The Rural Cellular Assn. (RCA) and the Alliance of Rural CMRS Car...

changing the ETC [eligible telecom carrier] rules.” For example, they said the Board’s recommendation that states be encouraged to conduct “rigorous” proceedings was “certainly salutary,” but “unnecessary to ensure that only seriously qualified carriers become ETCs.” The groups said another Board recommendation -- that states be encouraged to consider the impact of a competitive ETC designation on the high-cost fund -- “ignores the fact that the impact of support to competitors is minuscule compared to the $600 million per year in increased funding received by [ILECs].” They urged the Commission to “continue to avoid regulating competitive ETCs in a way that violates the fundamental principles of competitive neutrality” when considering the Joint Board’s latest recommendations. The groups also urged the Commission to: (1) Reject the “notion that states have broad discretion to impose additional ETC requirements such as unlimited local usage, financial qualifications, or ILEC-style service quality standards.” (2) Reject the Board’s “unlawful and unworkable” primary line restriction. (3) Decline to follow the Joint Board’s recommendations regarding “creamskimming” and service area redefinition. They said the FCC should look at “the sensible steps” taken by the Wash. Utilities & Transportation Commission. (4) Stop treating individual ETC designations as rulemakings subject to the “permit but disclose” ex parte rules, but rather adopt “adjudicatory rules that govern the process.