I’m few days behind but Mike Romano and I had a very productive meeting last week over at the FCC with Commissioner O’Rielly, who has been key the past few years in the development and formulation of next steps to go on the USF front. I was really grateful to hear the Commissioner’s recent remarks where he noted that in spite of all of the work on USF reform done to date, there was still more work to do. Working through the remainder of “the punch list” remains a priority for the Commissioner and I’ve always appreciated the work that he and his excellent staff member, Amy Bender, do in identifying and then following through on items that will allow as many loose ends to be tied as possible. I also appreciated the Commissioner noting the possible use of any existing reserves to ensure companies were able to get a little bit closer to their actual cost recovery for funds spent on broadband deployment but we saw those last reserves literally swept away by Hurricane Maria as the FCC pivoted to using those funds to support rebuilding of that wiped-out infrastructure in Puerto Rico and the Virgin Islands. It is impossible to argue with the need to help those folks rebuild their communications infrastructure but it certainly means that the FCC should pivot to creative thinking about ensuring sufficient resources.
That is why as NTCA highlighted the need to remedy the shortfalls in high-cost universal service fund (“USF”) support that are undermining the intended effectiveness of the USF programs as reformed last year, we urged the Federal Communications Commission (the “Commission”) to initiate a comprehensive “budgetary review” for high-cost USF by year end as contemplated when the overall budget was first adopted in 2011, and pending such review, to continue as a near-term measure to collect the current overall budget for high-cost USF. To the extent that such collection yields contributed amounts in excess of then-current high cost USF demand for the constituent program components, NTCA further urged the Commission to use any such additional sums to mitigate the shortfalls in support that are being applied only to smaller rural carriers. Given the elimination of any possible reserves, that makes pursuing this current collection even more critical. Commissioner O’Rielly is on the record now supporting this approach and Commissioner Rosenworcel mentioned she thought it should come before all of the Commissioners as well. I remain hopeful that Chairman Pai, who spent much the past few months touring rural America and meeting with rural broadband providers who are trying meet the mandate for broadband deployment, amidst continued budget mechanism cuts, will be supportive of this relatively painless short term solution to ease some of the anxiety generated by the latest slash against the high-cost USF program. A simply act that will go a long way at a critical time.