said. Friesen "focused on his use of the unbundled dark fiber interoffice transport." Incompas and IdeaTek said other fiber builders need UNE access. Windstream, which jointly proposed a three-year transition for eliminating such duties (see 1806260028), met with Pai and Commissioners Mike O'Rielly and Brendan Carr, said postings Friday (here, here, here): "The proposal represented a reasonable compromise between parties with competing interests and that the transition period specified therein reflected the minimum amount of time necessary." CenturyLink discussed UNE details with Wireline Bureau staffers in response to their questions about the data the company provided to USTelecom in support of its petition, said a posting Monday: "CenturyLink has not discontinued the provision of DSL in any market where it has been made available, and we are not aware of any case in which a carrier customer is utilizing UNEs purchased from CenturyLink to provide DSL in areas where CenturyLink itself does not provide DSL."
Opponents of USTelecom's FCC petition for ILEC wholesale pricing relief have a tough task, particularly in urban areas, more so after the group agreed with previous critic Windstream to propose a delay in eliminating "unbundled network element" discounts until 2021, some told us. Incompas, which represents CLECs using UNEs, said the forbearance petition would cripple the competitors and discourage fiber deployment, including of incumbent telcos. It said the agency should restart a procedural clock and extend comment deadlines. USTelecom said the clock doesn't need to be reset and stood by its analysis that UNE relief would provide consumer and economic benefits.
USTelecom companies, in a deal with member Windstream, changed a proposal so that it would now increase by almost twice the amount of time telcos wouldn't be able to raise prices for unbundled network element connections that competitors can use to reach their own customers. Other telecom companies using such UNEs weren't swayed by the association's changed FCC forbearance proposal posted Friday in docket 18-141, after the past version drew a letter of protest earlier last week to leaders of the Senate Commerce Committee from companies including Windstream. With the changes, Windstream is now on board. Incompas remains concerned, its chief told us.
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.
Many urged the FCC to limit business-oriented caller exposure to Telephone Consumer Protection Act liability, after partial court reversal of a 2015 commission decision targeting unwanted robocalls (see 1803160053). Financial and other corporate interests, including some telecom groups, said the commission should narrow its key definition of "automatic telephone dialing systems" (ATDS) subject to TCPA wireless restrictions and give parties more protection when making inadvertent calls to reassigned numbers. Consumer groups, class-action parties and a few others resisted such pleadings, which they said would further open the floodgates to unwanted robocalls. Comments were included in docket 18-152 on a public notice inviting input on the remand and other TCPA interpretations (see 1805150014).
Many urged the FCC to limit business-oriented caller exposure to Telephone Consumer Protection Act liability, after partial court reversal of a 2015 commission decision targeting unwanted robocalls (see 1803160053). Financial and other corporate interests, including some telecom groups, said the commission should narrow its key definition of "automatic telephone dialing systems" (ATDS) subject to TCPA wireless restrictions and give parties more protection when making inadvertent calls to reassigned numbers. Consumer groups, class-action parties and a few others resisted such pleadings, which they said would further open the floodgates to unwanted robocalls. Comments were included in docket 18-152 on a public notice inviting input on the remand and other TCPA interpretations (see 1805150014).
An FCC proposal for a reassigned-number database drew a fair amount of backing and some resistance, in comments posted Thursday and Friday in docket 17-59 on a March Further NPRM (see 1803220028). Comcast, retailers, financial interests and an electric company group were among those supporting the proposal to create a database of reassigned numbers to help businesses reduce unwanted robocalls and liability under the Telephone Consumer Protection Act. Most telecom entities and some others were more skeptical or less enthusiastic, citing cost and other concerns, and backing market-based solutions and commission actions to address TCPA issues. There was much support for giving callers an effective TCPA liability safe harbor.
An FCC proposal for a reassigned-number database drew a fair amount of backing and some resistance, in comments posted Thursday and Friday in docket 17-59 on a March Further NPRM (see 1803220028). Comcast, retailers, financial interests and an electric company group were among those supporting the proposal to create a database of reassigned numbers to help businesses reduce unwanted robocalls and liability under the Telephone Consumer Protection Act. Most telecom entities and some others were more skeptical or less enthusiastic, citing cost and other concerns, and backing market-based solutions and commission actions to address TCPA issues. There was much support for giving callers an effective TCPA liability safe harbor.