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ACA Says Initial Facilities-Based LD Providers Root Of Call Completion Problems

Trade Group Urges FCC To Focus Regulations On These Bad-Actor Carriers

PITTSBURGH, June 13, 2013 - The American Cable Association is urging the Federal Communications Commission to address rural call completion issues by focusing on the root of the problem: Initial facilities-based long distance providers, which play a direct and dominant role in routing long distance calls and have access to the necessary complete call tracking data to monitor compliance.

"Rural call completion issues are a serious and continuing problem that the FCC must address with effective solutions, such as holding responsible and applying regulations to initial facilities-based long-distance providers," said ACA President and CEO Matthew M. Polka, noting that state regulators also share this position.

ACA put forth its views in reply comments filed June 11 in response to a Notice of Proposed Rulemaking (NPRM) in which the FCC described the call completion issue as serious, widespread and producing a variety of harms to consumers.

ACA's replies tracked previous comments in which it urged the FCC to address rural call completion issues by holding long distance providers responsible and refraining from placing responsibility on local service providers, which ACA said would be ineffective and prove burdensome for smaller providers, many of whom are ACA Members.

In the reply comments, ACA sought to respond to commenters that are seeking to minimize the extent of the completion problem and delay immediate action. In addition, ACA discussed the rationale for directing its regulatory solutions at initial facilities-based long distance providers instead of local service providers that are not facilities-based long distance providers.

ACA noted that the dearth of comments specifically favoring applying new regulations to local service providers that are not facilities-based long distance providers made perfect sense. In contrast to the key role played by facilities-based long distance providers in long distance call completion, local service providers play no direct role in routing long distance calls and do not have direct access to complete call tracking data.

As such, the local provider has no role in causing call completion problems and should not have to comply with new monitoring and reporting rules.

Many ACA members operate in rural areas and are members of rural telecommunications trade associations that have called on the FCC in comments to adopt meaningful rules requiring providers to capture and report data necessary for the FCC to monitor carrier call completion performance and aid in enforcement action. ACA supports this view because over the past few years, the FCC has collected more than sufficient documentation upon which to base imposition of new requirements.

More importantly, members of rural telecommunications trade associations have informed the FCC that call completion problems persist and are harming their customers despite the FCC's recent enforcement action against Level 3 in an order and consent decree. This experience revealed that long distance providers are continuing to take their chances that their failure to complete calls will go undetected and unenforced.

The findings of a few state regulatory commissions that have recently and closely examined call completion problems support ACA's position. In the aftermath of the Level 3 enforcement action, the staff of the Missouri Public Service Commission concluded that call completion problems continue to exist, appear to occur only in rural out-state areas served by small incumbent local telephone companies, and appear to be caused by intentional traffic manipulation by certain intermediate providers (aka least-cost routers) used by some originating interexchange carriers.

The Nebraska Public Service Commissioner, reacting to the Level 3 action, stated that the use of call routers has long been a part of the telecommunications industry and that problems have arisen when cost savings are prioritized over service.

"Apparently, there continues to be strong incentive for a significant number of long distance providers to avoid their legal obligations. The FCC should not tolerate this behavior and should adopt clear, stringent monitoring and reporting regulations for initial facilities-based long distance providers," Polka said.

About the American Cable Association

Based in Pittsburgh, the American Cable Association is a trade organization representing nearly 850 smaller and medium-sized, independent cable companies who provide broadband services for more than 7 million cable subscribers primarily located in rural and smaller suburban markets across America.  Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business.  For more information, visit http://www.americancable.org/

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