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NECA files comments in RoR USF Reform proceeding

05.17.16 – NECA recently filed comments on the Further Notice of Proposed Rule Making attached to the FCC’s March 30 Rate-of-Return USF Reform Order, which sought comments on: 

  • rule changes to the FCC’s accounting and affiliate transaction rules for ratemaking and USF support purposes,
  • additional methods for reducing support in competitive areas,
  • increasing support for RoR carriers in tribal lands and unserved areas,
  • measures to improve the operation of the current RoR system, and 
  • streamlining ETC annual reporting requirements. 

NECA said the FCC should clarify what are impermissible expenses going forward, and said any changes should apply on a prospective basis and be clear and simple for carriers, NECA and USAC to administer.  The association also outlined the processes it has developed over years to ensure the smooth operation of the current RoR system. These processes include cost study validations (data reviews and process reviews), focused cost study reviews, USF loop reviews, and a cost issues resolution process. NECA also routinely reconciles all cost studies and loop data with financial data compiled by member companies under the FCC’s Part 32 rules, and reviews data submitted by member average schedule companies relating to billed revenues and other settlement submissions.

The FCC should not implement a general exception to the deemed lawful status of tariffs for inadvertent errors in certifications of company data, NECA suggested. The agency should at most consider implementing an exception applicable only to individual carriers found to have willfully or deliberately misrepresented data to gain financial or other advantages. The tariff and pooling processes NECA administers can be adapted to implement differing Subscriber Line Charges that may be used to recover costs in areas where support is disaggregated as a result of competitive overlaps.