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Associations comment on criteria for filing service discontinuance applications

10.29.15 – NTCA, WTA, ERTA and NECA recently filed comments in the FCC’s IP transition proceeding that proposed criteria to evaluate section 214 service discontinuance applications and notice requirements for copper retirements.

As the associations pointed out, rate-of-return regulated rural carriers traditionally have not been involved in filing section 214 service discontinuance applications before the FCC. As a result of the FCC’s recent Order, RLECs now find themselves wondering whether the FCC will second-guess if network upgrades from TDM to IP technology or from copper to fiber should have been preceded by the filing of an application for authority to discontinue services pursuant to section 214.

The associations suggested the FCC clarify that RLECs would rarely, if ever, need to file section 214 applications simply as a result of making network upgrades and broadband deployments, including associated conversions of local exchange and exchange access services from TDM to IP technology. They said to the extent the FCC does adopt a set of criteria for determining whether planned service changes amount to discontinuance under section 214, it should clarify such criteria are not intended to impose any new or additional service obligations on carriers.

Replies are due November 24.