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RURAL AND WIRELESS CARRIERS DEBATE NEED FOR EQUAL ACCESS

Comments to the FCC on the “definition” of universal service, one of the several universal service proceedings now under way, turned into a debate on whether wireless rural competitors should be required to offer equal access in order to get universal service support. “The debate is not really about equal access,” Western Wireless said in its comments: “The real debate here is about whether universal service support can coexist with intermodal competition.” Equal access was a 1980s requirement that local telephone companies had to provide connections to any long distance companies -- in other words, giving customers the ability to preselect long distance companies to handle their calls automatically.

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Rural telcos represented by the National Telecom Co-op Assn. (NTCA), OPASTCO and others argued in April 14 comments that the FCC should require wireless carriers to provide equal access before they could receive support from the universal service fund. NTCA said “a modern equal access” requirement would give consumers the ability to shop for competitive long distance providers on both their landline and their wireless phones. There’s nothing in the Telecom Act that bars the FCC from adding equal access to the definition of universal service and nothing that says the Commission must use universal service funding to encourage competition in rural areas, NTCA said.

Western Wireless argued that the Act didn’t authorize the FCC to impose equal access requirements on wireless carriers. “Adding equal access to the definition would violate the principle of competitive neutrality” and would harm consumers by imposing such “significant costs” on wireless carriers that they wouldn’t be able to compete effectively, Western Wireless said. “In most areas, such a requirement would deprive rural consumers of the choice of an alternative universal service provider,” it said. Those costs would include “order management, activations, usage rating, customer care, technical support and reporting,” the company said. Such a requirement also would impair wireless carriers’ ability to offer consumers “the popular calling plans that incorporate bundled local and long distance minutes at low rates as part of a supported universal service offering.”

OPASTCO said “there is nothing to indicate that adding equal access to the definition would reduce competition from [commercial wireless] providers in rural and high-cost areas.” It said most wireless providers that sought eligible telecom carrier (ETC) designation in rural areas had “already deployed infrastructure and have been successfully providing service without the aid of universal service support.” OPASTCO said wireless carriers could continue to offer service in rural areas without ETC designation if they didn’t want to provide equal access. It argued that when a wireless provider sought ETC designation “it is holding itself out as a substitute for the services offered by a LEC” and since Congress required all LECs to provide equal access, all ETCs should be required to provide it.

Sprint urged the Commission not to add more USF- supported services because “any additions to the list of services supported by universal service funds will only increase the fund beyond a sustainable level.” As for requiring carriers to provide equal access, Sprint said such action would violate the Telecom Act and even if it didn’t “it would place an undue burden on one segment of the industry, wireless service providers, and does not foster universal service goals.”

The Fla. PSC said the Federal-State Joint Board on Universal Service was unable to come to agreement on the equal access issue and said it agreed with those who thought equal access shouldn’t be included in the definition. The Fla. PSC said the Telecom Act gave 4 criteria that must be met to expand the current list of 8 “supported services.” The 8 include such things as operator services, voice grade access to the public network, single party service. The PSC warned that making a new service eligible for universal service support “may have unintended consequences in some rural, high-cost areas that need support the most… Specifically, if an ETC has not upgraded its network to provide a newly supported service, it would not receive any support.” The PSC agreed with those who said the Telecom Act barred equal access requirements for wireless carriers. It added that while there weren’t any wireless ETCs in Fla., “we believe that the addition of equal access as a required service for all ETCs would not serve the public interest because it would likely reduce competition in rural and high- cost areas.” The agency said the problem boiled down to the fact that: “If equal access were added to the definition of supported services, [commercial wireless] carriers would be ineligible to receive universal service support unless they provided equal access. As a result, they might choose not to provide services competitive with wireline local exchange service in rural and high-cost areas.”