WC Docket No. 11-42, Federal-State Joint Board on Universal Service Lifeline and Link Up Reform and Modernization; WC Docket No. 09-197, Telecommunications Carriers Eligible for Universal Service Support; WC Docket No. 10-90, Connect America Fund
NTCA–The Rural Broadband Association and WTA-Advocates for Rural Broadband hereby submit this letter to highlight once again an unfortunate incongruity between implementation of the Rate-of-Return Reform Order and one particular provision of the Lifeline Modernization Order which requires high-cost support recipients to offer a standalone broadband service to Universal Service Fund (“USF”) Lifeline-eligible consumers.