NRECA Comments to the FCC In Re: Delete, Delete, Delete

The National Rural Electric Cooperative Association submitted remarks to the Federal Communications Commission in response to the In Re: Delete, Delete, Delete request for comments. NRECA's comments focused on several rules, including transparency and reporting requirements. "Broadband providers that receive high-cost support are currently required not only to file detailed deployment data in the Universal Service Administrative Company High Cost Universal Broadband portal, but also to file coverage data twice each year in the Broadband Data Collection program. These are burdensome, duplicative exercises. While NRECA appreciates the distinct purposes of USAC’s HUBB portal and the BDC program, the Commission is requiring providers to submit the same information multiple times." NRECA also recommended a change to the "discriminatory effect" language in the FCC's digital discrimination rules, "NRECA suggests that this broad, effect-based analysis, whereby liability can be found in the absence of discriminatory intent, is not required by the statute and creates significant uncertainty for service providers. Accordingly, NRECA respectfully proposes that this 'discriminatory effect' language be removed."