The highest priority in the FCC’s national broadband plan must ce...

are “woefully insufficient,” it said. The group urged the commission to increase the “high-cost USF support” substantially and include all broadband Internet service providers in the pool of USF contributors. The pool should also include content providers like Google, which impose “tremendous costs” on the broadband providers that make up the public Internet. The group also urged the FCC to define broadband based on high-speed Internet access capabilities during peak-hour or busy-hour load that are generally available in a significant sample of service offerings in urban areas to establish a standard of comparability and affordability in urban and rural areas; include “broadband Internet access service” in the definition of “universal service;” open a proceeding to define and identify “Market Failure Areas” throughout the U.S. and target these areas for future high-cost broadband USF; define a “Market Failure Area” as an area that doesn’t have the population base or economic foundation for any provider to justify broadband facilities build-out and ongoing maintenance without external monetary support. The commission must require interconnected VoIP service to pay intercarrier compensation during comprehensive USF, IC and broadband reform. State commissions should be allowed to voluntarily move intrastate originating and terminating access rates and rate structures. The FCC should adopt an alternative high-cost USF cost recovery mechanism prior to the implementation of USF and IC reform, regulate broadband access service providers under Title II common carrier regulation and apply a Title II earnings review to all broadband providers who voluntarily receive federal high-cost broadband USF support. The regulator should require all vertically integrated Internet backbone and special access transport provider rates to be cost-based and non-discriminatory. The broadband plan should eliminate the identical support rule and base support on competitive eligible telecommunications companies’ actual costs within five years. Meanwhile, enhancing rural health care and offering broadband to low-income consumers should be part of the plan. NCTA also urged the FCC to strive to apply Regulatory Flexibility Act and establish alternative rules to reduce the economic impact on small broadband providers.