09.08.14 Rural Associations file Reply Comments in CAF FNPRM proceeding, WC 10-90

Connect America Fund, WC Docket No. 10-90, Universal Service Reform – Mobility Fund, WT Docket No. 10-208, ETC Annual Reports and Certifications, WC Docket No. 14-58, Establishing Just and Reasonable Rates for Local Exchange Carriers, WC Docket No. 07-135, Developing an Unified Intercarrier Compensation Regime, CC Docket No. 01-92, Report and Order, Declaratory Ruling, Order, Memorandum Opinion and Order, Seventh Order on Reconsideration, and Further Notice of Proposed Rulemaking,  FCC 14-54 (rel. June 10, 2014) (Omnibus Order or Further Notice)

On September 8, 2014, the Rural Associations filed reply comments in the above referenced proceeding wherein they stated, among other things, that they strongly support efforts to reform existing universal service mechanisms in ways that will improve the availability and quality of broadband services provided to consumers and businesses located in areas served by RLECs. Accordingly, the Commission should act promptly to establish a support mechanism for data-only broadband (DOBB) services provided by RLECs.  As show in their Reply Comments, the Rural Associations’ proposed DOBB support mechanism not only satisfies the principles established by the Commission in the Further Notice, but presents the simplest and most straightforward way on the record for the Commission to achieve its goals in this proceeding.

Additionally the Rural Associations believe proposals to reduce or eliminate support in rural areas served by unsubsidized or “qualifying” competitors using alternative technologies raise substantial public interest questions and should be approached with great caution.  Finally, the Rural Associations support the Commission’s efforts to assure accountability in the use of federal high-cost funding, but suggest the Commission apply caution in adopting new certification requirements, and should consider eliminating rules that impose draconian penalties on RLECs (and their customers) for failure to comply with complicated administrative rules.

09.08.14 Rural Associations file Reply Comments in CAF FNPRM proceeding, WC 10-90