CTIA Asks FCC to Rethink Regulatory Fee Calculations
CTIA is joining Cingular and others in asking the FCC to back away from the use of Numbering Resource Utilization/Forecast (NRUF) data for assessing regulatory fees, in favor of subscriber counts that follow numbers in SEC filings. The use of the NRUF numbers has caused major headaches for carriers and raised questions at the SEC, carrier sources said. In a separate filing, all national carriers except Verizon Wireless supported Cingular.
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“They've tried to streamline the rules, which has had the unintended effect of creating new burdens,” CTIA Senior Vp Michael Altschul told us Tues.: “It’s a signal to carriers that the FCC really doesn’t understand its own data or how its order imposes burdens on carriers.” Altschul said using the NRUF data, intended for an entirely different purpose, is “sort of like using the football team that wins the Super Bowl to predict the stock market.”
NRUF was created to keep track of area code exhaustion. Using NRUF as a starting point, FCC tracks subscriber numbers through assigned blocks. But not all numbers are actually used by subscribers since some numbers are otherwise in use or are being withheld for various reasons. Altschul said FCC’s solution was cumbersome. Carriers have to track each number and list those not being used by a subscriber. For example, in a block of 10,000 numbers Verizon Wireless would have to list all the numbers previously assigned to another carrier or withheld for use in a company PBX system or being “aged” for use with another subscriber.
Cingular filed a petition for reconsideration Aug. 6, warning the FCC: “It is arbitrary, capricious, and unreasonable for the Commission to adopt a regulatory fee assessment methodology that the Commission acknowledges is inaccurate.” Cingular noted that it had 24 million cellular/PCS subscribers at the end of 2003: “It would be a daunting, if not impossible, task to track discrepancies on a number-by-number basis,” the carrier said.
“As Cingular has emphasized, the Commission’s decision to compel carriers to reconcile the inconsistencies between the NRUF data and actual subscriber records is unduly arduous and wasteful of Commission resources,” CTIA said. “CTIA’s proposal to permit carriers to employ SEC reported subscriber numbers would correct the reporting problem that the NRUF data presents while insuring accurate reports.” CTIA added that the FCC should have every confidence that the numbers reported to the SEC are accurate “because carriers and the SEC pay close attention to the subscriber counts they report.”