Qtongre,9,9 of tlfe lltniteil ~tate,9
:mnsl1ington, IIQt 20515
February 17, 2012
The Honorable Julius Genachowski
Chairman
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554
Re: Connect America Fund
A National Broadband Plan for Our Future
Establishing Just and Reasonable Rates for
Local Exchange Carriers
High-Cost Universal Service Support
Developing a Unified Intercarrier
Compensation Regime
Federal-State Joint Board on Universal
Service
Lifeline and Link-Up
Universal Service Reform-Mobility Fund
Dear Chairman Genchowski:
WC Docket No. 10-90
GN Docket No. 09-51
WC Docket No. 07-135
WC Docket No. 05-337
CC Docket No. 01-92
CC Docket No. 96-45
WC Docket No. 03-109
WT Docket No. 10-208
We are writing to highlight the comments submitted by the Copper Valley
Telephone Cooperative, neadquartered in Valdez, Alaska, that were filed with the
commission on January 17, 2012. While we also share some concerns expressed by
other organizations regarding the proceedings listed above, we would appreciate your
particular consideration of those expressed by Copper Valley..
Alaska presents unique challenges for telecommunications service providers.
The state has several carriers with small rates of return that operate in rural areas.
These carriers serve extremely sparse and isolated populations in some of the most
remote communities in the nation. These carriers contend with a lack ofroads, difficult
topography, and the harshest climate in the country. As a result, these carriers' existing
investments in telecommunications and their plans for future investments are critical for
Alaskans.
We have heard from Copper Valley and other rural telecommunications providers
regarding Universal Service reforms detailed in the FCC's notice of proposed
rulemaking (NPRM) released late last year. Comments filed on January 18 by the
Organization for the Promotion and Advancement of Small Telecommunications
Companies (OPASTCO) and the Western Telecommunications Alliance examine the
FCC's application of quantile regression analysis. We urge you to strongly consider the
observations of Dr. Roger Koenker, the creator of the quantile regression analysis, as
outlined in Exhibit E of the filing. Additionally, Copper Valley raises a number of
pertinent issues with the most recent high cost NPRM regarding the legal standing of
PAINTED ON RECYCLED PAPER
creating regression caps that apply to existing capital investment. Such ratemaking
should clearly reflect the principles codified in the Telecommunications Act of 1996.
Accordingly, we urge the FCC to take into consideration Alaska's unique situation
when applying statistical modeling techniques, including the proposed quantile
regression analysis. Exempting Alaska-based carriers from the modeling may be an
appropriate solution, and we welcome a discussion on this issue. However, if this
exemption is not possible, the Commission should delay by two years planned
implementation of all recently adopted rules for all carriers in rural Alaska, including
CETCs and ILECs, to provide additional time to fully understand the impact on their
ability to provide advanced services to residents. Often, it is more difficult for metrics to
fairly take into account the obstacles faced by rural carriers. Additional time would
provide for a more thorough assessment of the NPRM's impact on high cost carriers in
Alaska and allow the carriers to adequately prepare for the new regulations.
Thank you for taking the time to consider Copper Valley's comments and the
concerns of carriers in Alaska. Should you have any questions or would like any
additional information, please contact Jason Suslavich with Congressman Don Young at
(202) 225-5765 or jason.suslavich@mail.house.gov, Jeremy Price with Senator Lisa
Murkowski at (202) 224-6665 or jeremYJlrice@murkowskLsenate.gov, and Andrea
Sanders with Senator Mark Begich at (202) 224-3004 or
andrea_sanders@begich.senate.gov.
Sincerely,
~~1~1o=0~~S~k~i~~~~'t.e.-.-
Senator Senator
CC: Commissioner Clyburn
Commissioner McDowell