​NRECA, along with the American Gas Association, the American Public Power Association, and the Edison Electric Institute, filed reply comments with the Federal Communications Commission (FCC) regarding implementation of the Telephone Consumer Protection Act (TCPA) with respect to automatic dialing systems. The comments address (1) what should constitute "using any automatic dialing system" under TCPA and (2) the Commission's authority to adopt a new safe harbor to replace the "one call safe harbor" approach to addressing calls made to reassigned wireless numbers under TCPA. FULL FILING