The FCC should ensure no barriers exist in...

State Utility Consumer Advocates (NASUCA) said in a reply (http://bit.ly/MYEx8C) to a Nov. 8 FCC Further NPRM (http://bit.ly/1k7cjXc) on rural call completion. NASUCA echoed comments by NARUC (http://bit.ly/1jxcecz) that the FCC should codify prohibitions on blocking, choking or restricting traffic, even as appeals of the USF reform order are pending at the 10th U.S. Circuit Court of Appeals. NASUCA also said intermediate providers should register and certify they will follow industry standards, as well as state and FCC rules, and that no additional safe harbors reducing obligations to collect and retain data should be created. NASUCA objected to Verizon’s reply (http://bit.ly/1mF9j68), which backed adjusting safe-harbor reporting requirements to exempt minimal volumes of traffic for overflow purposes, and to increase the number of intermediate carriers allowed to be used under the safe-harbor provision from one to two. “Verizon’s complaints about ’the already high burdens of complying with the Order’ overlook the tremendous burdens placed on consumers by call completion failures,” NASUCA said. “Requirements that ease consumers’ burdens by preventing call completion failures are reasonable solutions to this industry-created problem.” The FCC November order applied recording, retention, and reporting requirements to large long-distance voice providers, defined as those that make the initial long-distance call path choice for more than 100,000 domestic retail subscriber lines.