2010 Legal and Regulatory Filings

December

ITTA Voices Support for "Light Touch" Broadband Policies to House and Senate Leadership (House letter, Senate letter) Cites Past Success, Risk to Future Investment if Intrusive Regulation Imposed

ITTA Comments on FCC's High-Cost Mobile Broadband Proposal Urges FCC to Distinguish Between Green-Field Developments and Providers of Last Resort When Consider Reverse Auction Proposals for Distribution of High-Cost Support, Cites Adverse Impact on Investment Incentives

October

ITTA Urges Light Touch for Broadband Calls on FCC to Refrain from Regulation of Specialized and Managed Services

ITTA Urges Congress and the FCC To Fix the Current Retransmission Consent Rules

ITTA Commends Congress for Swift Action on Extending Bonus Depreciation on Investment
ITTA Letter to Congressional Leadership Urging Passage of Bonus Depreciation Legislation to Help Stimulate Broadband Investment

ITTA Calls for Targeted Application of USF for Broadband Deployment Urges FCC to Direct Undistributed CETC Support for Immediate Broadband Deployment

September

ITTA Supports Competitively Equitable USF Contribution Policies Recommends Expansion of Contribution Base Among Entities Relying on the Network

ITTA Urges FCC to Affirm Payment Obligations of Entities Using PSTN Urges Action on Phantom Traffic, Access Stimulation, and Obligations of IP-Enabled Voice Providers; Calls on FCC to Halt Incentives for Arbitrage

ITTA Comments on Section 706 Notice of Inquiry Urges FCC to Ensure Outcomes Promote Investment, Focus on User-Experience in Rural America

August

ITTA Presses for FCC Action on Phantom Traffic, Access Stimulation, Access Obligations for VoIP Traffic Continuing a Series of Meetings with FCC Staff, ITTA Urges Action on Vital ICC Components to Build Momentum for Comprehensive Reform (see additional notice here)

ITTA Addresses Pole Attachment Policies, Balances Pole Owner, Attacher Interests As Both Pole Owners and Attachers, ITTA Proposes Equitable Approach for Pole Attachment Rules that Benefit Broadband Deployment

ITTA Urges Regulatory Parity for Broadband Providers Reiterating its Opposition to Broadband Regulation Proposals, ITTA Emphasizes that Any Resolutions Should Apply Equally to All Providers

ITTA Urges FCC to Affirm that Entities Relying on PSTN Must Pay for Use Noting Incentives for Arbitrage and Costly Disputes, ITTA Urges FCC to Affirm Access Payment Obligations for IP-Enabled Voice Traffic Terminating on the PSTN

ITTA, Industry Colleagues Urge FCC to Allow Market-Based Determinations for Set-Top Boxes Citing an Evolving Marketplace, ITTA and Peer Associations Call Upon FCC to Refrain from Imposing Standards for CableCARD Successor, and to Instead Allow Market Forces to Determine Solution

July

ITTA Urges Immediate Action on Phantom Traffic, Access Stimulation, and Access Obligations for VoIP Traffic Demonstrates Complete Evidentiary Records to Staff, Cites Benefit of Resolution for Long-Range ICC Reform

ITTA Supports CenturyTel, Qwest Transaction Discusses Changing Industry, Urges FCC Approval without Conditions

ITTA Opposes Proposals for Broadband Regulation Cites Competitive Market and Overwhelming Lack of Disruptive Events that Would Warrant Intervention

ITTA Affirms Need for Broadband Support, Urges FCC to Include Rational Glide Path In comments on National Broadband Plan High-Cost Support Proposals, ITTA Urges Industry Access to Cost Models and Opposes Reductions in Current Support Before Final Mechanisms are Established

June

ITTA Highlights Issues for FCC Consideration in NBC-Comcast Merger Review Identifies Potential Adverse Effects, Urges FCC to Consider Impact on Competitive Video Providers

ITTA, Rural Video Providers Address MVPD Navigation Devices Seek Clarification, Waiver of CableCARD Rule for IPTV Providers

May

ITTA Advocates FCC Reform of Retransmission Regulations Joins Industry Associations to Achieve Affordable Video Rates, Increase Broadband Prospects

ITTA Promotes Uniform Rate for Broadband Pole Attachments Meets FCC Advisors to Discuss ILEC Pole Attachment Experiences; see ex parte notification letters here and here.

ITTA Comments on FCC Proposals for New Ex Parte Rules In Filed Comments, ITTA Demonstrates Effectiveness of Current Regulations, Offers Recommendations for Refinements

April

ITTA, Industry Urge FCC to Reject Title II for Broadband In a Letter to the FCC, ITTA and Major Wireline, Cable, and Wireless Interests Demonstrate Flaws in Proposals to "Reclassify" Broadband as Title II Service

ITTA Files Opposition to Net Neutrality Proposals In Reply Comments, Cites Recent Comcast v. FCC Decision and Academic Papers to Support Market-Driven Approach to Broadband Internet Access

ITTA, National Associations Urge Full Protection for Proprietary Data Citing FOIA Standards and the Competitively Sensitive Nature of Form 477 Data, Oppose Release of Proprietary Broadband Provider Information

ITTA Supports Extension of Separations Freeze Calls on FCC to Extend Freeze for At Least One Year Following Implementation of USF and ICC Reform

ITTA Urges NTIA to Extend Review Period for BTOP Applications Noting 30-day Review Period for Round 1 Applications, ITTA Requests NTIA to Extend Abbreviated 15-day Review Cycle in Order to Enable Adequate Review and Response

ITTA Joins National, State Associations to Support Access Charge Obligations for Interconnected VoIP Citing Interconnected VoIP Reliance on PSTN, Urges FCC to Affirm Compensation for Network Usage

March

ITTA Recommends Amendments to RUS BIP Grant Agreement Describing Partnership of Public and Private Sector Investment, Urges RUS to Ensure Appropriate Incentives for Private Broadband Investment

ITTA Comments on Maine PUC Unbundling Petition Responding to a Maine PUC Request, ITTA Urges the FCC to Maintain Market-Based Approach and Reject Fiber Unbundling Requirements

ITTA Supports FairPoint Price Cap Petition In Filed Comments, ITTA Supports Carrier's Request for Transition to Regulatory Framework that Enhances Operational Efficiencies

ITTA, Associations Respond to USF Proposal In Joint Letter, Describe Stability of ILEC USF Support

ITTA Supports Michigan Access Reform In Comments at the FCC, ITTA Explains Access Reform Measures in Context of ILEC and CLEC Obligations

February

ITTA Reinforces Opposition to Broadband Unbundling In Reply Comments, ITTA Cites Support from Carriers for Opposition to Requirements that Would Disrupt Broadband Investment

January

ITTA Proposes USF Methodolgy to Meet Tenth Circuit Remand Urges FCC to Target Price-Cap Support on Wire Center Basis, Create Efficiencies in CETC Support

ITTA Opposes Petition to Require Broadband Unbundling Defends Prior FCC Findings that Have Fostered Strong Broadband Investment, Cautions Against Consequences of Unbundling Requirements

ITTA Supports Market-Based Network Management Policies Cites Thriving Broadband Internet Access Market, Need to Promote Investment Incentives, in Rejecting "Net Neutrality" Proposals

ITTA Comments on USF Reform Proposal Describes Network Characteristics of Carriers of Last Resort Serving Rural America, Advises FCC Against Processes that Would Create Inefficiencies and Discourage Investment Incentives