Michael Romano

NTCA—The Rural Broadband Association and ACA Connects—America’s Communications Association strongly support the proposal to amend a “program comment” issued by the Advisory Council on Historic Preservation (ACHP) in 2017. Recognizing that telecommunications undertakings “typically [do] not result in adverse effects to historic properties,” in 2017 the ACHP adopted a streamlined process for communications providers’ compliance with Section 106 of the National Historic Preservation Act for the installation of certain categories of wireline and wireless communications infrastructure on federal

NTCA submits that overriding public interest goals can be accomplished with narrowly drawn measures that focus upon key potential points of failure in the transmission of content and data, regardless of where they reside in the ecosystem.

Two areas in the draft Notice of Proposed Rulemaking on Safeguarding and Securing the Open Internet: 

In meetings with Federal Communications Commission staff, NTCA–The Rural Broadband Association reiterated its support for ensuring that lowincome consumers have affordable access to the voice service they need and therefore urged the Commission to retain the Lifeline subsidy for stand-alone voice service. Voice service remains critical for many low-income and older individuals who rely on such service as an affordable method of contacting health care providers, government agencies, and public safety. NTCA further stressed the urgent need for FCC action on the National Association of State U

In meetings with Federal Communications Commission staff, NTCA discussed an issue identified recently related to the phasedown of Lifeline support for voice-only customers and its interplay with cost recovery under the High-Cost universal service program. Specifically, for many eligible telecommunications carriers (“ETCs”), the reduction of the Lifeline subsidy for such customers to $5.25 per month effective December 1, 2020, precludes recovery of the full amount of the Subscriber Line Charge (“SLC”), and it appears that these shortfalls may be unrecoverable through the High-Cost program.