All 3 alternative universal service contribution systems proposed...

which the FCC Wireline Bureau’s study (CD Feb 28 p7) showed to be “sustainable for the foreseeable future.” IPR said the study underestimated the total costs of the proposals “by failing to consider their respective administrative costs.” It said low-volume consumers who were “least able” to afford increases in their phone rates would pay “substantially” more under all 3 proposals: “This result cannot be reconciled with the Commission’s statutory mandate to ensure that consumers receive ‘quality service… at just, reasonable and affordable rates.'” The IPR said concerns over bundling and IP telephony were “not significant enough” to justify replacing the current assessment system, “especially since these problems can be addressed by directly assessing IP telephony and modifying the bundling safe harbor.” It said when and if the present system no longer were sustainable, the Commission would have authority to implement an all- revenue assessment system that “would greatly expand the pool of carriers obligated to contribute to the USF [universal service fund], and would ensure that carrier and consumer USF obligations remained equitably based upon their actual usage of telecommunications services.” In a separate comment, Beacon Telecom Advisors urged the Commission to consider the current revenue-based approach as the “most viable alternative in maintaining and supporting the universal service support funding mechanism in the future.” It criticized a connection-based approach, saying that “while connections may not be relevant to certain interstate services, revenues are relevant to all interstate services and will” better meet the requirements of Sec. 254 that all providers of interstate telecom services contribute on a nondiscriminatory basis.