In comments that respond to a recent joint petition filed by the Nebraska Public Service Commission (NPSC) and the Kansas Corporation Commission (KCC), state regulators and their supporters urged the FCC to immediately issue a declaratory ruling that authorizes the states to collect intrastate universal service fund (USF) contributions from nomadic voice-over-Internet protocol (VoIP) providers. By contrast, Vonage Holdings said the FCC should not proceed without first conducting rulemaking proceedings, while AT&T argued that a rulemaking is needed as the FCC’s 2004 Vonage order “plainly” as that order “clearly distinguishes state USF assessments from the state entry and economic regulation that the FCC did preempt.” On behalf of the states, the National Association of Regulatory Utility Commissioners (NARUC) observed that a 2006 FCC order requiring VoIP operators to base federal USF contributions on 64.9% of their revenues assumes that that figure would encompass interstate traffic, thus leaving the remaining revenues in the intrastate category. As such, NARUC urged the FCC to “immediately issue an interpretive rule clarifying that states may access nomadic VoIP providers to support state [USF] programs based on the complement to the federal safe harbor.” The National Exchange Carrier Association, the National Telecommunications Cooperative, and other advocates for small carriers backed NARUC’s call for quick action, declaring that “prompt issuance of a declaratory ruling will help preserve the integrity of state universal service funding mechanisms and help assure competitive fairness.” However, as AT&T called for a “targeted and expeditious rulemaking proceeding,” Verizon Communications and Verizon Wireless advised the FCC against separating the issues raised by NPSC and KCC from “the overarching and outstanding questions regarding classification of VoIP and IP-based services.”