In terms of setting priorities, ACA urged the FCC to recognize that the current contribution regime is too complex and often produces arbitrary outcomes, resulting in onerous burdens on contributors and potential contributors. As a result, the current regime is neither sustainable nor competitively neutral. In the first round of comments, virtually all commenters agreed on the need for a simpler, less burdensome system.
ACA also stressed in its reply comments that the current system has a host of discrete problems that do not involve altering the base or methodology. To that end, ACA said the FCC should consider:
In a concern shared by other broadband communications providers, ACA said it was premature to expand the assessable base to include broadband Internet access service because it may harm adoption, innovation, and network expansion. ACA also opposed adopting an assessment that would increase with faster tiers of service.
"There are simply too many unknowns for the FCC to leap to make broadband service assessable and to make any assessment increase with higher-performing tiers of service, especially if such an assessment discourages adoption and the deployment of networks with higher-performing broadband services," Polka said.
Elsewhere, ACA urged support for allowing providers to include USF as a separately identifiable surcharge on consumers broadband bills, saying it would be useful for consumer understanding and education. But ACA said it would be confusing, expensive and complicated if broadband access providers were required to provide a detailed breakdown of how the surcharge was calculated. ACA said it made more sense to require the Universal Service Administrative Company (USAC) to verify the accuracy of providers' surcharges.
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