On November 18, 2009, the Coalition filed an Ex Parte letter with the FCC to clarify its position regarding the injustice of "Face Value" revenue reporting; a position which had been mischaracterized by Verizon in an earlier pleading. Additionally, the Coalition took the opportunity to outline its policy position with respect to broader USF (and TRS) reform, which follows:
Prospectively, the Coalition advocates that any USF support system adopted by the FCC should achieve the objective of ensuring low cost, widely available international long distance. Furthermore, the Coalition believes that funding of any support programs should be consistent with basic concepts of fairness and aligned with existing federal precedent which is illustrative of an appropriate balancing of interests. Existing precedent results in the imposition of greater support burdens on those entities which both: (A) impose burdens on the Public Switched Telephone Network ("PSTN") and (B) derive benefits from an expansive PSTN, while striking an appropriate and equitable balance by minimizing the support burdens on those providers that do not. Beyond just the USF, the Coalition advocates applying these same basic principles of equity and fairness to all other FCC-governed federal funds, including but not limited to the Telecommunications Relay Services ("TRS") fund. Presently, there is a significant imbalance between the amount of financial support contributed to the TRS fund by international providers and the volume of international TRS usage. Therefore, to the extent the FCC undertakes comprehensive USF reform, the Coalition urges the Commission to also reform the funding mechanisms associated with the TRS and other programs in a manner which fairly and equitably applies to predominantly international and international only service providers, consistent with existing federal precedent.
A link to the full ex parte letter can be found here.