Proposed Reform of USF and ICC Programs Will Align with the Modern Technology Americans Use Today
Washington, D.C. – The Telecommunications Industry Association (TIA) today filed comments with the Federal Communications Commission (FCC) supporting its efforts to restructure the Universal Service Fund (USF) and Intercarrier Compensation (ICC) programs to support broadband deployment.
"TIA agrees with the Commission that the USF and ICC programs are 'broken.' As such, TIA supports the adoption of the proposed new universal service core principle that 'universal service support should be directed where possible to networks that provide advanced services, as well as voice services,'" said TIA Vice President for Government Affairs Danielle Coffey. "This new principle is consistent with the public interest, the Commission's goals, and Congress's clear intent as expressed in the statute."
In its comments, TIA supported the Commission's proposed creation of a broadband-focused Connect America Fund (CAF) to ultimately replace the existing USF high-cost fund and the implicit subsidies that continue to plague the ICC regime.
TIA also urged the Commission to implement CAF in a technology-agnostic, competitively neutral manner. To maximize efficient broadband deployment, the Commission must ensure that any coverage or service requirements (including voice service requirements) are technology-neutral, flexible, and able to be customized to address unique circumstances.
"Overly strict requirements would preclude providers from participation in the program even where compliance is not reasonably achievable due to external factors," said Coffey.
"Such requirements would arbitrarily exclude providers who might otherwise offer service to the most insular, unserved areas of the county, and would thereby thwart the core purpose of the USF." TIA is also supporting the Commission's proposal to allow partnerships between multiple providers in order to meet any applicable requirements.
Under a truly technology-agnostic approach, the Commission must holistically evaluate the functionality of broadband services offered by a potential recipient, rather than screening and eliminating potential recipients based solely on the speed of the connection offered. A speed-based threshold for broadband service support could leave some of the hardest-to-reach households uncovered.
TIA also strongly urged that in taking these steps to reform the USF, the Commission must avoid any actions that could divert funds from the E-Rate and Rural Health Care mechanisms, or from other programs that support broadband for anchor entities. Funds for these important programs should not be redirected into the CAF.
In addition to comprehensive USF reform, TIA also supports comprehensive intercarrier compensation reform under a federal regime that reflects advances in technology and encourages broadband deployment. TIA wrote that the current ICC framework is out of step with the IP-based, nationwide, data-centric communications networks of today. TIA therefore supports a rapid transition away from the outdated and market-distorting inter- and intra-state access rate structure and per-minute charges.
Finally, TIA urged the Commission to bring certainty to the market for interconnected voice over IP (VoIP) market by classifying that service as an information service. Doing so would promote investment in broadband deployment, would have no effect on the Commission's authority to transition the USF to broadband, and would be consistent with the Commission's transition to universal service support for broadband.
TIA's comments are available on its FCC filings page at tiaonline.org.
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