August 11, 2010 - Rural Associations Reply to Comments on FCC's Broadband Universal Service Reform Proceeding
Comments show broad agreement on need for universal service reform; Commission should develop a comprehensive plan to identify how future broadband mechanisms will work
WASHINGTON (August 11, 2010) - The FCC should not begin dismantling existing universal service mechanisms without clearly identifying how future broadband mechanisms will work, according to reply comments filed today by several rural associations.
The National Exchange Carrier Association (NECA), the National Telecommunications Cooperative Association (NTCA), the Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO), the Western Telecommunications Alliance (WTA) and the Rural Alliance, along with 41 concurring state associations and other groups, filed the joint reply comments in the FCC's Notice of Proposed Rulemaking (NPRM) and Notice of Inquiry (NOI), which seek comment on proposals regarding Broadband Universal Service Fund (USF) reform.
The groups said July 12 comments make it abundantly clear the Commission's various universal service reform proposals are, at best, premature. The Commission should decline to make changes in existing programs at the present time. It can then turn its full attention to developing a comprehensive plan that includes well-designed broadband mechanisms that fully incorporate the service and funding objectives of the 1996Telecommunications Act.
The Associations remain committed to finding a solution that enables rural providers to bring broadband services to the communities that increasingly rely on them for healthcare, education, commerce and other applications. Their reply reinforced vital points that they and others made in comments:
- The Associations acknowledge the current system is in need of reform, but reform should be accomplished in a comprehensive manner.
- Uncertainty caused by the incomplete proposals in the FCC's NPRM is undermining broadband deployment in rural areas. Commenters express bewilderment as to why the FCC would propose replacing rate-of-return (RoR) regulation, which has a proven track record of success in fostering broadband deployment, with incentive regulation, which has been shown not to work.
- Comments also demonstrate the Commission should not continue to devote resources to developing economic models or "procurement" auction mechanisms, as these will place rural consumers at risk.
- The potential for an urban/rural digital divide remains a major concern, and the Associations emphasize the need for well-designed support programs that include investment incentives and continued support for the broadband network infrastructure, so all Americans, no matter where they live, can enjoy the benefits envisioned by the National Broadband Plan.
- The comments provide several suggested alternatives to the FCC's proposals that deserve consideration. The Associations look forward to working with Commission staff to develop workable broadband support mechanisms that ensure specific, sufficient and predictable support for broadband consistent with the 1996 Telecom Act.
The National Telecommunications Cooperative Association is the premier association representing more than 560 locally owned and controlled telecommunications cooperatives and commercial companies throughout rural and small-town America. NTCA provides its members with legislative, regulatory and industry representation; meetings; publications and educational programs; and an array of employee benefit programs. Visit us at www.ntca.org.