The FCC’s Quantile Regression Analysis is Fatally Flawed, Period

[Commentary] During the Federal Communications Commission’s year-plus long campaign for Universal Service Fund/Intercarrier Compensation reform, the FCC commissioners continually mentioned how byzantine, complex, convoluted, anti-consumer, loophole-filled and backwards the old USF and ICC rules were. And then the FCC came up with a Quantile Regression Analysis (QR) methodology for high-cost loop support (HCLS), which even the so-called "father of qunatile regression," Dr. Roger Koenker, believes is applied incorrectly. Now we have a method for capping HCLS that is not only all of the above, but also punitive, retroactive, inaccurate, utterly unpredictable and all-around nefarious—unless by some chance the methodology and inputs are completely revamped, or QR gets tossed in the appeals cases. Since we can’t assume either a revamp or an appeals victory, it is best to try and comprehend how QR will impact your company and why it is so precarious.