As we reported last year, the Commission adopted new rules designed to increase its ability to monitor, and correct, the “frequent and pervasive” problem of failed telephone calls to small towns and rural areas. While those new rules took effect several months ago, it appears that a number of bugs, or possible bugs, still need to be worked out in the reporting system. We know this because a number of requests for waivers have already been filed, and the Commission itself is wondering whether certain categories of call attempts described in Appendix C of the Rural Call Completion Order need to be clarified or modified.
AT&T presents perhaps the most troublesome proposal. AT&T wants to report only the sample of data contained in the Originating Access Charge Verification records. With only sample data, the FCC will be unable to determine the cause for the degradation of many rural calls that are not contained in AT&T’s sample. That could significantly undermine the overall effectiveness of the new rules. AT&T is also looking for waivers with respect to certain AT&T Mobility traffic and intraLATA toll traffic, not to mention a six-month extension of the reporting deadline. As AT&T is the interexchange carrier with the most traffic terminating to many rural areas, a grant of AT&T’s waiver request could nullify many of the benefits to be derived from the new rural call completion rules.
Midcontinent Communications, by contrast, is looking to temporarily report only aggregate data – until Midcontinent serves 250,000 retail access lines or for three years, whichever period is shorter. Midcontinent’s concern is that it will cost it $150,000 to collect all the data required to be reported. Since Midcontinent got swept within the reach of the rules unexpectedly – thanks to the subscriber lines used to provide service to inbound telemarketers– Midcontinent believes that it might be entitled to some slack.
As to the Commission’s own proposed changes, the issue is whether the Appendix C categories of “answered” and “ring no answer” call attempts need to be defined differently (or at least clarified) in light of certain practical, technical considerations.
The Commission appears to figure that none of these matters should take much time to address – the comment periods it has provided are notably abbreviated. Comments on the two waiver requests are due by May 12, 2014; reply comments are due by May 19. Comments on the possible tweaks to Appendix C are due by May 13, 2014. You can upload comments through the ECFS filing site; use Proceeding No. 13-39.