Incumbent telcos voiced concerns about certain FCC tech transition duties of ILECs seeking to discontinue legacy voice services. "Regarding the requirement to certify or show that a replacement service offers comparably effective protection from network security risks, we sought clarification that 'enterprise-wide' refers only to those portions of the provider’s enterprise or business that involve the provision of voice service," said a USTelecom filing Friday in docket 13-5 on a meeting representatives from the ILEC group, AT&T, CenturyLink and Verizon had with Wireline Bureau and Public Safety Bureau staffers. "The option for providers to demonstrate compliance with the latency benchmark described in Appendix B of the Second Report and Order is not feasible for use with incumbent providers’ managed voice services, and [they] sought confirmation that providers can demonstrate compliance using other existing methods." The FCC held an information session Monday on how technology transitions and commission rules affect consumers. Archived agency webcasts can eventually be viewed here.

NTCA opposed Comcast's bid for a waiver from record keeping, retention and reporting rules under a 2013 FCC rural call completion order. Comcast didn't meet a waiver standard requiring it to show the requested relief wouldn't undermine the policy objective of the rules and special circumstances warranted deviating from the rules, said the NTCA comments Monday in docket 13-39. Comcast said that its engineers inadvertently didn't capture call detail record data for certain business customers due to the network complexities of a switching platform migration, but that its reported performance results were still accurate despite lower call volumes (see 1609160017). "Comcast makes no assertion that there are special circumstances that warrant grant of the requested waiver or that it was unable to collect the required Call Detail Record information. In fact, Comcast was apparently able to correct the problem ‘immediately upon discovering the errors,’" NTCA wrote. It said "neglect" doesn't constitute "good cause" for a waiver: "There is no reason to give any firm a 'free pass' with respect to regulations that it knew applied, that it had personnel available to address, and that it apparently could comply with quite readily once it ‘paid enough attention’ -- especially when the rules at issue are intended to assure service reliability and protect the livelihood and safety of consumers.”

Midwest RLECs voiced concern the FCC may alter model-based USF subsidy criteria for rate-of-return carriers to exclude many entities, while Alaska carriers cited fiber and middle-mile cost challenges. Eleven rural telcos from Minnesota, Wisconsin and Iowa said they intend by Nov. 1 to opt into subsidy support derived from a broadband Alternative Connect America Cost Model (ACAM). The companies "were both surprised and concerned" with language in an Aug. 3 Wireline Bureau public notice (see 1608030049) "indicating that it might 'prioritize' among electing carriers on the basis of one or more of three different potential criteria (percentage of locations lacking 10/1 Mbps, absolute number of locations lacking 10/1 and/or average cost per location)," said a filing from the group Friday in docket 10-90 on a meeting with an aide to Commissioner Jessica Rosenworcel. The rural telcos are concerned potential FCC changes, probably after Nov. 1, could "significantly decrease the number of RLECs eligible to participate in the ACAM Path." The possibility some carriers might be excluded would be "an arbitrary and unfair change" of rules "in the middle of the process," they said. In a Monday filing, representatives of GVNW Consulting and Arctic Slope Telephone Association Cooperative met separately with aides to Chairman Tom Wheeler, Commissioner Mike O'Rielly and Rosenworcel about an FCC order adopting a modified "Alaska Plan" for rate-of-return and wireless carrier broadband support (see 1608310067). While lauding the order, the RLEC representatives said fiber deployment costs were expected to rise with demand, and small carriers would be competing with large carriers for contractors, crews and equipment. "Middle mile is the step after the implementation is initiated for the consensus Alaska Plan that relates to the last mile costs," said the GVNW filing. "If last mile issues are not adequately addressed for Alaska, any middle mile debate is moot. We provided an update from the nearly completed Alaska Network Services (ANS) analysis that revealed that the cost of extending the middle mile network across Alaska exceeds $2 billion."

The FCC invited pleadings on proposed license transfers from 1 800 Collect to 18C LLC, with comments due Oct. 7, replies Oct. 14, said a Wireline Bureau public notice Friday in docket 16-275. It said 1 800 Collect is a wireline interexchange service provider of mostly collect calling, and 18C, a newly created entity, is controlled by WiMacTel, which provides long-distance service and is a VoIP and wireless reseller in the U.S. and Canada.

The FCC sought input on CenturyLink plans to offer broadband in 9,703 census blocks using Connect America Fund Phase 1, Round 2 subsidy support. Other providers have until Nov. 7 to tell CenturyLink if they already offer internet access service of at least 3 Mbps (down) and 768 kbps (up) or higher in the newly identified areas, said a Wireline Bureau public notice in docket 10-90 Friday. It said CenturyLink will have to then certify before beginning construction that, to the best of its knowledge, the locations it plans to serve are in fact unserved.

CenturyLink asked to withdraw its appeal of an FCC tariff investigation order that barred prospectively the "all-or-nothing" business data service discount plans of it, AT&T, Frontier Communications and Verizon, among other actions (see 1605030001). In an unopposed dismissal motion (in Pacer) to the U.S. Court of Appeals for the D.C. Circuit Friday, CenturyLink said it isn't withdrawing a separate motion to intervene and will continue to support petitioner AT&T in its challenge to the order (AT&T v. FCC, No. 16-1145, et al.).

WTA and rural telcos said certain evidentiary burdens should be placed on competitors challenging broadband-oriented Connect America Fund subsidy support for rate-of-return carriers. Home Telephone and LICT officials "indicated that there are substantial differences between the theoretical and actual service areas and broadband speeds of many fixed wireless service providers," including wireless ISPs, said a WTA filing posted in docket 10-90 Thursday on discussions with an aide to Chairman Tom Wheeler and Wireline Bureau staffers in which TDS Telecom and Totah Communications officials also participated. "Factors such as technology, tower heights, frequency bands, antennas and antenna patterns, terrain, foliage, weather and backhaul facilities can significantly affect fixed wireless coverage, broadband capacity and signal quality." WTA, which has filed a petition for reconsideration of a March order, said fixed wireless providers seeking classification as "unsubsidized competitors" (the presence of which negates incumbent funding) should be required to submit a list of towers serving specific census blocks with various details. It said all fixed wireless and wireline providers seeking such status "should be required to substantiate their ability to provide quality and reliable service" through certain steps. WTA filings on meetings with other commissioner aides were posted here.

The FCC is launching its urban rate survey of fixed voice and broadband services with queries to selected providers, said a Wireline Bureau public notice Thursday in docket 10-90. The collected rate information will be used to set "reasonable comparability benchmarks" (for rural, high-cost USF subsidy mechanisms) in 2017, among other things, the PN said. "Notifications that a provider is required to complete a survey will be sent via email to each selected provider’s FCC Form 477 contact person and certifying official on or around September 22." Survey responses are due Oct. 25.

The FCC denied three waiver requests by telcos on new rate-of-return USF rules for support carriers can receive based on an Alternative Connect America Fund broadband cost model (A-CAM). A Wireline Bureau order Wednesday in docket 10-90 denied a petition from Shawnee Telephone and Moultrie Independent Telephone to waive commission decisions "to exclude census blocks served by fiber to the premises (FTTP) from the support calculations; and (2) not to make an offer of model-based support to any rate-of-return carrier that has deployed 10/1 Mbps broadband to 90 percent or more of its eligible locations in the relevant state." The bureau also denied a Baraga Telephone request to waive a March 30, 2016, deadline for submitting Form 477 data used to determine a rural carrier’s percentage of broadband deployment for purposes of making an A-CAM support offer, and it denied a Clarity Telecom request to waive a deadline for submitting Form 477 data used to identify census blocks served by FTTP or cable technologies.

The FCC made inflation adjustments to revenue thresholds for classifying telecom carriers for various accounting and reporting purposes. The annual revenue threshold for 2015 between Class A carriers and Class B carriers was increased to $155 million, and the threshold between larger Class A carriers and midsize carriers was increased to $9.18 billion, said a Wireline Bureau public notice in Wednesday's Daily Digest.