A coalition of Rural Digital Opportunity Fund Phase I auction winners asked the FCC to waive its letter of credit (LOC) rules for RDOF, meeting separately with aides to Chairwoman Jessica Rosenworcel and Commissioners Brendan Carr, Geoffrey Starks and Anna Gomez (see 2311140077). The group proposed limiting LOCs to one year of support similar to NTIA's waiver for the broadband, equity, access and deployment program. "Maintaining the LOC while having to absorb the huge construction cost increases that RDOF winners are encountering exacerbates the significant financial burden RDOF Winners are already facing," the coalition said in a filing posted Thursday in docket 19-126.

NTCA raised concerns about the FCC's proposed decision to grant ISPs forbearance from USF contributions under Communications Act section 254(d), holding separate meetings with aides to Commissioners Geoffrey Starks and Anna Gomez (see 2404050068). The FCC "would be on sounder legal footing" if it issued a Further NPRM "to consider how and whether to reform universal service contributions," the group said in an ex parte filing posted Thursday in docket 23-320. Forbearance is "a blunt instrument where a lighter touch that has similar effect would be far more appropriate," NTCA said, asking the commission to "adopt a procedural approach that will at once enable more careful consideration of the merits of contribution reforms and potential impacts."

Advocacy groups urged the FCC to take several steps to revise incarcerated people's communications services (IPCS). The United Church of Christ Media Justice Ministry, Worth Rises, the National Consumer Law Center, the Leadership Conference on Civil and Human Rights, Amalgamated Policy Research, Public Knowledge and the Wright Petitioners told Wireline Bureau and Consumer and Governmental Affairs Bureau staff that a model carrier approach would best fulfill the Martha Wright-Reed Just and Reasonable Communications Act's requirement to use "industry-wide average costs" to calculate new rates. The model carrier approach "is in the public interest" and "avoids subsidizing inefficient carriers and unnecessary costs," the groups said in a filing posted Tuesday in docket 23-62. The coalition asked the commission to preempt site commissions and allow states to cap intrastate IPCS rates lower than the FCC's rates. The groups also sought a 30-day transition period for providers to implement the new rates.

Incompas pushed back on CTIA's claims regarding some FCC-proposed rules for call labeling and blocking in a meeting with Consumer and Governmental Affairs Bureau staff (see 2404080034). The group noted that the "lack of transparency into the call labeling and presentation practices that carriers and their analytics providers deploy is an increasing problem." FCC oversight of call labeling and blocking is necessary to ensure that "pay-to-play" business models "do not stymie nondiscriminatory, competitively neutral standardized solutions," Incompas said in an ex parte filing posted Monday in docket 17-59. "Without greater accountability and transparency, competitive providers, their customers and end-users will be significantly disadvantaged," the group warned, asking the FCC to also "standardize the inclusion of rich call data."

A coalition of more than 50 small ISPs asked the FCC to investigate the "grossly inaccurate broadband speeds" reported by LTD Broadband to the commission's broadband data collection (BDC). The commission's recent enforcement action against Ohio's Jefferson County Cable TV for incorrect broadband location reporting "should serve as ample precedent for initiating enforcement actions against more egregious data reporting which is currently on the record," said the Accurate Broadband Data Alliance in an ex parte filing posted Monday in docket 19-195 (see 2403180063). The group argued that LTD and its subsidiary, GigFire, "continue to game the BDC" by "impugning the veracity of entities daring to file BDC challenges against the faulty data."

The FCC Consumer and Governmental Affairs Bureau extended until Dec. 31 Hamilton Relay's conditional certification to provide fully automatic IP captioned telephone service (see 2204200052). The bureau said in an order Friday in docket 03-123 that the FCC "requires additional time to evaluate Hamilton's application for full certification."

Blue Stream Fiber raised questions about the "timing and need" of the FCC's proposed ban on bulk billing arrangements for broadband in apartment buildings in meetings with Wireline Bureau staff, with an aide to Chairwoman Jessica Rosenworcel, and with an aide to Commissioner Anna Gomez (see 2403050069). The company said in a filing posted Thursday in docket 17-142 that bulk billing "only works to provide high quality internet services at affordable prices where all residents in a community share the cost associated with providing the service." Blue Stream Fiber also asked the FCC to seek comment on "the benefits of bulk billing arrangements" rather than "tentatively conclude that they should be broadly banned."

The Bank Policy Institute raised "serious concerns" about the FCC's use of the Weiss Bank's safety rating for programs that require support recipients to obtain a letter of credit. "By relying on Weiss ratings in its regulations, the FCC effectively deputizes the organization to determine which banks may and may not provide letters of credit to carriers that participate in FCC programs," the group said, but Weiss "does not demonstrate the qualifications necessary for this responsibility." The group said in a letter posted Thursday in docket 17-182 that the Weiss rating system's methodology is "opaque" and the organization "appears to lack sufficient resources to adequately assess all of the institutions it purports to rate." It asked the FCC to eliminate the requirement, noting Weiss "regularly promotes crypto assets as an alternative to traditional banks on its official website."

Hotwire Communications asked the FCC to abandon its proposal for banning bulk billing arrangements between ISPs and apartment buildings (see 2403050069). Hotwire noted in an ex parte filing posted Tuesday in docket 17-142 that it discussed with Wireline Bureau staff challenges consumers faced when they attempted to apply their affordable connectivity program benefit to a service offered through bulk billing. The company said the difficulties are due to "flaws in the ACP rules," suggesting the FCC amend its rules to "facilitate greater use of ACP discounts where bulk billing arrangements are present" should the program be replenished. Hotwire also asked the commission to consider the item during a commissioners' meeting. "This would enable the public to review and provide input on the draft rulemaking for three weeks prior to the vote," Hotwire said.

An FCC order modifying certain administrative and reporting requirements for the USF high-cost program takes effect May 10, said a notice for Wednesday's Federal Register. Commissioners adopted the item in October (see 2310190056).