JSI Takes Client Concerns About A-CAM to FCC in Recent Ex Partes

JSI, along with representatives from several industry groups and client companies, recently shared its concerns with the FCC about the Alternative Connect America Model (A-CAM) and how the Commission is using data submitted via Form 477 to determine what census blocks could receive USF in the future.

During the October 27, 2015, ex parte with the FCC’s Wireline Competition Bureau, JSI, NTCA, Bennet & Bennet, Panhandle Telephone Cooperative and Madison Telephone Company discussed a number of concerns with the way the A-CAM identifies the purported presence of unsubsidized competition in rate of return service areas. The group specifically pointed out instances in which the A-CAM incorrectly classifies an RLEC’s or an RLEC affiliate’s voice and/or broadband services as services that are being provided by an unsubsidized competitor, even if these services are in fact used and provided in furtherance of the RLEC’s eligible telecommunications carrier (ETC) obligations.

In its September 17 ex parte, JSI staff presented scenarios to the FCC’s Wireline Competition Bureau in which rural rate of return carriers would lose universal service support under the A-CAM if one of its affiliates provided broadband via cable modem or fixed wireless. Even a few ILECs could be eliminated for using fixed wireless to serve some of its customers if the rules remain as written. JSI staff also discussed the ability to challenge a third party’s claims that they serve the census block.