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FCC Comments re NCTA Petition for Rulemaking to reduce Universal Service High-Cost Support

Submission Date: 
I. Introduction.

The American Cable Association ("ACA") files these Comments in response to the Commission's Public Notice inviting comments on the National Cable and Telecommunications Association ("NCTA") Petition for Rulemaking to reduce Universal Service High-Cost Support to carriers in areas where there is extensive unsubsidized facilities-based voice competition.

In the ACA's recent filing regarding the role of the Universal Service Fund ("USF") in the National Broadband Plan, the ACA set forth a proposal to evolve and reform Universal Service to fund broadband service in unserved and underserved areas, including by distributing funds more efficiently. A key premise behind the ACA proposal is the same as the NCTA proposal: to improve the efficiency of problems with the current Universal Service program by targeting funding to consumers that truly require support. However, unlike the NCTA proposal, the ACA proposal seeks to balance important competing legal and policy considerations.

The NCTA proposal applies equally to all carriers receiving universal service support. In contrast, the ACA's proposal provides that smaller, more rural incumbent wireline providers - those entities most reliant on current funding to support consumers - can continue to access funding. The ACA is concerned that the fundamental change in policy proposed by the NCTA would have a disproportionately grave impact on smaller providers if it were implemented as proposed. Thus, the ACA believes it is necessary to strike a balance between the need to improve the efficiency of the fund with the objective of ensuring a fair opportunity for smaller, potentially more vulnerable providers.

2010 01 07 ACA Comments NCTA USF FINAL.pdf119.27 KB

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