From: Fred R. Goldstein
Date: Mon, Aug 15, 2011
Subject: FCC's latest USF/ICC docket
In case any of you CLECs out there haven't been watching the FCC lately, we are Once Again in a Comment period for the long-running Inter-carrier Compensation and Universal Service dockets. They opened the ICC one in April, 2001 and this is something like the sixth round of comments. USF is just an eternal issue (1996, actually).
The current round is to Comment on a set of questions the FCC raises based upon two recent proposals. The large (price-cap) ILECs have proposed the "ABC Plan", and a group of rural (rate-of-return) ILECs have proposals in a "Joint Letter". Needless to say, both proposals are highly anti-competitive. Of course they propose -- the FCC has already come up with this -- to get rid of competitive USF. Only one carrier gets it for a given location. Just how that is determined is not quite settled though; there is a possibility of a reverse auction (it goes to the one who requests the least subsidy), though they're asking if this should only apply to big ILEC territories or to little ones too. (I for one don't see why the big ILECs, who have gotten rid of most of their rural turf anyway and make huge profits in urban areas, can't continue to average in their rural areas, rather than ask for subsidies.)
They also seem to be back-tracking on inter-carrier compensation. The original idea was to have "unified" ICC, rather than separate rates for local recip, ISP-bound, intra-state access, inter-state access, and mobile. Now they're talking about lowering the inter-state and recip rates, but retaining and even strengthening the classification structure, so billing remains hopelessly complex and the ILECs an argue forever about bills they claim the CLEC owes them.
I've drafted my Comments for a group of CLECs, the Coalition for Rational Universal Service and Intercarrier Reform. Other CLECs might want to get onto the record too, since they FCC doesn't seem to remember that we exist. Comments are due on August 24, Reply Comments a week later. Here's the Public Notice with the FCC's Questions.
If you see something particularly interesting, you might want to point it out so that others can comment on it too.
Fred Goldstein .... fgoldstein "at" ionary.com ...... ionary Consulting
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