2009 Legal and Regulatory Filings

December 2009

ITTA Describes Need for Equitable Pole Attachment Policies: In a letter to FCC staff, ITTA urged the FCC to ensure regulatory parity and reasonable treatment for telephone companies seeking pole attachments in order to facilitate efficient broadband deployment.

ITTA Supports Waiver of Equal Access Long Distance Scripting Requirements: Consistent with prior advocacy, ITTA filed written comments supporting a petition of Cincinnati Bell for relief from equal access long distance scripting requirements.

ITTA Addresses Policy Issues Implicated by Transition to IP Networks:Outlining broad parameters, ITTA proposes an initial framework for FCC inquiry into a transition to IP-based networks.

ITTA Addresses Jurisdictional Issues Relating to IP-Based Services: In a letter to Congressional leadership, ITTA highlighted issues implicated by technology-specific preemption, and advocated technology-neutral approaches to ensure key policy goals of broadband deployment.

ITTA Calls for Regulatory Parity and Market-Based Guidelines for Broadband Consumer Protection: Responding to the FCC's request for broadband consumer protection information, ITTA voiced support for market-based guidelines, and urged the FCC to ensure that all users of broadband are protected equally.

ITTA Commends FCC, NTIA to Establish Adequate Protections for Proprietary Carrier Data:Responding to an NTIA request for sensitive carrier data, ITTA voiced support for efforts to ensure proper implementation of broadband deployment programs, but emphasized the need for Federal agencies to ensure adequate protections for carriers' proprietary information.

ITTA Urges Policy Makers to Ensure Adequate Support for Broadband Mandates:In filed comments, ITTA described the need for policy makers to ensure that adequate incentives exist to support broadband deployment in rural, high-cost areas of the Nation.

November 2009

ITTA Addresses ARRA in Comments to NTIA, RUS: In written comments, ITTA urged NTIA and RUS to ensure that second round BTOP and BIP funding be focused on bringing broadband to unserved areas, and that arbitrary restrictions on infrastructure projects in rural, unserved areas should be rejected.

October 2009

ITTA Cautions Against Retroactive Applicability of FCC Regulations:Responding to potential for retroactive regulation, ITTA demonstrates that USF document retention requirements cannot be applied to audit periods before the rules became effective.

ITTA, Industry Urge FCC to Develop Fact-Based Net Neutrality Policies: In a joint letter to FCC Commissioners, ITTA and other industry associations cited National broadband investments of $80 billion and urged the FCC to develop policies that increase consumer choice and encourage investment.

ITTA Urges Equitable Application of Truth-in-Billing Requirements:In filed comments, ITTA recommended the FCC refrain from imposing additional truth-in-billing requirements, citing market forces that encourage good industry behavior, but urged the FCC to ensure that consumers of similar services enjoy same levels of protection.

September 2009

ITTA Cites Pole Attachment Rates as Major Input to Broadband Deployment:Commenting on a petition regarding pole attachment rates paid by cable broadband providers, ITTA recommended the FCC to consider the matter within a broader docket to address pole attachment rates paid by all broadband providers and to ensure regulatory parity.

ITTA Joins National and State Industry Associations to Support USF Parity: In reply comments, ITTA joined industry associations and state commissions to offer further support for the Nebraska and Kansas state commissions' petition to ensure state USF contributions by nomadic interconnected VoIP providers.

ITTA Files Support for Frontier/Verizon Transaction: In comments filed at the FCC, ITTA supported Frontier's acquisition of rural Verizon lines.

ITTA Urges Elimination of Equal Access LD Scripting Requirements: Citing the strong intermodal competitive marketplace for long-distance services, ITTA urged the FCC to eliminate the unevenly applied equal access long-distance scripting requirements.

ITTA Joins Industry and State Industry Associations to Support VoIP Contributions to State USF: Joining other industry associations and state commissions, ITTA supported Nebraska and Kansas state public service commissions' request for FCC confirmation that states may assess USF contribution obligations on providers of nomadic interconnected VoIP services.

ITTA Defines "Broadband" for National Broadband Plan: ITTA offered an applications-based definition aimed at ensuring that consumers in rural America have sufficient broadband capabilities.

August 2009

ITTA Recommends FCC to Establish Parameters for Wireless Cost Studies: In response to a cost study filed by a wireless CETC, ITTA recommended consideration of wireless-specific cost studies, rather than application of wireline-based cost studies to wireless carriers.

ITTA Calls for Rational Audit Measures: Noting past progress in improving the OIG/USAC audit process, ITTA called on the FCC to now replace arbitrary metric thresholds with standards based on carrier-specific data.

July 2009

ITTA Urges FCC to Ensure Proper Treatment of Proprietary Data: Joined by OPASTCO, ITTA urged the FCC to ensure that carriers' proprietary Form 477 data is protected adequately when it is shared with other entities pursuant to the Broadband Data Improvement Act.

ITTA Responds to National Broadband Plan Comments, Calls for Strong Networks: In filed reply comments, ITTA addressed positions of other parties and called upon the FCC to create a National Broadband Plan that will promote networks that offer capacity, reliability, security, and scalability.

ITTA Advises FCC to Open Proceeding to Examine Competitive Provision of E911: In comments and reply comments, ITTA urged the FCC to separate consideration of competitive E911 services from pending interconnection arbitration proceedings.

ITTA Recommends FCC Consider Lifeline Within Pending USF Proceeding: Responding to a petition for waiver filed a by party seeking additional USF Lifeline support, ITTA recommended the FCC to defer consideration of the request to the FCC's broader examination of USF, and to ensure that any changes apply to all Lifeline service providers.

June 2009

ITTA Presents Outlook for National Broadband Plan: In filed comments, ITTA presented a framework for the National Broadband Plan, urging attention to network capabilities and deployment in rural areas.

ITTA Distinguishes Need for USF Solution to 10th Circuit Remand: Responding to comments of other parties, ITTA distinguished the need for a USF framework that addresses the needs of non-rural carriers.

ITTA Urges Equitable Regulatory Fee Structure: In response to the FCC's annual regulatory fee order, ITTA refreshed its advocacy calling for equitable distribution of responsibility among fee payers.

May 2009

ITTA Supports Targeted USF and 10th Circuit Solution: In comments, ITTA explained its USF proposal that meets the demands of the 10th Circuit's remand of non-rural USF rules.

ITTA Comments on LNP Requirements: In a filing and meetings with FCC staff, ITTA described non-automated porting processes.

April 2009

ITTA Supports Lifeline Assistance for Consumers as Part of Comprehensive USF Undertaking: Responding to a petition for rulemaking, ITTA recommended that the Commission incorporate review of the Lifeline assistance program within the context of overall USF rulemaking, rather than as a stand-alone effort.

ITTA Supports Extension of Separations Freeze: Citing the current competitive climate, ITTA filed comments supporting an extension of the "separations freeze."

ITTA Files Comments on FCC Role in Broadband Stimulus Act: In filed comments, ITTA proposed definitions for “unserved,” “underserved,” and “broadband” relevant to the FCC’s consultative role in the BTOP program to be administered by the NTIA and RUS.

ITTA NTIA RUS Final: ITTA Files Comprehensive Broadband Stimulus Comments at NTIA, RUS: Urging priority attention for unserved areas, ITTA filed comprehensive comments setting forth guidelines for the NTIA and RUS administration of the BTOP broadband Stimulus Act programs.

March 2009

ITTA Supports CenturyTel, Embarq Merger: In a meeting with the FCC, ITTA cited general industry trends and urged the FCC to approve the merger of CenturyTel and Embarq.

ITTA Proposes Parameters for FCC in Rural Broadband Initiative: ITTA proposed methods by which the FCC can coordinate efforts with other Federal agencies in order to efficiently speed the further deployment of broadband throughout rural America.

ITTA Reminds FCC of LNP Costs: In a meeting with the FCC, ITTA explained that while some carriers have automated LNP processes, many still rely on manual processes where the number of porting requests do not justify economically the cost of upgrades necessary to meet proposed 48 hour porting requirements.

ITTA Continues Call for Proper Intercarrier Compensation: Citing the practice of “virtual NXX” arrangements, ITTA and a coalition of concerned industry participants called on the FCC to affirm proper intercarrier compensation.

ITTA Opposes FGIP Petition for Reconsideration: Rejoining industry associations who opposed FGIP’s initial petition, ITTA filed an opposition to FGIP’s petition for reconsideration of the FCC Order that denied the initial FGIP request.

February 2009

ITTA Files Petition Urging Stay of Form 477 Deadline: Noting the imminent filing deadline for Form 477, ITTA filed a formal petition urging the FCC to extend the filing deadline of the yet-unreleased Form.

ITTA Details Form 477 Issues to FCC: In a meeting with FCC staff, ITTA explained the need for carriers to have a reasonable opportunity to review new Form 477 prior to the filing deadline.

ITTA and Industry Coalition Call for Reasonable Form 477 Deadline: ITTA and peer associations urged the FCC to implement reasonable filing deadlines for new Form 477, in light of delays in the public release of the Form.
Exhibit

ITTA Joins Industry Associations to Advocate Clarification of Compensation Rules: ITTA joined other associations to support local switching support that is based on current line costs.

January 2009

ITTA Discussed ICC Reform and IP-Enabled Traffic with FCC: Meeting with the FCC, ITTA reaffirmed its interest in rational intercarrier compensation reform and urged the Commission to confirm that providers who rely on telephone networks must pay for their usage.

ITTA, Others Urge Regulatory Parity for IP-Enabled Traffic: ITTA and other telephone trade associations urged the FCC to ensure that all providers that rely telephone networks pay for that use.
Exhibit

ITTA Supports Merger of CenturyTel, Embarq: In filed comments, ITTA supported the merger of CenturyTel and Embarq. ITTA cited prior industry actions that support the approval, without conditions, of a transaction intended to initiate greater economic efficiencies and enhanced deployment of advanced services.

ITTA Engages New Leadership to Ensure Support for Broadband Deployment in Rural Areas: In conjunction with personal presentations, ITTA submitted a letter to Hill leadership to guide economic stimulus efforts toward ensuring economic stimulus support for broadband deployment in rural America.

ITTA Renews Call for Reasonable Implementation of Data Gathering Requirements: Citing the short timeframe between release of new FCC data forms and the deadline for carriers’ submission, ITTA asked the FCC to defer the filing deadline in order to enable carriers sufficient time to fulfill the filing requirements.
Notification Letter

ITTA Calls on FCC to Ensure Regulatory Parity for Voice Traffic: Joining others representing carriers serving rural America, ITTA urged the FCC to reject a petition filed by Feature Group IP, and to ensure regulatory parity for voice.
Presentation

ITTA Reiterates Interest in ICC Reform, Regulatory Parity: In a meeting with executive FCC staff, ITTA urged practical resolution for intercarrier compensation reform and regulatory parity for voice traffic.