As we hit the season where we give ourselves more time and space to think about what we are grateful for, I continue to be grateful to be working for a group of companies who care so passionately about providing the best service possible to the broadband customers they serve in rural America. To that end, Mike and I made one more visit to the FCC prior to the holiday break (or in other words, the best time to be driving around DC since most of the folks have fled for the long weekend…) to catch up with the Chairman’s team on our continued concerns regarding near term and long term USF high cost support.
In the meeting, Mike and I highlighted the need to remedy shortfalls in high-cost universal service fund (“USF”) support that are undermining the effectiveness of the USF programs and stalling broadband investment. We urged the FCC to pursue readily available paths toward helping to mitigate the insufficiency of USF support, including but not limited to the immediate use of existing program reserves to help mitigate the harmful shortfalls pending further examination of the program budget and additional measures to promote longer-term predictability and sufficiency.
We also noted that our May 2016 Petition for Reconsideration and/or Clarification expressly teed up the need for relief to address the insufficiency of the high-cost USF mechanisms and the ensuing effects on consumer rates and carrier cost recovery, and that the record with respect to that Petition has been fully briefed and closed for fifteen months. It is really important to remember that it all comes down to how the rural consumers are served and that consumer rate impacts due to budget control-driven reductions in USF support are already underway, indicating that the denial of USF support under an insufficient budget is already creating unrecoverable costs associated with the provision of universal service, and additional budget resources are needed now to address such concerns. We truly believe that our Petition provides a clear and direct procedural vehicle to adopt and implement immediately measures that would help mitigate such budget concerns, including but not limited to the use of program reserve funds. Frankly, the sooner the better.
Mike and I also shared our continuing support for engagement on any and all initiatives that could help improve and simplify the operation of the high-cost USF mechanisms, but also made clear that the immediate budget concerns need to be addressed to allow more thoughtful and measured discussions with respect to any potential improvements. It’s hard to be thoughtful and forward-looking when your hair is on fire!
Our visit and discussion on what is really needed to build rural broadband infrastructure fit perfectly into the discussion I then had this morning with someone from CNN Money who wanted to further explore the challenges of building rural broadband but the opportunities that follow when the infrastructure is in place. Here at NTCA we will continue to do all we can to keep these critical conversations top of mind for folks here in Washington DC and across the country and remain grateful that our members make us proud to tell their stories.