Commenters Offer Tweaks on CAF Phase II Eligibility Requirements
Commenters differed on the proper speed proxy the FCC should use to ensure that recipients of Connect America Fund Phase II money provide broadband service of at least 4 Mbps downstream and 1 Mbps upstream. Commenters in WC docket 10-90 were responding to a Wireline Bureau request on how best to identify unserved areas eligible for CAF Phase II funding, and on how to measure broadband speed, latency and other metrics required of funding recipients.
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USTelecom said its proposed standards would “ensure the most efficient use of scarce CAF Phase II funding” (http://bit.ly/179wk74). A speed proxy of 6/1.5 Mbps, combined with a “vigorous” challenge process, will give consumers more assurance that they'll be able to find service of at least 4/1 Mbps, USTelecom said. USTelecom also suggested the commission adopt a 100 ms latency standard to enable real-time applications such as voice, with a minimum usage allowance of 60 Gigabytes per month. AT&T cautioned against requiring a “large” usage allowance for entertainment purposes, which will likely disqualify broadband providers using “certain technologies” from participating in Phase II, it said (http://bit.ly/10iOMGs).
The Independent Telephone & Telecommunications Alliance, however, thinks there’s “no need” to adjust Phase II buildout requirements to provide 6/1.5 broadband to all supported locations. “Creating a blanket 6 Mbps/1.5 Mbps requirement across an entire supported area would short-circuit the transition the Commission has in mind and require CAF Phase II support recipients to completely redesign pieces of their network architecture, particularly due to technical challenges associated with the new upload speeds,” ITTA said (http://bit.ly/YOwugx).
The American Cable Association also questioned the 6/1.5 proxy, which “would result in either placing an onerous burden on cable operators or risk expending scarce government support in areas where 4/1 Mbps service is actually provided,” it said (http://bit.ly/ZwPVGW). NCTA urged the bureau to identify unserved areas that “recognize the difference between entities that receive universal service subsidies and those that have deployed facilities without such support” (http://bit.ly/179BDDI). The bureau should impose more stringent requirements on entities accepting USF money, and not “impose de facto broadband pricing or service requirements on companies that have built networks without universal service support,” NCTA said.
NTCA, the National Exchange Carrier Association, the Eastern Rural Telecom Association and the Western Telecommunications Alliance said they're “concerned” that while the public notice proposals “inch toward a more robust process” to confirm where unsubsidized competitors operate, “such determinations will fail to capture accurately and entirely the extent to which a competitor offers a meaningful alternative in such areas, thus undermining the statutory mandate of universal service” (http://bit.ly/Z4pCI9). The rural associations suggested the bureau implement an “evidentiary-based process” that takes “more true account” of the issues discussed in the public notice, such as the availability of both broadband and voice service, the prices for such services, and the quality of service in each instance.
The FCC should recognize that wireless carriers are unsubsidized competitors for the sake of the CAF rules. “Mobile wireless providers are competing with ILECs for voice and broadband customers, typically without receiving any universal service support,” CTIA observed (http://bit.ly/13MeUP4). CTIA also said “defining ‘unsubsidized competitors’ in an inclusive way is necessary for technology neutrality.” An inclusive definition would also “increase the efficiency of the fund by eliminating support in areas where it is unnecessary to ensure that consumers have access to voice and broadband service,” the group said.
The Wireless ISP Association objected to how WISPs would be treated relative to other broadband providers. “Under the proposal, fixed wireless providers must prove -- apparently in every census block they serve -- that they meet the to-be-established speed, latency, capacity and price criteria before being afforded unsubsidized competitor status,” WISPA said (http://bit.ly/YX0XGc). “No such burden would be placed on cable broadband providers. To the contrary, cable providers offering service at the to-be-defined speed threshold would be afforded the presumption of unsubsidized competitor status.” Singling out WISPs for special treatment is “unnecessary, unwarranted, and contrary to law,” WISPA said.