March 13, Enclosed for filing in the above-referenced matter, please find Reply Comments of the Michigan Cable Telecommunications Association.

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1 124 West Allegan Street, Suite 1000 Lansing, Michigan T (517) F (517) Michael S. Ashton (517) March 13, 2012 Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 6545 Mercantile Way, Ste. 7 Lansing, MI RE: MPSC Case No. U Dear Ms. Kunkle: Enclosed for filing in the above-referenced matter, please find Reply Comments of the Michigan Cable Telecommunications Association. Very truly yours, Fraser Trebilcock Davis & Dunlap, P.C. MSA/ab Enclosure Michael S. Ashton FRASER TREBILCOCK DAVIS & DUNLAP PC LANSING DETROIT

2 STATE OF MICHIGAN BEFORE THE PUBLIC SERVICE COMMISSION In the matter, on the Commission's own motion, ) to solicit public comments regarding the ) Commission's administration of the Federal ) Case No. U Communications Commission's order on ) Comprehensive Universal Service Fund and ) Intercarrier Compensation reform. ) ) I. INTRODUCTION REPLY COMMENTS OF THE MICHIGAN CABLE TELECOMMUNICATIONS ASSOCIATION The Michigan Cable Telecommunications Association ("MCTA") filed its original comments in this proceeding to encourage the Michigan Public Service Commission ("Commission") to harmonize the Michigan Telecommunication Act's ("MTA") intrastate access restructuring mechanism with the Federal Communications Commission's ("FCC") Report and Order and Further Notice of Proposed Rulemaking, released November 18, 2011, FCC , WC Docket No , et al, ("ICC/USF Order ). The FCC s ICC/USF Order establishes a uniform, national framework for the transition of terminating intercarrier compensation to billand-keep, with an accompanying federal recovery mechanism. 1 In adopting its uniform and national framework, the FCC specifically included intrastate terminating access service and stated that in mitigating the effects of the reduced intercarrier revenues, providers are required to "look first to their subscribers to cover the costs" of their own networks. 2 The FCC's goal is to create an incentive-based, market-driven approach to intercarrier compensation that will reduce 1 ICC/USF Order at Id., at 34.

3 arbitrage and competitive distortion and create for all providers the appropriate incentives to invest in modern, IP networks. 3 In its initial comments, the MCTA requested that the Commission harmonize the MTA's access restructuring mechanism with the federal recovery mechanism to prevent over recovery by eligible providers. The Commission's failure to harmonize the state mechanism with the federal mechanism may cause the very arbitrage and competitive distortions the FCC's ICC/USF Order seeks to eliminate. Similarly, the initial comments filed by Michigan Bell Telephone Company, d/b/a AT&T Michigan ("AT&T"), Frontier Communications and a group of Michigan competitive local exchange carriers ("CLECs"), 4 also raised concerns with respect to over recovery by eligible providers with respect to the state restructuring mechanism. These comments reinforce the concerns raised by the MCTA and the Commission should utilize this proceeding to prevent any over recovery by eligible providers. In addition, AT&T and the Telecommunications Association of Michigan ("TAM") requested that the Commission initiate a new proceeding to determine whether interconnected voice over internet protocol ("interconnected VoIP") providers should be required to contribute to the state restructuring mechanism. This request is fundamentally flawed because it is outside the scope of this proceeding and ignores that Section 310(12) of the MTA specifically excludes interconnected VoIP providers from contributing to the state restructuring mechanism. While both AT&T and TAM cite to Section 310(13) which under certain circumstances allows the Commission to consider whether interconnected VoIP providers may contribute to an intrastate universal service fund, the state restructuring mechanism is not an intrastate universal service 3 Id., at 9. 4 This group of Michigan CLECs is comprised of ACD Telecom, Clear Rate Communications, TC3 Telecom and Telnet Worldwide. 2

4 fund. As the Commission has recognized in the past, the structure of the MTA makes clear that the access restructuring mechanism (which is governed by Section 310 of the MTA) is separate and distinct from an intrastate universal service fund (which is governed by Section 316a of the MTA). In addition to the unequivocal legal prohibition which prevents interconnected VoIP providers from having to pay into the state restructuring mechanism, there are also sound policy reasons resulting from the ICC/USF Order to reject such efforts. II. REPLY COMMENTS A. The Commission Should Take Action to Avoid Over Recovery by Eligible Providers The Michigan CLECs' comments raise a concern as to whether Michigan s restructuring mechanism is now preempted by the FCC s ICC/USF Order. The Michigan CLECs comments state: Accordingly, given that the FCC established a comprehensive recovery mechanism for lost intrastate access revenues, the ability of ILECs to obtain a similar recovery pursuant to the restructuring mechanism of Act is preempted and no longer applies. One recovery mechanism is sufficient, and the FCC has now provided such a mechanism. (CLECs' Comments at pages 8-9, footnote added.) While the MCTA did not take a position as to whether the Michigan restructuring mechanism was preempted by the ICC/USF Order, the CLECs raise a significant issue because the FCC s comprehensive framework includes intrastate terminating access service and establishes a federal recovery mechanism. Even if the entire Michigan restructuring mechanism is not preempted by federal law as suggested by the Michigan CLECs, clearly those portions that are inconsistent with federal law or interfere with the goals of the federal framework for intercarrier PA 182 ("Act 182") amended Section 310 of the MTA and, among other things, required a reduction in intrastate access charges, created a state restructuring mechanism and allowed certain eligible providers to be compensated for their access rate reductions from the state restructuring mechanism. 3

5 compensation reform would be preempted. For example to the extent that the Michigan mechanism when combined with the federal mechanism allows for over recovery by eligible providers, it will interfere with the FCC's twin goals of (1) creating an incentive-based, marketdriven approach to intercarrier compensation and (2) eliminating arbitrage and competitive distortion. Frontier also raises a concern regarding the over recovery by certain rate-of-return regulated providers. Frontier's comments stress that for this class of providers, Section 310 of the MTA merely required that they mirror their intrastate access rates to their interstate access rates. While this resulted in the initial lowering of intrastate access rates for these providers, it did not prevent these providers from increasing their interstate access rates and thereby also increasing their intrastate access rates. According to the data presented by Frontier, a significant number of rate-of-return providers who initially lowered their intrastate rates have subsequently increased their intrastate access rates. While these increases may not be expressly prohibited by the mirroring provision in Michigan law, the data presented by Frontier suggests that for some providers the increases have been substantial and are likely resulting in current over recovery from the state restructuring mechanism by several millions of dollars. As Frontier states the goal of the state law was to reduce intrastate access rates and to allow certain providers to be made whole through the state's restructuring mechanism. The purpose of the state law was never to allow over recovery. The concerns raised by Frontier that certain rate-of-return providers may already be over recovering only compounds the concern that two different recovery mechanisms will result in substantial over recovery. Any such over recovery ultimately has an adverse impact on Michigan consumers and will interfere with the FCC stated national goal to eliminate such economic 4

6 distortions as the market moves toward a bill-and-keep system. As a result of the information provided by Frontier, the Commission should conduct a contested case to ensure that the federal mechanism and the state mechanism do not result in over recovery. Similarly, AT&T raises two concrete examples with respect to potential over recovery. Pursuant to Section 310(16) of the MTA, AT&T notes that the size of Michigan's restructuring fund is to be recalculated in 2014 and The purpose of this recalculation is to adjust the size of the restructuring fund for the differences which have occurred over time between the eligible providers' intrastate access rates as of July 1, 2009 and their intrastate access rates due to the mirroring requirements imposed by state law. Yet as AT&T explains, this recalculation pursuant to state law is not intended to reflect the differential caused by the reduction of interstate access rates due to the ICC/USF Order. Starting on July 1, 2014 interstate terminating access rates will begin their decline to $.0007 and then to bill-and-keep, and if such interstate rate reductions are used in the recalculation required under Section 310(16) in 2014 and 2018, the difference and thus the size of the state restructuring mechanism will be larger than that caused merely by the state law's mirroring requirement. As AT&T correctly points out this would cause an improper increase in the size of the state restructuring mechanism which this Commission should address in this proceeding. The other issue raised by AT&T is that eligible providers will be able to utilize the federal recovery mechanism to recover loss revenue due to the reductions in access rates caused by the ICC/USF Order. As AT&T states: Since the Michigan ILECs will be compensated from federal sources, it makes no sense to allow them to be compensated from the state fund for the same rate reduction. This would be overrecovery of the worst sort and should be prevented. (AT&T Comments at pages ) 5

7 AT&T's comments support the need to harmonize Michigan's restructuring mechanism with the FCC's ICC/USF Order. For all the reasons set forth above, the Commission should conduct a contested case to ensure that the federal recovery mechanism and the state mechanism do not result in over recovery by eligible providers. B. Interconnected VOIP Providers may not be Required to Contribute to the State Restructuring Mechanism Both AT&T and TAM erroneously suggest that the Commission should initiate a new proceeding to consider whether interconnected VoIP providers should be required to contribute to the state restructuring mechanism. This issue is completely outside the scope of this proceeding and directly conflicts with Section 310(12) of the MTA, which unequivocally excludes interconnected VoIP providers from paying into the state's restructuring mechanism. In an effort to require contributions from interconnected VoIP providers, AT&T and TAM attempt to erroneously classify the state access restructuring mechanism as an intrastate universal service fund. Yet, this position conflicts with the MTA and the previous position taken by the Commission. The Commission initiated this proceeding to examine the impact of the FCC's ICC/USF Order on the state restructuring mechanism or other provisions of the MTA. TAM candidly admits that nothing in the ICC/USF Order supports the claim that interconnected VoIP providers should be required to pay into Michigan's restructuring mechanism. (TAM Comments at page 13.) Neither TAM nor AT&T rely upon any provision of the ICC/USF Order to support an argument that interconnected VoIP providers should be included in the state restructuring mechanism. For this reason alone, their suggestion to require interconnected VoIP providers to 6

8 pay into the state's restructuring mechanism should be rejected as outside the scope of this proceeding. Both AT&T and TAM also ignore that the Michigan Legislature unequivocally prohibited interconnected VoIP from contributing to the state restructuring mechanism. Section 310(12) unequivocally states: The restructuring mechanism shall be created and supported by a mandatory monthly contribution by all providers of retail intrastate telecommunications services and all providers of commercial mobile service. Interconnected voice over internet protocol services shall not be considered an intrastate telecommunications service for the purposes of this section and interconnected voice over internet protocol service providers shall not be required to pay, directly or indirectly, the mandatory monthly contributions established in this subsection. A provider of telecommunications services to a provider of interconnected voice over internet protocol services shall not pay a mandatory monthly contribution related to those interconnected voice over internet protocol services or attempt to pass through any mandatory monthly contributions, directly or indirectly, to a provider of interconnected voice over internet protocol services. Nothing in this act grants the commission authority over commercial mobile service providers or voice over internet protocol service providers except as is strictly necessary for administration of the restructuring mechanism. (Emphasis added.) Section 310(12) makes clear that interconnected VoIP service is not an intrastate telecommunications service and, thus, interconnected VoIP providers are not required to pay into the state restructuring mechanism for intrastate access. Nothing in the FCC/USF Order modified the prohibition set forth in Section 310(12) and any effort by AT&T and TAM to require interconnected VoIP providers to contribute to the state restructuring mechanism violates Section 310(12). Instead of relying upon any provision of the ICC/USF Order to support an argument that interconnected VoIP providers should pay into the state restructuring mechanism, AT&T and 7

9 TAM cite to a 2010 FCC Order 6 which allows states to require interconnected VoIP providers to contribute to intrastate universal service funds. AT&T and TAM then cite Section 310(13), which provides that the MTA's unequivocal prohibition against requiring interconnected VoIP providers to pay into the state intrastate access restructuring fund would not necessarily bar interconnected VoIP providers from paying into a separate and distinct intrastate universal service fund. In relevant part, Section 310(13) states: Notwithstanding anything in subsection (12), if the federal communications commission determines that interconnected voice over internet protocol services may be subject to state regulation for universal services purposes, the commission may open a proceeding to determine who is required to participate in a universal service fund. AT&T's and TAM's argument is fundamentally flawed in that their argument confuses the difference between the MTA's intrastate access restructuring mechanism created by Section 310 and the potential to create an intrastate universal service fund pursuant to Section 316a of the MTA. The Commission has already rejected the argument that the state restructuring mechanism established by Section 310 is a universal service fund. When the Michigan Legislature amended Section 310 of the MTA to create the restructuring mechanism, a group of Michigan CLECs filed a petition with the FCC claiming that the restructuring mechanism violated universal service fund requirements set forth in federal law. In response, this Commission unequivocally stated that the state restructuring mechanism was not a universal service fund. Before the FCC, the Commission stated: 6 In the Matter of Universal Service Contribution Methodology, Universal Service Contribution Methodology; Petition of Nebraska Public Service Commission and Kansas Corporation Commission for Declaratory Ruling or, in the Alternative, Adoption of Rule Declaring that State Universal Service Funds May Assess Nomadic VoIP Intrastate Revenues, WC Docket No , Declaratory Ruling 25 FCC Rcd (rel. October Nov. 5, 2010). 8

10 Act 182 [the Public Act which amended Section 310] does not fall under the MTA's provision for a state universal service fund. That is a separate and distinct provision codified at 316a of the MTA. Since the restructuring mechanism found in Act 182 is not a universal service fund, it cannot possibly fail to comply with provisions of FCC regulations that govern universal service funds. 7 As the Commission earlier recognized, the state restructuring mechanism is separate and distinct from the intrastate universal service fund, which may be created pursuant to the MTA. Thus, Section 310(13) has no bearing whatsoever on the determination of whether interconnected VoIP providers pay into a the state's restructuring mechanism and leaves unaffected the unequivocal prohibition set forth in Section 310(12). A comparison of Section 310's restructuring mechanism and the universal service fund which may be created by Section 316a demonstrate that the two serve unrelated purposes. Section 310 was amended to reduce intrastate access rates paid by other intrastate providers. To lessen the burden on certain eligible providers, Section 310 creates the state restructuring mechanism to offset lost intrastate access revenues. This state access restructuring mechanism is funded by all intrastate telecommunication providers who are also benefitted from the reduction of the intrastate access rates. The purpose of Section 310 was to reduce intrastate access rates and temporarily created the restructuring mechanism funded by intrastate service providers; it did not create a universal service fund. In comparison, Section 316a of the MTA empowers the Commission to create an intrastate universal service fund to subsidize residential local exchange service when "an affordable rate" is below a provider's "forward looking economic cost." MCL a. Thus, 7 In the Matter of Joint Michigan CLEC Petition for Declaratory Ruling and Motion for Temporary Relief, WC Docket No , March 9, 2010 Comments of the Michigan Public Service Commission at page 14. 9

11 the purpose of the intrastate universal service fund is markedly different from the state's access restructuring mechanism. The intrastate universal service fund subsidizes residential local service rates to insure customers receive an affordable rate. In contrast the state's access restructuring mechanism is designed to compensate certain eligible providers for reducing their intrastate access rates charged to other intrastate providers. These are two vastly different statutory programs created by the MTA and any effort by AT&T and TAM to describe the state's restructuring mechanism as a universal service fund ignores the MTA's plain language. In addition to the above legal provisions which prohibit interconnected VoIP providers from being required to contribute to the state intrastate access mechanism, there are also sound policy reasons to exclude interconnected VoIP providers from paying into the state mechanism. These policy reasons include that fact that the FCC's ICC/USF Order adopted a "prospective intercarrier framework for VoIP traffic," which includes a transitional default compensation rate for toll traffic "equal to interstate access rates." 8 The FCC recognized that its transitional treatment of VoIP traffic provides rural carriers with yet another opportunity to obtain additional revenues in conjunction with the other portions of the FCC's comprehensive reforms. 9 Thus, the ICC/USF Order establishes the appropriate treatment of VoIP traffic in the transition to a national bill-and-keep system. Finally, given the very real risk that the newly established federal framework in conjunction with the existing state mechanism will result in over recovery, the scope of the state mechanism should not be expanded to include interconnected VoIP providers, but instead it needs to be curtailed and harmonized with the federal framework to prevent over recovery. 8 ICC/USF Order at Id.,

12 III. CONCLUSION For the reasons set forth in its initial comments and reply comments, MCTA encourages the Commission to conduct a contested case to harmonize the state restructuring mechanism with the federal recovery mechanism to prevent over recovery by eligible providers. The FCC's goal in creating its new intercarrier compensation framework was to create an incentive-based, market approach to intercarrier compensation and reduce arbitrage in competitive distortion. If the Commission does not harmonize the state mechanism with the federal mechanism, then arbitrage and competitive distortion may occur and frustrate the FCC's goal to create for all providers the appropriate incentives to invest in modern, IP networks. Furthermore, the Commission should reject any effort to include interconnected VoIP providers as contributing providers to the state restructuring mechanism because such a request is outside the scope of this proceeding and directly violates the prohibition set forth in Section 310(12) of the MTA. Respectfully Submitted, Fraser Trebilcock Davis & Dunlap, P.C. Counsel for Michigan Cable Telecommunications Association Date: March 13, 2012 By: Michael S. Ashton (P40474) 124 West Allegan Street, Suite 1000 Lansing, Michigan Telephone: (517) Facsimile: (517)

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