• Connect America Fund
• A National Broadband Plan for Our Future
• Establishing Just and Reasonable Rates for Local Exchange Carriers
• High-Cost Universal Service Support
• Developing an Unified Intercarrier Compensation Regime

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In most parts of our American life, we are governed by rules and regulations, and there are consequences to our actions. If you enter a grocery store, you have to pay for your cart of groceries before you take them to the trunk of your car. If you enter a car dealership, the owner expects you to pay or make arrangements to pay before you are given the keys and allowed to drive away. read more ...

In light of the Commission’s proposals to limit the recovery of rural carrier corporate operations expenses from USF in its February, 2011 Notice, it is a reasonable expectation that any new data collection efforts by the FCC should be coordinated. read more ...

There has been a major transition in services being billed since the inception of the separations freeze using data from the year 2000. In the year 2000, rate of return local exchange carriers provided a significant amount of toll billing for interexchange carriers, and provided almost no billing for DSL services to end users. read more ...

The Commission must be cautious to recognize the interdependence that wireless carriers have on wireline networks. The mobility provider depends on the wireline provider in its call completion and transport architecture. Current wireless, VoIP, and satellite networks require a connection to land line infrastructure to provide full functionality. read more ...

For rural areas to realize their share of the vision of the National Broadband Plan, it will be necessary for broadband networks to be constructed in anticipation of future broadband demand. Given the high fixed costs of constructing broadband networks, once built, they are not likely to be replaced, especially in rural areas that are unserved today. read more ...

We recognize that the Commission desires comprehensive USF reform and seeks to redirect legacy USF support to supporting broadband infrastructure deployment in unserved areas, or to areas “that depend on universal service support for the maintenance of existing broadband service.” We respectfully submit that a prudent public policy outcome will fully recognize providing this type of maintenance support to rural carriers in order to maintain the cornerstone of rural broadband infrastructure. read more ...

• SummarySorted.pdf - This file contains a summary of the frozen per loop impacts for the three mechanisms sorted by line size and impact per line.
• Combined_HCL_LSS_ICLS.pdf - This file contains the same information as the SummarySoreted.pdf  file but organized according to state in the same manner as the HC-01 and HC-05.
• Study_Area_HCL_LSS_ICLS_Sorted.pdf - This file contains a summary of the three mechanisms sorted by line size and impact per line.  This is the file used to provide the brief analysis in the write up.
• Study_Area_Summary_HCL_LSS_ICLS.pdf - This file contains the same information as the Study_Area_HCL_LSS_ICLS_Sorted.pdf file but organized according to state in the same manner as the HC-01 and HC-05.

 

The Federal Communications Commission (Commission) has long recognized the importance of consumers being able to keep their telephone numbers when they switch telephone service providers.   In this Report and Order (Order), we ensure that service providers can accomplish these transfers quickly. read more ...

Non-rural carriers include mostly large, publicly traded companies with hardwired access to national and international capital markets that do not depend on universal service support for a significant portion of their revenue streams. Rural carriers have fewer options for access to capital, with relatively higher infrastructure costs on a per customer basis, creating the need for a “sufficient” source of universal service funding. read more ...

We concur with Commissioner McDowell that the only way the Internet can work is if engineers are allowed to discriminate among different types of traffic by allowing, for instance, video bytes to go ahead of e-mail bytes: “Discriminatory conduct, in the network management context, does not necessarily mean anti-competitive conduct. The public interest would be better served if the debate would focus more on this important distinction.” read more ...