NASUCA Accuses Others of Extraneous Comments in USF Rulemaking
Some industry groups are using an FCC notice of proposed rulemaking on USF contribution methodology to argue for moving to a number-based method of calculating payments -- a question the FCC never raised, NASUCA claimed. The VON Coalition, CTIA and other groups said tweaks to current methodology will fall far short of needed reform.
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“Nowhere in the NPRM is there an invitation to comment on whether the Commission should adopt a numbers-based USF contribution mechanism,” NASUCA said: “As previously stated by NASUCA (and others), there is no need to adopt such a radical change to the USF contribution mechanism. These commenters continue to ignore the facts and the impacts of the radical change they propose.”
Filers should have stuck to discussing whether or not to kill or raise the wireless safe harbor, and to requirements recently imposed by the FCC on VoIP providers, NASUCA said. There’s no reason to shift to a number-based solution, it said: “The contribution base has grown, not shrunk, increasing 3.4% over the previous quarter. The lack of such evidence [of problems] makes the support for the numbers- based mechanism exceedingly tenuous, based on what can be described as equivalent to an urban legend.”
Tweaks examined in the NPRM won’t go far enough, the VON Coalition said: “The Commission has adopted [a] haphazard revenue-based regime that instead makes broadband-based voice communications less affordable thereby reducing the value proposition for consumers… Continuing this illogical and discriminatory regime any longer than absolutely necessary does a disservice to the American public and continues to damage the long term sustainability of the federal universal service fund.”
USF methodology is “incompatible with the emerging multi-dimensional communications marketplace” and needs revamping, CTIA said. “There is widespread agreement that merely tweaking safe harbors and traffic studies that rely upon arbitrary jurisdictional and regulatory distinctions cannot compensate for the inherent deficiencies of a revenue- based mechanism,” Verizon said.
On a question the FCC did raise, wireless carriers urged the Commission to keep letting companies use traditional traffic studies to show the percentage of calls on their system that are interstate vs. intrastate, as an alternative to paying the safe harbor percentage. T-Mobile said barring use of traffic studies “would require significant investment on the part of carriers to purchase or convert to data processing systems that could track interstate revenues on a call-by-call basis.”