The FCC should give Alaska a separate “transition path” for...

and face challenges of distance, climate and supporting infrastructure unlike anywhere else in the United States,” General Communication said. Despite the company’s “substantial rural wireless deployments in 2009 and 2010, much of rural Alaska is still waiting to receive the 2G mobile voice services that the rest of the country has enjoyed for over a decade,” General Communication said. The National Broadband Plan recommended that the commission focus on broadband speed of 4 Mbps down and 1 Mbps up, but “those objectives will never be achieved in Alaska without hundreds of millions of dollars in capital investment,” General Communication said. Only “a fraction of Alaska has access to broadband with maximum advertised speeds of 3-6 Mbps for downloads and .786-1.5 Mbps for uploads,” the company said. “At a time when all indications show that achieving the Commission’s broadband objectives in Alaska will require several hundred million dollars in support just for capital investments, let alone operating costs, the interim proposals for both ILEC and CETC support would slash support for Alaskan telecommunications and broadband deployment,” General Communication said. If the FCC adopts all of the proposals for USF reform in its rulemaking notice, Alaska would lose about 75 percent of its universal service support by 2016, General Communication said. “Meanwhile, because of the way that the proposed interim Connect America Fund and Mobility Fund would be structured, virtually no funds from those new mechanisms can be expected to support Alaska telecommunications and broadband deployment services,” General Communication said. “Rural Alaska will never win a nationwide reverse auction pegged at supporting the lowest dollar per user deployments because Rural Alaska is both high cost to serve especially to connect over the middle mile and has extremely small population centers.” The better course is to preserve “existing support” for all eligible telecommunications carriers and high-cost programs on Tribal Lands “during the interim, and then move directly to a long term (not first phase) reformed Connect America Fund ('CAF'), as long as it can be tailored to Alaska’s unique challenges,” General Communication said.