Industry Backs FCC Broadband Fabric High-Cost USF Proposal

NCTA backed many of the FCC's proposals. It said that using the fabric's data "creates efficiencies for high-cost support recipients as well as both the commission and [Universal Service Administrative Co.] in administrating the program." It asked that location IDs for individual locations in the fabric remain fixed "to the greatest extent possible" once the fabric is "used as the basis for monitoring high-cost support." NCTA also backed continued use of 2010 census blocks "as the basis for updating the location counts" within Rural Digital Opportunity Fund support areas. The group asked that high-cost recipients be allowed to use the fabric to verify they have served "all existing locations in authorized areas" before their sixth year service milestone and close their letters of credit.

The FCC should wait to track compliance with high-cost USF buildout obligations with the fabric "only for newly established programs and only after the fabric is a more settled and stable data set," said NTCA. It would be "highly disruptive" for the FCC to adopt this requirement for ongoing programs, the group said, noting that final buildout milestones will soon be reached in several high-cost programs at issue.

A coalition of more than a dozen rural electric cooperatives agreed. "Requiring RDOF participants to start new broadband deployment projects based on updated location counts would be unfair for those RDOF funding recipients that previously completed their obligations," the coalition said. The group suggested the FCC adopt a "de minimis threshold of new locations to justify the additional cost and burden on additional new broadband infrastructure buildout."

Union River Telephone Company urged the FCC to adopt a "threshold necessary to guarantee high-cost support" if it allows downward adjustments. The company warned that adopting a methodology adjusting A-CAM support downward without a threshold for recipients that was similarly adopted for RDOF carriers will harm rural carriers. It asked the FCC to clarify that "adjustment of support downward should not occur unless the new location total is less than 65%" of a support recipient's total locations.

A coalition of RDOF winners agreed, noting that broadband deployment costs are "predominantly based on the number of feet of fiber that is deployed along the streets of a census block" instead of the number of locations passed. In addition, the group asked the FCC to address the "deficiency" in the number of serviceable addresses in the fabric before revising its methodology.

"To facilitate coordination among government agencies and for administrative efficiency for internet service providers, RDOF deployment obligations should be adjusted using the fabric, not some other data source," said Irby Utilities, 4-County Fiber, Aeneas Communications, Clay County Connect and TEPA Connect in joint comments. The companies asked that fabric location count information for RDOF recipients be published sooner than June 2027 to "facilitate the ability of the companies expecting to complete their deployments early to take whatever steps are necessary to meet their revised deployment obligations."

The Alaska Telecom Association raised concerns about "modifying Alaska Plan obligation[s] at this date to reflect the fabric as it currently exists." ATA said that adding "substantial new deployment obligations is inconsistent with the intent of the Alaska Plan" and the "unresolved fabric challenges in remote Alaska also counsel against the use of the fabric to modify deployment obligations at this time." The fabric in remote Alaska "is not ready," ATA said.