Most Unopposed to Counting Access Lines for Calif. USF
CTIA stood alone fighting to keep revenue-based contribution for California USF, in comments last week at the California Public Utilities Commission. CPUC members plan to vote Oct. 6 on a proposed decision to assess state public purpose program (PPP) fees based on a carrier’s number of access lines (see 2209060048). The wireless industry continued to staunchly oppose the change, but wireline and cable companies instead sought more implementation time and wording changes.
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“A connections-based surcharge mechanism would be inequitable and discriminatory to low-income and wireless consumers,” said CTIA comments received by the commission Thursday in docket R.21-03-002. "The current revenue-based mechanism is sustainable despite the downward trend in intrastate telecommunications revenues, and ... differences in providers’ levels of intrastate revenue are a result of differences in the mix of services sold to their consumers.” Under the CPUC plan, funding responsibility "would disproportionately shift onto wireless consumers, who would face an estimated four-fold increase in their contribution burden,” said CTIA, saying the plan inequitably "would exclude all intrastate telecommunications service providers that do not provision end-user connections, such as interexchange carriers.”
The proposed connections-based method responds appropriately to year-over-year declines in the state USF contribution base, said CalTel and other small LECs. But companies need more than the proposed three months to make the change, said the group, seeking six months. Frontier requested eight months. Give companies until April 1, said the California Cable and Telecommunications Association (CCTA), which said it’s glad the proposal doesn’t assess broadband.
The CPUC draft didn't adopt consumer groups' proposal for a hybrid surcharge mechanism with different fees for residential and business users, but the Center for Accessible Technology said it “supports much of the PD’s analysis.” CforAT said it’s glad the draft "resoundingly and repeatedly rejects carriers’ assertions that no changes to the existing methodology are needed,” and snubs other proposals to shift support to California's general fund. The CPUC should monitor impacts of the new surcharge mechanism, it said.
Industry sought changes to the proposed definition of access line. The draft defines that as “a wire or wireless connection that provides a real-time two-way voice telecommunications service or VoIP service to or from any device utilized by an end-user, regardless of technology, which is associated with a 10-digit NPA-NXX number or other unique identifier and has a service address or Place of Primary Use in California.”
Remove the reference to a “unique identifier,” which isn’t defined and could confuse, suggested CCTA. Frontier and small RLECs agreed, and asked the CPUC to limit the definition to “intrastate” voice and “interconnected” VoIP. And they suggested the CPUC use Form 477 standards for counting high capacity circuits and other multi-line business services.
The CPUC must tie access lines to California based on a place of purchase, or prepaid wireless companies "will have no guidance on how to determine the jurisdiction of their customers for the purposes of PPP contributions,” warned CTIA: The current definition wouldn't work for prepaid companies, which don't "have a 'service address,' or any address at all, associated with some customer accounts.”
Clarify that access line data reported by providers is subject to periodic review and audit, commented the agency’s independent Public Advocates Office. The office supported adopting a per-access line, flat-rate surcharge mechanism.
The California Emerging Technology Fund supported the proposed $1.11 surcharge taking effect Jan. 1. But CETF was disappointed that broadband won’t be assessed. CPUC may feel its authority is limited, but "given that the thrust of PPPs must be to close the Digital Divide, promote Digital Inclusion, and achieve Digital Equity, federal and State public policy must move towards generating revenue from Internet transactions as a fairer approach to shared responsibility for the public interest and to provide a broader revenue base that will result in a multitude of economic and environmental benefits for society in addition to advancing social justice,” said CETF: The CPUC should seek approval from the governor "to pursue changes in federal law and regulations to include Internet transactions in the revenue base."