Many individual ILECs and their associations have offered formal comments, as well as ex parte presentations, advocating the full funding of high cost broadband support for both A-CAM model participants and carriers choosing (or in many cases having no choice) to remain under RoR regulation.
The greater-than-anticipated demand for A-CAM led to a shortfall in the FCC’s self-imposed high cost broadband budget, causing the Commission to reduce settlements under both the model and legacy settlement programs. The FCC is now trying to decide whether, and by how much, to increase support to encourage its much-desired provision of broadband services.
In its deliberations, the Commission should simply look back at the success of its Universal Service initiatives for telephony. Ubiquitous telephone service came to rural America only when regulators understood that small, rural high cost/low revenue carriers needed a fair and equitable level of support if they were to provide high quality telephone service, at reasonable rates, to all their customers.
The provision of broadband service by high cost, rural carriers faces the same challenges, and needs the same kind of support. As WTA wrote recently to the FCC, “A fully funded ACAM … (will) extend… broadband services to tens of thousands of new locations in many of the more expensive-to-serve, outlying portions of RLEC service areas.”
In also calling for the full funding of RoR support, WTA said that, “eliminating the unpredictable and investment-deterring… budget control mechanism and adopting an inflation adjustment for the High Cost Program budget like those in other USF programs – would address inequities that precluded significant numbers of RLECs from electing the ACAM Path…”
In other words, the FCC should apply more elements of its traditional USF model to its current broadband support mechanisms.