Universal Service: Too Important to Make Bad Bets!

Universal Service: Too Important to Make Bad Bets!

It is no surprise that the FCC has several difficult tasks when it comes to Universal Service. It needs to: 1) reach unserved consumers, 2) make sure those who are served stay served, and 3) ensure that the services being provided to rural Americans are “reasonably comparable” to those that urban consumers receive.

The focus always seems to fall on the first of those goals, and certainly reaching those without broadband access is critical and is the source of many headlines, studies, and mapping debates. However, the other two objectives are really important as well when it comes to true Universal Service and to making sure we’re making the best, most effective, smartest, and efficient use of USF resources over the long-haul as a nation.

That third goal—making sure services are “reasonably comparable”—is especially important not to ignore in the “afterglow” of the FCC’s recent Connect America Fund Phase II Auction. Many are rightly celebrating the number of Americans who will be reached, but the real hard work has yet to begin. Providers now must actually build the networks, and make sure that the voice and broadband services on those networks are “reasonably comparable.”

In fact, that’s another important aspect of this discussion on using USF resources that tends to get lost; the networks must offer both quality broadband and reliable voice service. The winners of the CAF II Auctions are effectively the new “carriers of last resort” in those parts of rural America. If we want rural Americans to have access to public safety and for calls to complete, the auction winners must build networks that enable both voice and broadband. To use support, they must become carriers who will deliver the kind of “carrier-class” services that consumers can depend on—that is part of the commitment that is made with this program. Again, it’s not enough just to build broadband networks, walk away, and call it a day; networks must be built to last, so consumers can make effective use of them. That is true universal service.

And this is where the FCC comes back in. Final CAF II application forms were due a few days ago, and now it’s time to make sure that auction winners can actually deliver on their promises. Originally, NTCA wanted the FCC to make sure of this before operators even bid—why award auction funds to someone who can’t deliver? We also advocated to disqualify bidders who claimed to do things never seen in the marketplace. There should be no “moonshots” gambling that a technology can do something it hasn’t before in scope and scale. There are frankly no “innovation points” if precious resources are used unwisely. But the FCC decided to hold off a more detailed review until after the auction.

So, now the winning bidders have turned in their papers. It’s important before funds start to flow to confirm that bidders can actually do what they promised. Unfortunately, the FCC likely doesn’t have the resources to review hundreds of technical plans to serve hundreds of thousands of locations. For that reason, interested parties should be able to review the plans, at least under protective order. The states who will be making ETC designations, the communities who are starving for broadband but also need access to voice service, technical experts who understand networks—stakeholders like these should be able to help identify questions or concerns about technical plans and promises.

The CAF II Auction will be important in reaching areas starved for service. It’s a big deal. In fact, it’s too big a deal to let fail, and too big a deal to make bets on untested solutions. Some “CAF 3” program will come along in a few years that will likely be even bigger in terms of the funds involved and areas to be served. Rather than letting bad bets play out and leaving communities without reliable services as a result, the FCC should enable review by interested stakeholders who can help make sure that the pieces are in place to deploy and sustain a network consistent with promises made. This is the best way to ensure accountability, achieve true universal service and set the right broadband path for the future.

2 thoughts on “Universal Service: Too Important to Make Bad Bets!

  1. We remember that day, our eyes watching the analog TV July 1969 when the “moonshot” landed successfully for the world to see, communication without wires. 50 years of innovation moving our world from analog to digital everything. A “bad bet”? We think not.

  2. While you certainly raise legitimate concerns, it would appear that you have not been following the process closely. The “short form” actually required general plans and specific technology requirements that were vetted by manufacturers, independent specification bodies, by the engineering community, and finally by FCC staff. The long form is even more involved in the amount of detail and vetting requiring “professional engineer” approval. The real question that should be raised in relation to CAF funding of any sort is why are we allowing substandard networks to be built by ANY carrier, especially carriers that did not even have to do anything to receive this funding? Existing Tier 1 and 2 carriers were able to leverage huge sums of money for the sole reason that they “always” had provided service in an area. The areas, in general, have had “band aids” applied. Reconditioning copper that will at best make it another 5-10 years and more likely be obsolete in 3-5 have had many millions and even billions of dollars pumped in without allowing for the aspect of the 2nd goal mentioned above, keeping served areas served. As the speeds that consumers and businesses demand and need increase, the planned obsolescence of copper serving facilities is shameful, essentially wasting billions of dollars over the last several years. Yes it got some broadband service into the rural areas in the extremely short term but even in the mid term of 5-7 years, the demand has outstripped the available services. This demand will continue to grow and until the FCC actually takes a hard look at its ideas of broadband, growth of demand, and what that will actually require to provide, the program will continue to have issues, especially in the 2nd goal.

    As for the 3rd part of the mandate, broadband networks are very robust with modern electronics and software. While the old telco system sported 5 9s (about .8 seconds of downtime per day “on average”), the modern broadband system can consistently deliver 4 9 s or better (between 0 and 8 seconds of downtime per day “on average”). This is better than my cellular service which is also supported by CAF and it often does not work in my rural home at all.

    I am not a huge proponent of wireless networks as a long term solution but from a technical perspective, it is now better than copper when implemented properly, especially when the broken nature of the supported block groups is taken into consideration. However, when all factors are taken into consideration, speed, range, longevity, it seems that fiber wins hands down. Many of the NTCA members began laying fiber to the premise years ago with many of these companies having complete fiber networks in rural areas. Places like Iowa, South Dakota, and Minnesota, where many of the NTCA members have networks lead the way in fiber optics and high speed, resilient networks.

    Does fiber cost more? Yes, the initial cost is higher but in the long run, fiber often is lower cost over the life of the network with minimal maintenance and operation expense. Is wireless a more difficult network to maintain than copper? Well, it depends. Yes it probably needs replacing more often but that replacement is at a much more modest cost than copper or fiber.

    I do agree that this program is too important to make a bad bet on. However, the bad bets have been coming for a long time and maybe, just maybe, this will be the beginning of providing real service instead of making any type of a “bet”.

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