The telecommunications industry, the FCC, state regulators, Congress and a plethora of other interested parties have been discussing, offering opinions, arguing, filing and commenting on, and endlessly debating the insufficiency and unpredictability of broadband universal support for RoR carriers. For far, far too long.
This uncertainty has deterred investment, negatively affected rural carriers and their customers, and damaged the Commission’s longstanding principle of universal service at affordable rates. It has also harmed the important goal of closing the digital divide between urban and rural areas.
Given the foot dragging, excuses and incessant over-analysis of this situation, it is well beyond time for the FCC to act. We fully agree with what NTCA has suggested as a workable, common sense approach, summarized in our own words below.
First, the FCC must adopt a real budget, which was last set in 2011, and has since been the victim of an arbitrary and capricious control mechanism. It is estimated that an increase of $2.4 billion, on top of the $200 million previously set aside for the A-CAM program, would be needed. The budget should include an inflation factor, which is applied to other USF programs. (Aside: $2.4 billion seems like a small number, compared to other federal programs, to achieve such a major social and economic goal.)
Second, while a totally adequate budget, including an inflation adjustment, should eliminate the need for a support floor, such a floor should be provided as a fail-safe mechanism to each RoR carrier. This would serve as a safety net to prevent any large, unforeseen changes in support levels.
Third, until these provisions are fully implemented, allowing small, rural carriers to meet their service and cost objectives, no new model support offers should be made. Such new offers would simply muddy the waters in finally achieving the Commission’s original goals.
We urge the FCC to act NOW.
