USTelecom, ITTA Seek At Least 12 More Weeks for Special-Access Comments

USTelecom and ITTA asked the FCC to further extend the special-access comment period due to various complexities in the proceeding examining ILEC rates for dedicated circuits, particularly regarding sensitive industry data submitted on the business service market. “The commission’s data collection effort is a unique and massive undertaking. Providing three months to properly analyze and understand the data is consistent with the fact-based approach the commission has taken. The potential value of this information should not be squandered by a rushed analysis,” said USTelecom Senior Vice President Jon Banks in a Tuesday blog post. Although the Wireline Bureau "recently extended the comment schedule -- with comments now due January 6, 2016, and reply comments due February 5, 2016 -- the current schedule does not provide the opportunity for the careful and searching analysis that this proceeding requires," the telco groups said in a filing Tuesday in docket 05-25: "As clearly and carefully detailed [in an declaration submitted by an industry expert], the current data set is not yet stable, and the necessary tools to fully analyze the data are not in place. Given the enormity of the data set, the complexity of the industry and the importance of it to our economy, once the data are stable and the necessary software and tools are available, twelve weeks will be necessary to provide the meaningful opportunity to analyze the data and prepare comments required by the Administrative Procedures Act. ... Specifically, we request that the Commission extend the due date for opening comments until at least twelve weeks after two criteria have been satisfied: (1) the Commission issues a Public Notice confirming that the data set has been finalized and a change control process has been instituted for any further modifications (including explanations for all future changes); and (2) all software and tools necessary to conduct relevant data analysis have been made available by NORC [National Opinion Research Center, a University of Chicago institution]." ILEC representatives recently raised concerns about data's reliability (see 1511050053).