The FCC has released a public notice seeking comment on two petitions for reconsideration — one filed by NTCA – The Rural Broadband Association and the other filed by USTelecom – The Broadband Association — each seeking to have one key aspect of the Commission’s April 2018 Rural Call Completion Order reevaluated. The April 2018 Rural Call Completion Order, among other things, required “covered providers” selecting the initial long-distance route to monitor the performance of intermediate providers and take remedial action to correct performance problems. It also created a safe harbor provision for covered providers that adhere to all of the ATIS RCC Handbook best practices. However, the one thing that the 2018 Rural Call Completion Order does not do is require covered providers to “document” their prospective monitoring processes and then file their monitoring procedures with the FCC. NTCA’s Petition for Reconsideration requests that the Commission reconsider its earlier order such that covered providers be required to file with the Commission and make publicly available their documented rural call competition monitoring procedures. USTelecom’s Petition for Reconsideration requests that the FCC reconsider the uncodified rules governing the monitoring obligations of non-safe-harbor covered providers. Specifically, USTelecom urges a Commission policy that does not overly-burden non-safe-harbor providers, which it believes the current policy does because the only realistic means by which non-safe-harbor providers can impose downstream changes to rural call completion quality is to overhaul commercial contracts (which intermediate providers are under no obligation to do, because they are not mandated under the FCC’s current rural call completion regulations). Oppositions to NTCA and USTelecom’s petitions for reconsideration are due 15 days after the public notice is published in the Federal Register. Replies to those oppositions are due 10 days after the opposition filing due date.
