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FCC Comments

Comments on Connect America Fund, High Cost Universal Service Support and others

WC Docket No. 10-90, GN Docket No. 09-51, WC Docket No. 07-135, WC Docket No. 05-337, CC Docket No. 01-92, CC Docket No. 96-45, WC Docket No. 03-109
  • and Media Access Project, Access Humboldt, Rural Mobile & Broadband Alliance, and Center for Media Justice
September 6, 2011 |

Commenters urge the Commission to oppose the ABC joint framework proposed by various industry groups, include broad interconnection obligations on Connect America Fund recipients, and include in the fund an adequate amount of support for a broadband pilot program supporting local self-provisioning of broadband infrastructure in the highest cost areas of the country. Specifically, the Commission should: (1) reject the specific provisions within the ABC plan that would raise the Subscriber Line Charge, grant a Right of First Refusal to incumbent telephone providers, and remove all public interest obligations on fund recipients; (2) as a component of support for broadband services, include explicit interconnection obligations in line with those imposed upon BTOP and BIP awardees; and (3) establish a pilot program to fund the buildout of networks by local communities, networks that can include county and state broadband initiatives, electric and telephone cooperatives, municipal power authorities, and investor-owned service providers, and residents in areas that remain unserved by the Connect America Fund (“CAF”).

As proposed, the ABC Plan would inflict far-reaching harms on consumers. The Plan particularly harms the most vulnerable among consumers – the elderly and low-income rural, who depend on their telephone service as a primary means for communication. The Plan effectively locks out non-incumbent commercial providers as well as community and municipal networks from any opportunity for fund support that may enable them to deploy high-speed broadband service in a more efficient manner and at higher quality than incumbent providers. Finally, in an unprecedented move, the Plan eliminates any regulations on high-cost and CAF recipients, essentially doling out bonuses to large incumbents at taxpayer cost.

In addition, interconnection requirements for CAF recipients are critical for promoting competition and broadband adoption in high-cost communities. Evidence domestically and abroad indicates that interconnection obligations have a significant positive impact on connectivity in communities, and the Commission should ensure inclusion of those obligations here. Indeed, the Administration’s successful BTOP program is largely centered on the concept of open access and reasonably priced interconnection to, and transport via, robust high-capacity middle mile facilities.

Finally, the CAF and the Commission should not leave potentially millions of households without access to broadband. Commenters support ubiquitous connectivity, even for the highest- cost communities, and believe community networks and models could serve presently unserved areas that traditional commercial carriers are unwilling to serve and could do so at significantly lower costs. Commenters support the proposal to establish an adequately-funded pilot program to sustain local self-provisioning and buildout of broadband in the highest cost areas.

To read the rest of the comments, click here.

CAF and the Commission should not leave potentially millions of households without access to broadband. Commenters support ubiquitous connectivity, even for the highest- cost communities, and believe community networks and models could serve presently unserved areas that traditional commercial carriers are unwilling to serve and could do so at significantly lower costs.

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