Reply Comments to Oppositions to Reconsideration of FCC’s Second R&O
NATOA and its partners (NLC, NACo, USCM, ACM, ACD) submitted Reply Comments in response to Oppositions by Verizon, NCTA and Hawaii to our Petition for Reconsideration of the Commission’s Second
Report and Order in which the Commission extended its new franchising rules and
interpretations to incumbent operators. On February 11, Verizon and NCTA filed
comments in Opposition to the Petitions in which they argued, in part, that the
Second Order applied to ALL incumbent operators, even in those states that have
enacted state-level franchising legislation. The State of

