NECA filed comments yesterday on the FCC's FNPRM proposing to extend the current Part 36 freeze of category relationships and jurisdictional cost allocation factors applicable to incumbent local exchange carriers. NECA strongly recommended the current freeze, last extended in 2014, be extended for at least 18 months past the July 1, 2017 expiration, pending a separations rules recommendation from the Federal-State Joint Board on Separations.
NECA noted the FCC has recognized separations reform as being intertwined with changes to universal service and intercarrier compensation rules and is pleased the FCC is working closely with the Joint Board on its separations rules review and recommendation. NECA suggested the Commission consider the timing of the adoption of the Joint Board's revised separations procedures recommendation and implement the freeze period accordingly, such as adding six months after any revised separations rules become final. This will allow RLECs to accurately conform their cost studies and other reports and avoid the need for a freeze extension beyond the current proceeding.