mr NOAH CHERRY

S. 1353 (Cybersecurity Act of 2013) and H.R. 624 (Cyber Intelligence Sharing and Protection Act) -- WTA continued advocating for key liability protections that should be in place for small telecommunications carriers in an effort to enable information sharing between private industry and government agencies. The association continued advocating the National Institutes of Standards & Technology's (NIST's) Cybersecurity Framework should remain voluntary and non-prescriptive, that incentives encouraging adoption should be geared toward helping to defray the costs of implementing the plan.

Universal Service and Intercarrier Compensation Reform -- WTA continued sharing information with policymakers about how the Federal Communications Commission's 2011 USF/ICC Transformation Order is affecting rural local exchange carriers (RLECs) and their abilities to use universal service funds to invest in advanced networks to provide better broadband and extending it further into their service territories. WTA has also advocated for policymakers to begin to address USF Contribution Reform -- the mechanism by which consumers contribute to the Universal Service Fund. WTA also focused its attention on a provision within the 2011 Transformation Order which requires the FCC to conduct a survey of urban telephone rates as a means of setting the "floor" for such rates in rural areas. The association continued focusing its efforts on promoting the Data Only Broadband Plan which would help increase broadband take-rates in rural communities. The Plan also meets the requirements in the Communications Act which calls for reasonably comparable rates and services between urban and rural communities. Evolution of the Public Switch Network (PSTN) to Internet Protocol (IP) -- WTA continued sharing with policymakers stories and anecdotes about how RLECs continue to incorporate more IP technology into their networks as a way to maximize limited resources and to provide additional services to their customers. E-Rate Modernization -- WTA supports modernizing the E-Rate program and has offered many key suggestions to reforming the program. In particular, WTA continued advocating against using E-Rate funds to build new networks when existing infrastructure can be leveraged to expand and meet the broadband needs of schools and libraries. Communications Act Update -- WTA commented on the House Energy and Commerce's Communications and Technology's Subcommittee's White Papers regarding updating the Communications Act of 1934 (as amended). WTA shared its comments and thoughts with the Members of that Subcommittee and others interested in communications matters. Call Completion -- WTA lobbied in support of S. 2125, Public Safety and Economic Security Communications Act of 2104. The legislation would require all voice calls to be terminated regardless of whether they were destined for urban or rural areas. Specifically, it requires an intermediate provider that offers the capability to transmit certain voice communications and signaling information from one destination to another, and that charges a rate to any other entity (including an affiliated entity) for the transmission, to: (1) register with the Federal Communications Commission (FCC), and (2) comply with service quality standards to be established by the FCC.

Universal Service and Intercarrier Compensation Reform -- WTA continued sharing information with policymakers about how the Federal Communications Commission's 2011 USF/ICC Transformation Order is affecting rural local exchange carriers (RLECs) and their abilities to use universal service funds to invest in advanced networks to provide better broadband and extending it further into their service territories. WTA has also advocated for policymakers to begin to address USF Contribution Reform -- the mechanism by which consumers contribute to the Universal Service Fund. WTA also focused its attention on a provision within the 2011 Transformation Order which requires the FCC to conduct a survey of urban telephone rates as a means of setting the "floor" for such rates in rural areas. The association continued focusing its efforts on promoting the Data Only Broadband Plan which would help increase broadband take-rates in rural communities. The Plan also meets the requirements in the Communications Act which calls for reasonably comparable rates and services between urban and rural communities. Evolution of the Public Switch Network (PSTN) to Internet Protocol (IP) -- WTA continued sharing with policymakers stories and anecdotes about how RLECs continue to incorporate more IP technology into their networks as a way to maximize limited resources and to provide additional services to their customers. E-Rate Modernization -- WTA supports modernizing the E-Rate program and has offered many key suggestions to reforming the program. In particular, WTA continued advocating against using E-Rate funds to build new networks when existing infrastructure can be leveraged to expand and meet the broadband needs of schools and libraries. Communications Act Update -- WTA commented on the House Energy and Commerce's Communications and Technology's Subcommittee's White Papers regarding updating the Communications Act of 1934 (as amended). WTA shared its comments and thoughts with the Members of that Subcommittee and others interested in communications matters. Call Completion -- WTA lobbied in support of S. 2125, Public Safety and Economic Security Communications Act of 2104. The legislation would require all voice calls to be terminated regardless of whether they were destined for urban or rural areas. Specifically, it requires an intermediate provider that offers the capability to transmit certain voice communications and signaling information from one destination to another, and that charges a rate to any other entity (including an affiliated entity) for the transmission, to: (1) register with the Federal Communications Commission (FCC), and (2) comply with service quality standards to be established by the FCC.

Universal Service Reform -- WTA continued meeting with policymakers to discuss the effects of the Federal Communications Commission's (FCC's) 2011 USF-ICC Transformation Order. Specifically, we discussed concerns with the increased obligations for companies to provide more broadband but within the FCC's limited "targeted" budget; concerns regarding the imposition of a local voice service rate benchmark which is based off of an average of voice rate service in urban areas; the need for a Connect America Fund (CAF) for rate of return (ROR) carriers that is broadband-focused and that allows carriers to obtain USF support for their customers that only want the carrier's broadband service and not voice service; and support for the targeted reinstallation of safety net additive support (SNA) for a limited number of companies. IP-Transition -- WTA continued to share information with policymakers about how ROR carriers continue to implement IP technologies into their underlying network infrastructure. E-Rate Modernization -- WTA continued to express its support for modernizing the E-Rate program. It expressed concerns regarding consortiums having sole authority over which entities participate in the process of determining how schools and libraries receive broadband connections using e-rate funds. WTA members shared stories of being excluded from the participating in the bidding process and how that actually affected pricing of services for schools. Call Completion -- WTA continued advocating that calls to rural areas be completed as the problem has not been eliminated. We lobbied in support of S. 2125, the Public Safety and Economic Security Communications Act of 2014, which would require all voice calls to be terminated regardless of whether they were destined for urban or rural areas. WTA also lobbied in support of two Sense of Congress Resolutions in the House and Senate calling on calls to be terminated in rural areas. Net Neutrality -- WTA shared its views on this matter with policymakers. In particular, WTA expressed the need and desire to be able to effectively manage its network so that all of its customers have a quality broadband experience, but also expressed the need to be able to gain access to content and to do so at reasonable costs. Rural Broadband Experiments -- WTA lobbied in support of the FCC's rural broadband experiments. We shared insight on how these experiments may help to extend broadband service in high-cost rural areas where it is either below the current minimum speeds or non-existent at this time. Municipal/Public Broadband -- WTA met with policymakers to share its concerns regarding the municipal broadband systems. Communications Act Update -- WTA responded to the House Commerce Committee's CommAct Update paper regarding the nation's competition policy and the role of the FCC. The association spent time talking with congressional staffers about its position.

H.R. 3719, The Video Choice Act of 2013 and the Television Consumer Freedom Act of 2013 -- WTA continued its advocacy support for these pieces of legislation which would provide some relief for rural local exchange carriers (RLECs) that are in the video business with regard to gaining access to content, the prices they pay concerning retransmission consent agreements and the forced tying associated with programming.

S. 1353 (Cybersecurity Act of 2013) and H.R. 624 (Cyber Intelligence Sharing and Protection Act) -- WTA continued talking with congressional offices about key liability protections that should be in place that would enable information sharing between private industry and U.S. government agencies. WTA also submitted comments regarding the National Institutes of Standards & Technology's (NIST's) Cybersecurity Framework. In regard to the Framework, WTA continued to express that it should remain voluntary and non-prescriptive, that incentives encouraging adoption of the Framework should be geared toward helping to defray the costs of implementing such a plan, especially for small rural local exchange carriers (RLECs) that operate critical infrastructure and that are subject to operating expense caps.

H.R. 624 Cyber Intelligence Sharing and Protection Act and S. 1353 Cybersecurity Act of 2013 -- WTA has been talking with congressional offices about key liability protections that should be in place that would enable information sharing between private industry and U.S. government agencies. Specifically, the NIST Cybersecurity Framework should remain voluntary and non-prescriptive; incentives aimed at encouraging adoption of the Framework should be aimed to help defray the costs of implementing a cyber plan, especially for small rural local exchange carriers (RLECs) that operate critical infrastructure and are subject to operating expense caps.

Universal Service and Intercarrier Compensation Reform -- WTA continued its lobbying efforts focusing on how provisions in the Federal Communications Commission's 2011 Transformation Order are adversely affecting rural local exchange carriers' (RLECs) inabilities to build out and modernize their networks to meet their customers' current and future broadband needs. As part of our lobbying WTA has shared numerous proposals that would provide RLECs with more certainty and predictability to meet their customer's broadband requirements. Rate of Return Represcription -- WTA has lobbied against an FCC staff report that would lower the current authorized interstate rate of return for ILECs. WTA has demonstrated how this would negatively affect small carriers' abilities to obtain reasonable financing to modernize their networks. USF Support for Data-Only Broadband -- WTA has discussed allowing support for Data-Only Broadband as a way to increase broadband adoption in rural areas and also as a way to make broadband more affordable for consumers living in these communities. Evolution of the Public Switched Telecommunications Network (PSTN) from TDM to an Internet Protocol-based Network -- WTA continued discussing how RLECs' current TDM networks are transitioning to ones that are more IP-based. Rural Call Completion -- WTA continued it lobbying efforts to have Congress and the FCC resolve this national problem (i.e., calls originating outside of rural areas and not being terminated/completed in rural calling areas). USF Contributions Reform -- WTA continued to stress the need for Congress and the FCC to address the contributions-side of USF reform (e.g., the way individuals contribute into the Universal Service Fund), especially since the FCC has already addressed the distribution mechanism in the 2011 USF/ICC Transformation Order. WTA lobbied on the benefits that reform would bring and why it is important to do so. E-Rate Modernization -- WTA lobbied in support of reforming the E-Rate program in ways that better use the limited E-Rate funds and that leverage existing infrastructure to enhance the delivery of broadband services. WTA argued for restrictions on duplicative infrastructure construction where pre-exising federal programs and recipients of support are in the process of providing broadband to community anchor institutions. WTA also discussed the difficulty of setting unnecessarily high service speed goals that are not tethered to current or near-term needs.

USF/ICC Reform -- WTA lobbied members of the Small Business Committees in the House of Representatives and the Senate regarding the impacts that the FCC's 2011 USF/ICC Transformation Order are having on small rural local exchange carriers (RLECs) abilities to grow and expand their business opportunities while also meeting their customers' broadband needs. In many instances, these RLECs are the largest business providers, and employers, in their regions.

Universal Service and Intercarrier Compensation Reform -- WTA lobbied on the effects the Federal Communications Commission's 2011 Transformation Order is having on rural local exchange carriers (RLECs) and their abilities to continue to build out and modernize their networks to meet their consumers' telecommunications and broadband needs. Our efforts have also focused on proposed fixes to provisions within the 2011 Order that would provide RLECs with more certainty and predictability to allow them to obtain public (Rural Utilities Service) and private financing to extend broadband in rural areas. USF Contributions Reform -- WTA lobbied on the need for the FCC to address how individuals contribute into the Universal Service Fund. We lobbied on the benefits that reform would bring and why it is important to do so. Rural Call Completion -- WTA lobbied on the problems RLECs and their customers are experiencing as a result of originating carriers' calls outside of rural areas not being completed in RLEC areas. WTA lobbied for the FCC to act swiftly to address this national problem.

Universal Service and Intercarrier Compensation Reform -- WTA lobbied on the effects the Federal Communications Commission's 2011 Transformation Order is having on rural local exchange carriers (RLECs) and their abilities to continue to build out and modernize their networks to meet their consumers' telecommunications and broadband needs. Our efforts have also focused on proposed fixes to provisions within the 2011 Order that would provide RLECs with more certainty and predictability to allow them to obtain public (Rural Utilities Service) and private financing to extend broadband in rural areas. USF Support for Data-Only Broadband -- WTA lobbied on the reasons why RLECs should be able to seek USF support for data-only or "standalone" broadband. We also discussed why this would be helpful to expanding broadband availability and making broadband more affordable for consumers. USF Contributions Reform -- WTA lobbied on the need for the FCC to address how individuals contribute into the Universal Service Fund. We lobbied on the benefits that reform would bring and why it is important to do so. Evolution of the Public Switched Telecommunications Network from TDM-to-Internet Protocol (IP) -- WTA discussed how RLECs have been transitioning their current Time-Division Multiplexing (TDM) networks to ones that are becoming more IP-based. We also shared specific experiences that RLECs are having with this transition. Rural Call Completion -- WTA lobbied on the problems RLECs and their customers are experiencing as a result of originating carriers' calls outside of rural areas not being completed in RLEC areas. WTA lobbied for the FCC to act swiftly to address this national problem.