The ACA supports the Commission's proposal to cap the size of the High-Cost fund at 2010 levels. An overriding guide in reforming the Universal Service fund and establishing the Connect America Fund ("CAF") should be the simple fact that the consumer is the ultimate contributor to Universal Service. Capping the fund at the current level should be a cornerstone of the Commission's plans. The ACA believes that the CAF can be sufficiently funded through the elimination of existing inefficiencies and ineffectiveness in the current Universal Service fund.
The ACA supports the Commission's proposal to create the CAF to assure that broadband is brought to unserved and underserved areas. The ACA believes, however, that there is value in continuing the current High-Cost mechanism in a limited fashion to support voice and evolving telecommunications services for smaller telephone companies who require the support to ensure that they can provide quality services at rates reasonably comparable to that provided in urban areas.
Thus, the ACA supports a balanced approach to Universal Service fund reform; one that takes into account the significant challenges that some small telephone companies and their users may face if the High-Cost funding is totally eliminated. The ACA proposes that current wireline Eligible Telecommunications Carriers with fewer than 100,000 access lines should have the option to continue to draw from the fund as they draw today (by area) unless the company chooses to access the CAF, in which case the CAF would replace the High-Cost fund support for that area.
Admittedly, the continuation of the current High-Cost fund for some smaller telephone companies may delay the bringing of broadband to all unserved areas. However, the goal of universal broadband must be weighed against the equally sound principle of assuring the continued availability of wireline voice services in high-cost areas at rates that are reasonably comparable to that provided in urban areas.
|2010 07 12 ACA USF Comments Docket No 10-90 FINAL.pdf||74.62 KB|
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