Industry Urges FCC to Establish Sustainable USF High-Cost Framework

"Effective and sustainable broadband policy is one of the greatest challenges facing the commission," said Vantage Point Solutions. It urged the FCC to address USF contribution reform, backing the inclusion of fixed and mobile broadband internet access revenues as part of the contribution base. A "substantially expanded contributions base will be necessary to achieve universal service goals," said USTelecom. The group raised concerns about the current process for providing disaster relief and suggested the FCC also consider adding support for relief as part of its sustainability fund. Scalability is a "critical element" of a full-service network and any future USF support, WTA said. The group also backed establishing a support mechanism for disaster relief.

"A sustainability framework should be positioned as a coordinated complement to existing high-cost USF mechanisms while the latter programs’ work is completed," said NTCA. The group emphasized the need for "ongoing support to sustain networks and services" to ensure "sufficient and predicable support" for the high-cost program. The Wireless ISP Association urged the FCC to focus on providing high-cost support "only to locations where there is a market failure" and areas where broadband infrastructure "would not be deployed or would not be financially sustainable" without governmental assistance.

USF "needs substantial reform to support evolving networks that operate in high-cost, low population areas," said the Rural Wireless Association. There's a "wide gap in funding" between current high-cost USF support and the funding necessary to achieve universal service goals, the group said. It asked the FCC to "transition" funding for the Rural Digital Opportunity Fund Phase II auction to "fund ongoing support in order to sustain existing networks and to-be-deployed networks" funded by the Infrastructure Investment and Jobs Act.

Sustaining deployed broadband networks is "vital for the well-being of existing and nascent tribal broadband networks," said the National Tribal Telecommunications Association. "Sustainability funding programs should immediately be set in motion so that the providers, federal and state governments can be assured that networks deployed in high-cost rural tribal areas can survive," NTTA said.

Nearly two dozen rural LECs urged the FCC to "develop a full-service network support model." The RLECs said the model should "reflect the actual experience of rural operators," noting that the companies were unable to commit to their proposed enhanced alternative connect America model program support offers because the ACAM models "did not correctly reflect the investment and operating costs realized in their service areas."

NCTA said it "does not follow that there is a need for additional support, or new support mechanisms, to cover operational costs." The group said that any support for operational costs "should be far more limited in scope and size than past subsidy programs." The FCC should "develop a much more robust record" regarding rural providers' costs and revenues before deciding on any modifications to the existing support mechanism.