The FCC should keep in mind that wireless carriers are following ...

agency. In comments on a notice of proposed rulemaking on USF rules, CTIA said the FCC shouldn’t impose more restrictive rules for traffic studies, but instead allow carriers to rely on estimates based on “originating/terminating cell sites, NPA-NXX, a combination of these methods, or any other similarly reliable data” in calculating the percentage of calls on their systems that are interstate and thus subject to USF payments. “Wireless carriers… have always struggled with the segregation of revenues and traffic because they provide a service that is inherently mobile.” The association said that in the current world, where the actual location of calls is sometimes not clear, LECs also have difficulty tracking traffic on their systems. “Even some incumbent LECs, who once were able to use originating and terminating area codes to determine the jurisdiction of calls, no longer can segregate traffic precisely, since calls to or from mobile or VoIP numbers cannot necessarily be jurisdictionally classified with precision,” CTIA said. A carrier source said CTIA’s message is that “all flavors of telecom carriers need an ability to make some assumptions here and can’t be held to a 100% standard.”