RTG’s comments are focused on the issues outlined by the Universal Service Administrative Company (USAC) that most affect RTG’s rural, wireless competitive eligible telecommunications carrier (ETC) membership. Specifically, RTG opposes retroactive punishment of ETCs that failed to advertise all nine specific supported services if the FCC determines that such a specific listing is required. In a similar vein, RTG opposes any remedial actions against carriers that did not maintain documentation for periods being audited prior to the establishment of the explicit high-cost program document retention rule effective March 1, 2008. Further, RTG opposes any implementation of the company-specific caps for AT&T and Alltel prior to implementation of the already arbitrary and discriminatory competitive ETC interim cap.  Click here for a copy of the Comments.