Of the dozens of comments filed this week in response to the FCC’s rulemaking on USF contribution reform, there was little agreement about whether to stick with a revenue-based system for assessing contribution fees, to move to a system that uses connections or numbers, or even whether to assess fees on broadband service. The only universal sentiment that might be teased out of the plethora of comments filed is that, as AT&T put it, the current system is “dysfunctional.” Carriers differed, but generally supported a modified revenue-based system, while VoIP providers preferred a connections-based system.

FCC efforts to establish uniform data specifications for collecting study area boundary information “appear reasonable,” the National Exchange Carrier Association, Independent Telephone and Telecommunications Alliance, NTCA, OPASTCO, USTelecom, Eastern Rural Telecom Association and the Western Telecom Alliance said. They were responding to a public notice seeking comment on proposed data specifications for collecting study area boundaries (http://xrl.us/bnfbvj). The associations are generally against the imposition of benchmark-based limitations on high-cost loop support and proposals to eliminate support in areas served by unsubsidized carriers, but they support the use of more accurate data to accomplish the agency’s goals, they said. Companies might not have enough resources to submit study area shapefiles, so the commission should allow “substantial time” for submission of initial maps, they said. In a separate filing Monday, Nebraska Rural Independent Companies indicated its support of the agency’s data specifications for collecting study area boundaries (http://xrl.us/bnfbd3). The technical specifications in the notice are “adequate,” and reliance on state commissions is “appropriate and useful,” the filing said.

The FCC Wireline Bureau seeks comment on petitions filed by CTIA and USTelecom seeking clarification and reconsideration, or, in the alternative, waiver of three high-cost universal service rules (http://xrl.us/bne89z). The telecom associations have asked the commission to clarify that the broadband reporting obligations in section 54.313(a)(11) of the commission’s rules, and the rule requiring five-year service quality improvement plans and associated progress reports, only apply to carriers receiving Connect America Fund Phase II support. USTelecom also seeks clarification that the Interstate Access Support portion of frozen high-cost support is not subject to the broadband deployment certifications required by section 54.313(c) of the commission’s rules. Comments in docket 10-90 are due Aug. 6, replies Aug. 21.

CTIA and USTelecom want the FCC to clarify certain broadband reporting obligations in the USF/intercarrier compensation rules. The commission previously denied a request by USTelecom to reconsider imposing new reporting requirements on eligible telecom carriers whose support is being eliminated, but “did not discuss considerations for ETCs whose legacy support is being eliminated,” the groups wrote in their petition for reconsideration (http://xrl.us/bnc4oh). The commission also needs to address reporting requirements for incumbent wireline ETCs whose support is subject to elimination, they said. The commission’s third order on reconsideration “leaves unsettled what reporting and related requirements actually apply to wireless and wireline ETCs,” they said. The groups asked the commission to eliminate obligations to collect and file broadband data, which was “potentially called for” in an “ambiguous” section of the order. They also asked the commission to limit the filing of five-year service quality improvement plans and progress reports to ETCs that receive Phase II support, and to eliminate a requirement that an ETC certify that “frozen” Interstate Access Support (IAS) was used for broadband deployment. “This certification is impossible to make because the Commission requires that IAS support be used for other purposes … and carriers cannot spend this funding twice,” they said.

USTelecom petitioned the FCC for review of the Wireline Bureau’s order setting limits on high-cost loop support recovery. “Uncertainty and lack of clarity around present and future effects” of the benchmarks, which are based on a quantile regression analysis, “pose risks to the delivery and expansion of rural broadband availability,” the group said (http://xrl.us/bncvkm). USTelecom argued that the benchmarks will not only impact those carriers affected by reductions this year, but will also result in a “chilling effect on investment for rate-of-return ILECs whose support is currently unchanged.” And because companies don’t understand how the regression analysis works, it will be ineffective in providing incentives for prudent investment, USTelecom said. The association of ILECs asked the full commission to postpone implementation of the order until it can resolve concerns about “accuracy, transparency and predictability.” USTelecom is just the latest of several organizations to seek review (CD June 25 p14).

FCC options of scaling back program access rules drew no support from telcos, DBS providers and small cable operators, while operators that also own programming want the ban on exclusive deals for such content fully sunset. That’s according to initial comments on a rulemaking notice (CD March 22 p8). The document sought comment on whether to sunset the rules -- last extended for five years and expiring Oct. 5. Options the commission sought comment on other than keeping the rules or removing them in their entirety drew no support in docket 12-68. USTelecom and some others linked broadband service to keeping the rules, as cable rivals have in the past on video competition, saying subscription-video provider access to channels affiliated with operators helps them sell video and broadband.

Parts of many cellular networks potentially face traffic overload due to increasing video traffic, said Tom Soroka, USTelecom vice president-engineering and technology, in a webinar hosted by USTelecom. “No doubt, there’s been a video explosion,” he said. “Just about any mobile backhaul network needs the highest capacity they can get their hands on.” Video will consume two-thirds of mobile data traffic worldwide, 7.6 exabytes out of the 10.6 used per month, by 2016, according to the Cisco Visual Networking Index for 2011-2016 released in February (http://xrl.us/bigzmr). “There’s no one grand silver bullet solution,” Soroka said. Service providers will have to conduct cost-benefit analyses to determine the extent of network optimization in order to meet the increasing data demands, he said. Adtran posed one solution in the webinar: Optical Networking Edge, designed to help network providers offer a reliable, scalable network. “Years ago, most backhaul was over copper circuits,” Soroka said. “Now it’s moving toward packet over optical solutions. The current phase will be to eliminate as much transport overhead as possible,” he said, citing the use of Internet Protocol over optical circuits in the next phase of backhaul transformation.

Companies on both sides of the special access debate continued their eighth-floor FCC rounds this week. USTelecom met with an aide to Commissioner Mignon Clyburn Tuesday to encourage the commission to pursue mandatory data requests it said would demonstrate “robust competition” for high-capacity special access services to business customers (http://xrl.us/bnbsdn). The group urged the agency to make no “rush to judgment,” but rather to wait until it had all the data it needed to make an “informed decision.” Meanwhile Tuesday, Sprint Nextel met with Clyburn and aides to argue against the current pricing flexibility triggers, saying there’s already an “extensive record demonstrating lack of competition in the special access marketplace,” and additional evidence is “not needed” for the commission to suspend the triggers while it develops a new pricing flexibility framework (http://xrl.us/bnbsdv).

President Barack Obama will sign an executive order Thursday that aims to make the deployment of broadband infrastructure more efficient and less expensive, White House officials said. The order encourages a “dig-once” policy for broadband deployment that calls on federal agencies to provide guidance to states for including broadband conduit during the construction of federal highways. House and Senate Democrats supported the administration’s order, which they said would promote broadband deployment with bigger savings for taxpayers.

The FCC shouldn’t make any substantive changes to the special access pricing flexibility triggers until it gathers and analyzes competitive data, large telcos that sell such services have been telling commissioners in meetings this week. Those who buy special access have continued to express frustration at a system they say favors incumbents in areas where there’s no competition, allowing them to raise prices without fear of losing customers. A draft order that’s been circulating for over a week plans to seek data to reform the 1999 pricing flexibility rules, and FCC officials have said the existing special access framework is “broken” (CD June 5 p3).