In comments filed by the American Cable Association, the group encouraged the Federal Communications Commission “to fix identified problems with the current Universal Service Fund (USF) contribution system while continuing to collect data and information on the harms and benefits of expanding the base to include broadband before deciding on the best course of action going forward.” ACA believes the current contribution regime “is too complex and often produces arbitrary outcomes.” Here are some of its suggested improvements: increasing the de minimus threshold from $10,000 in annual contributions to $200,000 in annual assessable revenues; allow smaller contributors to elect to rely on the prior year’s traffic study when preparing Form 499-Qs and require only one traffic study filing per year in connection with the Form 499-A; eliminate the need to file a traffic study when a VoIP provider determines its jurisdictional allocations by measuring 100 percent of its traffic for the reporting period, which is actual interstate revenue and not a statistical sample; and revisit and revise downward the VoIP safe harbor for allocating interstate/intrastate usage to reflect the fact that interstate usage of cable operator voice services is usually far less than the 64.9-percent allocation adopted six years ago…The Telecommunications Industry Association (TIA) filed a Petition for Rulemaking with the FCC regarding allowing non-exclusive option of electronic labeling on wireless devices.  TIA said that the move would ease technical and logistical burdens on manufacturers while increasing end user access to useful information about their devices. Comments Danielle Coffey, vice president/Government Affairs, “TIA is asking the FCC to move forward with making electronic labeling for all wireless devices a default option. Not only does it more effectively meet end-user expectations while continuing the FCC’s comprehensive device labeling framework, it also will streamline manufacturing processes, lower costs, reduce prices and encourage innovation.”

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