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FCC Comments regarding the Role of the Universal Service Fund and Intercarrier Compensation

Submission Date: 

Executive Summary

The ACA supports the consideration of a Universal Service mechanism to fund broadband as part of the National Broadband Plan; one that is competitively and technologically neutral and is precisely targeted to users that lack access in areas that are unserved or underserved.  Over the past several months ACA and its diverse membership have worked diligently to develop a proposal that evolves and reforms Universal Service to support broadband in an efficient, non-discriminatory manner where 1) one industry segment is not favored over another and 2) one technology is not favored over another. 

The ACA proposal looks to correct problems with the current Universal Service program and target the funding to where it is actually needed.  An overriding guide in developing the ACA proposal is the fact that the consumer is the ultimate contributor to Universal Service.  Thus the ACA plan is tailored to efficient funding where truly needed.  The main components of the ACA proposal are:

1. Cap the Entire Universal Service Fund and the High Cost Portion of the Fund at 12/31/09 Level;

2. Create a New Broadband Fund for Unserved and Underserved Areas (Last Mile Wireline & Wireless, and Middle Mile);

a. The amount of funding for the Broadband Fund would be the difference between the capped high-cost fund amount as of 12/31/09 and the level of the high cost fund as it is reduced through the mechanisms described in Section 3.

b. Funding would be awarded separately for last-mile wireline and wireless providers and for middle-mile providers with the FCC determining the appropriate allocation. Funding would be awarded on a first-come, first-served basis, with unserved areas being funded first; if multiple last-mile providers seek capital funding in unserved areas or multiple middle-mile providers seek capital funding, reverse auctions (or another neutral selection method) would be used.

See full content in pdf file.

091207 ACA Comments USF Final.pdf129.18 KB

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