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WC 10-90: USTelecom comments on ACS Application for Review


USTelecom is pleased to submit these comments in response to the Wireline Competition Bureau’s (“Bureau”) Public Notice concerning the Application for Review (“Application”) of Alaska Communications Systems (“ACS”) of paragraph 41 of the Connect America Phase II Service Obligations Order (“CAF II Obligations Order”). ACS requests that the Commission reverse, or, in the alternative, stay the Bureau’s statement in paragraph 41 of the CAF II Obligations Order that it would entertain challenges from any competitive eligible telecommunications carrier (“ETC”) that otherwise meets or exceeds the performance obligations established by that order and who high-cost support is scheduled to be eliminated during the five-year term of Phase II. USTelecom agrees with ACS that the Bureau’s interpretation of the definition of “unsubsidized voice and broadband provider” is incorrect, inconsistent with the intent of the Commission in the USF/ICC Transformation Order, and is bad public policy. The Commission should promptly grant the ACS Application.