Three carriers – Windstream Services LLC, Frontier Communications Corporation and Consolidated Communications Inc. – have met with the FCC to express their support for the Commission’s plan to detariff Telephone Access Charges (TAC). But their support contains suggestions to make the plan more acceptable to ILECs.
To address jurisdictional issues and potential revenue losses, they suggest TAC recovery through an interstate line item. Allowing this to be presented as a carrier-identified charge would satisfy Truth-in-Billing rules.
The three carriers also propose a transition for existing business contracts to allow recovery consistent with these contract terms. Lastly, they recommend adoption of the NPRM’s proposal to apply a 25% safe harbor and permit traffic studies which, in concert with the line item charge, would “minimize any contribution implications.”
They also correctly argue that permissive detariffing, rather than a mandatory system, would address concerns about implementation difficulties for smaller ILECs.
We agree. Permissive detariffing, at least for RLECs, would give them a reasonable choice. And if they were to choose the detariffing option, the interstate line item, contract transition period, and safe harbor suggestions should protect this vital revenue stream.
