The National Telecom Co-op Assn. (NTCA) urged the FCC to explore ...

“not an appropriate substitute for a charge that recognizes the value provided and the costs imposed when a carrier utilizes another carrier’s facilities.” The group warned the Commission against adopting a “one-size fits all” solution, which it said “could harm rural telephone companies and the rural consumers they serve.” NTCA submitted a “blueprint of elements” for the FCC to consider when shaping the new rules. It urged the Commission to adopt rules that: (1) “Include a different set of regulatory policies for rural telephone companies to ensure that their network remain viable.” It said rural ILEC networks were “the default infrastructure in high cost areas,” and in most cases they offered “the only telecommunications service that is ubiquitous throughout their service area and universal service would not exist without them.” (2) “Include some charge that provides for carriers to compensate each other for the use of one another’s network.” (3) “Preserve and sustain universal service.” It said a reform shouldn’t result in “unaffordable end user rates or in a ballooned universal service fund that is unsustainable.” (4) “Preserve rural ILECs’ option to operate under rate-of- return regulation,” which it said was “a reasonable means to determine financial requirements for rural telephone companies also to ensure their ability to continue to invest in rural areas.” (5) “Encourage investment in a network infrastructure capable of delivering high quality broadband services in all areas of the nation.” NTCA said the FCC should ensure that “customers and carriers across all sectors of the industry share equal responsibility for the use of the public switched network.” The filing followed a study the group submitted to the Commission in Jan., which found a pure bill & keep regime would affect the revenue of rural companies by more than $2 billion annually.