ViaSat disputed a Rural Coalition's procedural and substantive criticisms of its proposals for the FCC's Connect America Fund Phase II auction of fixed broadband subsidies (see 1706160018). It noted a suggestion that ViaSat’s input proposals constitute an untimely petition for reconsideration. "To the contrary, those inputs were provided to inform the Commission’s efforts to further define the structures and procedures to be used in [the] upcoming CAF II reverse-auction -- including through the development of an auction procedures public notice," said a filing Thursday in docket 10-90. "The Commission is free to consider ViaSat’s inputs for those purposes, or any others the Commission deems suitable." The filing also contained a white paper by Paul Milgrom of Auctionomics responding to an analysis by David Salant submitted by the Rural Coalition. Milgrom called Salant's analysis "incomplete," with conclusions that "rely on incorrect statements and misleading examples."
Comments are due July 21 and replies July 31 on an NCTA petition for the FCC to reconsider pole-attachment provisions of an order streamlining telco Part 32 accounting rules (see 1706260040), said a summary of a commission public notice published in the Federal Register Thursday. The FR also published two FCC summaries requesting Paperwork Reduction Act comments by Sept. 5 on two information collections: one revising telco reporting requirements under an April business data service order (see 1704200020), and the other revising reporting requirements of covered 911 service providers that must certify implementation of best practices or reasonable alternative measures (see 1312130062 and 1507310010). A summary of another FCC item published in the FR said the Office of Management and Budget approved an information collection from an order giving railroad police access to public safety interoperability channels, and it set Thursday as the effective date of related rules (see 1608230036).
A North American Numbering Council report identified issues and made recommendations to the FCC on possible foreign ownership of interconnected VoIP (i-VoIP) providers seeking direct access to telephone numbering resources. The June 29 report -- which the FCC requested after it received two i-VoIP numbering applications involving foreign ownership -- was made available to us Thursday. NANC said foreign-owned i-VoIP applicants raise many of the same issues as domestic applicants -- on number exhaust, rule enforcement, tax and fee assessment, and security and law enforcement -- many of which "may be adequately covered" under existing law and regulation. But the "use or misuse of [North American Numbering Plan] resources outside of the U.S. and any costs to U.S. consumers would be of significant concern," the report said. "The FCC should consider whether to condition and monitor such activities to prevent any unintended consequences, including fraud where relevant." NANC further recommended the commission "consider vetting non-numbering related concerns (e.g., call completion requirements, Caller ID or anti-spoofing provisions) before granting foreign-owned interconnected VoIP providers authority to obtain numbering resources directly" from administrators. It also recommended foreign-owned i-VoIP numbering applicants follow all the same requirements applied to domestic i-VoIP applicants, including by providing contact information for personnel reachable during U.S. business hours.
A draft FCC slamming and cramming NPRM seems to imply existing rules apply to providers of commercial mobile radio services (CMRS) and interconnected VoIP services, said Public Knowledge Senior Vice President Harold Feld. The draft (see 1706300042) doesn't say whether proposed rules should apply to CMRS and interconnected VoIP services, but it seeks comment on why the commission receives fewer slamming and cramming complaints for those services than it does on legacy telco services. "This implies that the Commission believes that the existing rules apply to CMRS and interconnected VOIP, since the natural answer is 'there are fewer complaints because the Commission’s rules do not expressly cover'" either service, he said in filings posted Wednesday in docket 17-169 on meetings with General Counsel Brendan Carr and aides to Chairman Ajit Pai and Mignon Clyburn. "The current state of the law is complicated," he said, citing agency actions in 2009 and 2012 and calling the draft proposals unclear, particularly for interconnected VoIP. He recommended the FCC clarify that it intends to impose its proposed rules on traditional LEC, CMRS and interconnected VoIP services, or at least solicit comment on whether it should do so. The FCC didn't comment.
Outgoing local number portability administrator Neustar and Golden Gate Capital gave the FCC supplemental information and commitments on the proposed takeover of Neustar by Aerial Investors, a company run by Golden Gate. They were further responding to Wireline Bureau and Office of General Counsel queries regarding the parties' June 12 initial response to an agency information request (see 1706130031). The supplemental information included a list of operating businesses in which investment funds managed or advised by Golden Gate or David Dominik (its sole shareholder) beneficially owns a 5 percent or more interest, plus a letter from Hux Investment committing to the neutrality undertakings of the parties, said a filing posted Monday in docket 99-200.
LECs pressed the FCC not to permit interexchange carriers (IXCs) to use tariffed access services and later seek refunds on the grounds they routed intraMTA (major trading area) wireless traffic using such services to LECs. CenturyLink, Cox Communications, Windstream and Frontier Communications also urged the agency not to take any actions inconsistent with a 2015 U.S. district judge's ruling that resolved "key issues" in a way that upholds their positions (see 1511200070), said their filing posted Monday in docket 14-228 on discussions with an aide to Chairman Ajit Pai and Wireline Bureau staffers. They said the FCC could help by providing further guidance on mechanisms that might be used prospectively to allow IXCs (long-distance providers) "to route commingled traffic through Feature Group D trunks, while treating intraMTA wireless traffic as exempt from access charges," though the need for such new mechanisms has decreased due to the ongoing "phase-out of terminating access charges" and new interconnection arrangements. If the FCC nevertheless seeks to devise such mechanisms, the LECs asked that it be done through a new rulemaking, not in response to their pending declaratory ruling petition. Verizon, Sprint and Level 3 again asked the FCC to deny the LEC petition and "reiterate that the intraMTA rule applies without exception to all intraMTA traffic exchanged between local exchange carriers and wireless carriers, and reaffirm that intraMTA wireless traffic is not subject to access charges -- regardless of whether an intermediary interexchange carrier or other provider is involved in routing, and regardless of the facilities on which the traffic is routed," said a June 12 filing.
The local number portability administrator transition remains on track to meet the "final acceptance date of May 25, 2018," said North American Portability Management in its monthly update Friday in docket 09-109. Telcordia/iconectiv is taking over LNPA duties from Neustar. NAPM said its transition oversight manager, PwC, continues to track transition risks, such as a lack of agreement on "key" requirements preventing certain plans from being finalized, including on "an approach and implementation commitment for LNPA transition contingency rollback"; "determination of appropriate contractual obligations governing contingency rollback and parallel operations"; and "governance of transition decision-making and resolution of potential disputes." The filing also updated the status of iconectiv's efforts to "on-board users to its new NPAC [Number Portability Administration Center] platform."
Telcordia/iconectiv and FP-Icon Holdings vowed to be neutral among industry parties as they supplemented their request that the FCC approve changes to iconectiv's local number portability administrator (LNPA) code of conduct and voting trust, and if necessary, transfer of control. FP plans to become a minority investor in the incoming LNPA, which is owned by Ericsson (see 1705180018). Both iconectiv and FP "made clear" in their request they would remain neutral, and FP's involvement "raises no undue influence concerns," said their letters posted Thursday in docket 09-109. In its letter, FP "confirms that it meets all three prongs of the Commission’s neutrality test and that no telecommunications service provider owns a majority of FP’s debt, or is a source of a majority of FP’s revenues." Iconectiv's letter made a similar representation regarding its compliance with the test.
The FCC is seeking comments by July 24, replies Aug. 22 on its inquiry into broadband competition and deployment in apartment and condo buildings and other multiple tenant environments. A notice of inquiry was released Friday in docket 17-142 after being adopted Thursday (see 1706220036).
Level 3 asked the FCC to reject, or suspend and investigate, AT&T's proposed tariffs for tandem-switched transport access service. "Tariff changes proposed by AT&T are inconsistent with the Commission’s access charge transition rules, the Commission’s order adopting those rules, Section 3(2) of the Communications Act ..., the dictionary definition of 'affiliate,' and sound public policy," said Level 3's petition posted Monday in docket 17-65. Sprint Friday made a similar request regarding AT&T's tariffs and tariffs of CenturyLink, Cincinnati Bell and Verizon (see 1706230058).