CCA Seeks Rip and Replacement Certainty From FCC
The Competitive Carriers Association sought additional clarity on the rules for the program to rip and replace insecure equipment in carrier networks. Commissioners vote on rules for the program July 13 (see 2106220060). The request came in calls with aides…
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to FCC Commissioners Brendan Carr and Geoffrey Starks and Wireline Bureau staff. CCA sought clarity that the program will pay for upgraded equipment rather than the test in draft rules. “An upgrade to, at a minimum, 4G LTE appears to be inevitable, both as a practical matter (2G and 3G equipment may not be available) and a policy matter (it makes little sense to invest in building new networks using older technologies),” said a filing posted Thursday in docket 18-89. “Since 2G vs. 3G vs. 4G LTE networks may rely on different architectures and different equipment to perform functions, the multi-factor, fact-specific test risks introducing uncertainty over whether any particular 4G LTE function or piece of network equipment has the comparable capabilities and functions as a 2G or 3G piece of equipment.” CCA asked that removal and disposal of gear be reimbursed even if not replaced, and for an immediate six-month extension of deadlines for completing replacement. “Carriers are working hard to develop their transition plans in the face of substantial uncertainty,” the group said: “Simply having the potential for a discretionary extension at some point in the future will not give carriers the comfort they need today to prepare their network transition plans.” Rural Wireless Association representatives raised concerns on definitions in the draft, in a call with a Wireline Bureau staff. “As proposed, the definition of ‘provider of advanced telecommunication service’ with 2 million or fewer customers includes all intermediary carriers, schools, libraries and health care providers, leaving no one in the second prioritization category, Priority 2,” the group said.