Interim Cap on Wireless CETCs
The Coalition to Keep America Connected (CKAC) applauds the Joint Board s recommendation of an interim cap on Universal Service Fund (USF) support for competitive eligible telecommunications carriers (CETCs) and urges the FCC to act on this matter immediately. The cap is a sensible remedy to explosive growth in USF support to CETCs. Failure to make these improvements will threaten the achievements and sustainability of a program crucial to consumers and our nation s future economic competitiveness.
Identical Support Rule
The Coalition to Keep America Connected (CKAC) supports the Joint Board s recommendation to eliminate the identical support rule. The identical support rule unnecessarily compensates competitive eligible telecommunications carriers (CETCs) on the basis of costs those carriers did not incur. The CKAC supports USF mechanisms that are based on a carrier s own costs. The identical support rule has contributed to excessive USF growth, and its replacement with an own costs approach will restore confidence in the USF.
Broadband
The Coalition to Keep America Connected (CKAC) strongly supports ensuring all Americans have access to the latest technologies, including broadband. The Coalition agrees with the Joint Board that more broadband deployment must occur so that more Americans can enjoy access. The Coalition also appreciates the Joint Board s recognition that rural carriers are doing a commendable job in delivering broadband to some of America s most difficult areas to reach.
Overall Cap
While the Joint Board s approach to reforming USF is admirable, the proposed rigid cap on the high-cost portion conflicts with the Act s principle that support be specific, predictable and sufficient in order to preserve and advance universal service. The U.S. Court of Appeals for the 10th Circuit has twice found that the FCC has yet to demonstrate that rural consumers served by non-rural ILECs are receiving sufficient universal service support. The overall cap also serves to lock-out updates to the underlying wireline infrastructure that are expected across the industry. While the ILECs have operated under a cap for many years, this new definition would eliminate the chance for system development that will be essential for other segment growth, including wireless and broadband. In the future, the nation s telecommunications system will depend upon the underlying network even more and for this reason, CKAC cannot support this misguided approach.
Reverse Auctions
Though the Joint Board recommended that the FCC explore the most appropriate auction mechanisms to determine high-cost universal service support, numerous factors make auctions a high-risk prospect for both consumers and the incumbent telephone carriers that serve them. These include risks to networks, continued broadband build-out in rural America, and carriers ability to invest and secure proper financing and cost recovery. Auctions, if utilized, should first be tested in unserved areas where market forces and existing support mechanisms have as yet not been sufficient to encourage deployment. CKAC members do not support this approach to USF reform.
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The Coalition to Keep America Connected is dedicated to ensuring that all consumers have access to affordable telecommunications services and the latest technologies-no matter where they live. The effort is organized by four rural telecom associations, whose memberships include more than 800 small and midsize communications companies. Together these companies serve millions of consumers and 40% of the landmass across America. Visit us at www.keepamericaconnected.org.
