2008 Legal and Regulatory Filings

December 2008

ITTA Urges Broadband Component to Economic Stimulus Package: In a letter to Hill leadership, ITTA urged Congress to include broadband provisions in economic stimulus packages to speed deployment and associated benefits.

ITTA Presents Hill Leadership with Comprehensive Approach to National Broadband: In a letter to House and Senate leadership, ITTA recommended a mix of grants, tax incentives, and other measures intended to ensure national deployment of broadband at affordable rates for all citizens.

ITTA Discusses Broadband, Telecom Policy with Obama Transition Team: ITTA met with the transition team of President-Elect Barack Obama to discuss broadband and telecom policy, including efforts to expand broadband deployment throughout rural America.

November 2008

ITTA Files Comprehensive ICC, USF Reform Proposals: Responding to an FCC rulemaking notice, ITTA filed a comprehensive plan for intercarrier compensation and Universal Service Fund reform that will target support to areas where it is needed most, facilitate broadband deployment, and end opportunities for arbitrage.

ITTA Requests Deferral of Form 477 Filing Deadline: Noting the lack of FCC instructions for new broadband data filing requirements, ITTA requested the FCC to defer the filing deadline until after the instructions are released and carriers have sufficient time to implement new processes.

October 2008

ITTA Delivers Rural Network Deployment Info to FCC: ITTA commented on rural network deployment characteristics, describing the cost and use of softswitches.

ITTA Urges FCC to Permit Public Inspection of Proposed ICC Rules: Citing potential adverse impacts on rural telecom and broadband deployment, ITTA urged the FCC to enable public inspection of proposed rules for intercarrier compensation. The ITTA motion capped a series of meetings with Federal regulators. For copies of additional presentations, please contact jseidemann@itta.us.
Notice of Ex Parte
Presentation

ITTA Supports Regulatory Flexibility: In filed comments, ITTA supported a petition of CenturyTel to convert its rate-of-return properties to price cap regulation.

ITTA Advocates Balanced and Equitable ICC Reform: Meeting with FCC staff and legal advisors, ITTA presented a mid-size carrier plan for intercarrier compensation reform.
Additional Presentation

September 2008

ITTA Discusses Intercarrier Comp Plan with FCC: ITTA met with FCC staff to describe the mid-size carriers' plan for intercarrier compensation reform.
Presentation

ITTA Calls for Parity in Regulatory Fee Payments: Noting changes in the marketplace and FCC activity, ITTA proposed a framework for calculating regulatory fees that will provide equitable and reasonable treatment for carriers and consumers.

ITTA Files Comprehensive Intercarrier Compensation Proposal: Rejecting "one size fits all" solutions that fail to provide adequate support for networks serving rural America, ITTA proposed a comprehensive plan for intercarrier compensation reform.
Comprehensive Plan

ITTA Comments on Broadband Deployment: Opposing a petition for reconsideration of the FCC's broadband deployment findings, ITTA noted the achivements of its member companies, the nature of broadband deployment, and factors that can determine deployment levels.

August 2008

ITTA Submits Overview of Need for Intercarrier Compensation Reform: Describing the unique needs of mid-sized carriers serving rural America, ITTA proposed parameters for the FCC's consideration of intercarrier compensation reform. ITTA separately commented on separate proposals submitted by Embarq and others.
Embarq Proposal
AT&T Proposal

ITTA Supports Reasonable Broadband Data Collections: ITTA cited industry practice and carrier costs in urging the FCC to adopt only reasonable types of data relating to broadband deployment.

July 2008

ITTA Calls for Effective Network Management Practices: Citing the shared- infrastructure basis of broadband networks and rapidly evolving technology, ITTA urged the FCC to refrain from imposing narrow and specific network management regulations that may become outdated as technology evolves rapidly.

ITTA Supports Rational Broadband Mapping: In filed comments, ITTA cautioned that mapping efforts should not consume resources that would be better spent on actual broadband deployment.

ITTA Calls for Equitable Assessment of Regulatory Fees: Noting the evolution of the telecommunications marketplace, ITTA recommended the FCC to include providers of similar voice services in a single group when assessing regulatory fees responsibilities. ITTA submitted this chart in support of its position.
Ex Parte Presentation 1
Ex Parte Presentation 2

ITTA Urges Regulatory Parity and Payment for Use of Network: In meetings with FCC advisors, ITTA advocated regulatory parity, payment for network usage, and carrier control of the network. Relying upon prior ITTA filings regarding pole attachments, phantom traffic, network management, regulatory fees, and Universal Service, members and staff emphasized the need to ensure that regulatory models evolve with the dynamic telecommunications market.
Notice of Ex Parte Appearance 1
Notice of Ex Parte Appearance 2
Notice of Ex Parte Appearance 3

June 2008

ITTA Cites Constitutional and Cost Concerns of DTV Notice Proposal: ITTA called on the FCC to reject a proposal that would require a broad range of telephone companies to provide to their customers notice of impending broadcast-to-digital television transition.

ITTA Supports Level Playing Field for Competitors: Citing consumer benefits and regulatory parity, ITTA called on the FCC to ensure that telecommunications providers are permitted to market their services effectively.

ITTA Meets with FCC to Discuss Wide Range of Issues: ITTA met with the FCC to discuss phantom traffic, pole attachments, network management, and other issues of concern to mid-size carriers serving rural America.

ITTA Calls for Parity in Federal Fee Assessments: Citing common participation in FCC dockets and similarity of services offered, ITTA urged the FCC to restructure regulatory fee allocations to bring parity to the process.

ITTA Urges Rational Revisions to USF: In reply comments, ITTA urged the FCC to continue successful USF mechanisms and to set aside proposals that would unreasonably depart from Federal-State Joint Board recommendations. ITTA also urged the Commission to ensure that all areas are adequately supported.

May 2008

ITTA Advises Strict Reading of Interconnection Statute: Commenting on a petition of the Vermont Telephone Company, ITTA urged a strict reading of the relevant statute and a factual investigation of entities seeking interconnection where questions regarding their eligibility arise.

ITTA Recommends Rejection of Lifeline Partial-Month Decision: Citing FCC instructions and the history of Form 497, ITTA urged the FCC to reject USAC Administrator decisions that would require carriers to report partial-month Lifeline data.

ITTA Urges House and Senate Leadership to Reject Nine-Digit Zip Data for Broadband Mapping: In separate letters to Farm Bill Conferees, ITTA explained that the FCC earlier this year rejected nine-digit data in favor of census tract data for broadband mapping purposes, and asked that Farm Bill language follow that FCC lead.
House Letter
Senate Letter

ITTA Explains Adverse Effects of Reverse Comp for ISP-Bound Traffic: Continuing a series of meetings, ITTA staff and member company representatives met with FCC advisors to explain the adverse effects that reciprocal compensation for ISP-bound traffic would create for carriers and broadband deployment.
Notification Letter

April 2008

ITTA Explains Adverse Effects of Recip Comp for ISP-Bound Traffic: In meetings with senior FCC advisors, ITTA explained that requiring reciprocal compensation for ISP-bound traffic would adversely impact carriers and broadband deployment.
Letter 1
Letter 2

ITTA Urges FCC to Ensure Lawful Pole Attachment Rates: Responding to comments filed by utilities, ITTA demonstrated broad support for revision of FCC pole attachment rules to ensure lawful pole attachment rates for incumbent local exchange carriers.

ITTA Proposes Broad Multi-Prong Approach to USF Reform: In comments to the FCC, ITTA supports separate wireline provider of last resort, mobile voice, and broadband programs within a single USF, with suport paid to carriers on "actual costs" basis.

ITTA Recommends FTC Affirm Self-Regulation for On-Line Consumer Preference Marketing: Citing businesses' attention to customer protection in rapidly evolving technological markets, ITTA promotes a self-regulatory approach in a Federal Trade Commission filing.

ITTA Urges Greater Accountability and Oversight of Rural Utility Service Broadband Loans and Grants: In letters to Senate and House leadership, ITTA urges greater attention to RUS programs to ensure that broadband loans and grants are directed toward areas that are unserved.
House Letter
Senate Letter

March 2008

ITTA Urges Prompt Action on Phantom Traffic: ITTA and member companies addressed need for action on phantom traffic; also discuss interim cap on support for CETCs and potential unintended impact on IAS recipients. See letters here and here.
Letter 1
Letter 2

ITTA Recommends Exemption Where Few LNP Requests Do Not Justify Costly Upgrades: Noting differences in the ways various carriers handle LNP requests, ITTA recommends limited carrier exemptions where upgrades would be disproportionate to the number of LNP requests received.

ITTA Joins Effort to Assure Payment for Use of Telephone Network: ITTA joins other associations asking FCC to confirm that all users of the public switched telephone network must pay for use of it.

ITTA Supports Frontier Price-Cap Petition: ITTA supports waiver of FCC rules necessary to ensure adequate support for telecommunications networks serving consumers in rural areas.

ITTA Urges FCC to Assure Just and Reasonable Pole Attachments: Citing statutory directive in the Communications Act and noting benefits for broadband deployment, ITTA urges the FCC to assure just and reasonable rates, terms, and conditions for incumbent telephone company pole attachments.

ITTA Advises Against Procedural Requirements for Forbearance: ITTA demonstrates the deregulatory intent of the Communications Act and urges the Commission not toimpose regulations on a process intended to facilitate deregulation.

February 2008

ITTA Calls on FCC to Address Phantom Traffic: Describing the impact of phantom traffic and mid-sized carrier involvement in efforts to resolve it, ITTA calls on FCC to address phantom traffic as new proposals are introduced at the FCC.

ITTA: Broadband Providers Must Have Ability to Manage Networks: ITTA urged the FCC to refrain from regulating broadband network management practices, citing competition and the market's ability to meet and respond to consumer demands.

ITTA Files Comments Supporting Consolidated Communications Request for Price Cap Election: Noting the need for regulatory flexibility in today's dynamic markets, ITTA supports Consolidated Communications' request to elect price-cap regulation.

ITTA Joins Other Associations on Consumer Wireless Protection and Municipal Networks

ITTA Commends House for Farm Bill Language Promoting Broadband, RUS Accountability

ITTA Applauds Inclusion of Broadband Language in Senate Farm Bill

ITTA Calls for Rural Witness at USF Hearings

January 2008

ITTA Supports Puerto Rico Telephone Request for Regulatory Flexibility: Consistent with historic positions, ITTA supported a carrier's request to elect price-cap regulation. ITTA also urged the Commission to permit the company to avail itself of the regulatory structure the carrier determined best suits its needs in today's dynamic market.

ITTA Addresses DTV Transition: ITTA met with FCC advisors to discuss an FCC proposal that telephone carriers inform certain customers of DTV transition.
Letter 1
Letter 2
Letter 3
Letter 4
Letter 5

ITTA, Multi-Party USF Effort at FCC: ITTA, with other associations and carriers, urged the FCC to adopt an interim cap on USF support for CETCs.
Letter 1
Letter 2
Letter 3
Letter 4
Letter 5

ITTA Commends FCC Release of USF Notices

ITTA Supports HR 5140 Depreciation Standard; Would Encourage Broadband Deployment