The Coalition recently filed comments with the FCC reiterating its concerns about the Carrier's Carrier Rule and drawing parallels between its pending Petition and the issues currently being debated by AT&T, Verizon, et. al. The Coalition once again urged the Commission to act upon its Petition by immediately suspending all further enforcement of the Carrier's Carrier Rule and initiating a rulemaking proceeding in which to sort out and clarify its rules.
Over the course of the past several years, perhaps no single regulatory issue has confounded the wholesale telecommunications industry quite like the Carrier's Carrier Rule. And with the threat of revenue reclassification looming over wholesale providers who fail to adequately comply with the Carrier's Carrier Rule prior to reporting reseller revenue as "wholesale," perhaps no single issue carries as much potential for financial harm. Yet despite the unequivocal and well-known ambiguities and shortcomings of the Carrier's Carrier Rule (as implemented and enforced by USAC), the industry has been reluctant to tackle the issue. Now that the issue has garnered the attention of AT&T, Verizon and other Tier I providers, however, there is a rare opportunity for the industry to voice its concerns over the rule, demand FCC clarification, and until clarity is achieved, obtain a reprieve of USAC's oppressive enforcement of the ambiguous and unworkable Carrier's Carrier Rule.