Ad Hoc Coalition files comments in response to a request for guidance from the FCC by USAC

On April 1, 2011, the Coalition filed comments in response to a request for guidance from the FCC by USAC.  USAC presented the question whether it may base an “audit finding” (evidence of a rule violation) on post-dated reseller certificates submitted by contributing wholesalers to support their expectation that a reseller would contribute directly to the USF.  The Coalition reiterated its position as articulated in its petitions for declaratory ruling- that the CCR as applied by USAC is rife with inequities and violates FCC rules.  Instead of addressing USAC’s discrete question, the Coalition urged the Commission to consider the broader issues it raised in its petitions and to reform the entire carrier-to-carrier exemption process.

Link >>