AT&T, CTIA Ask Utah to Delay Connections-Based USF

contribution method. But in separate comments filed this week, AT&T and CTIA said the PSC should retain its revenue-based method, or at least provide more time for working out final rules and implementing the change. The proposed rule change “is unnecessary and would create a myriad of legal and logistical problems,” CTIA said in docket 17-R360-01. "The existing contribution mechanism … remains legally sound and demonstrably successful.” The proposed rule may violate state and federal law because it could be read to include broadband lines, CTIA said. Requiring a state USF surcharge on bills could harm less wealthy consumers by making it difficult for carriers to sell "all-in, single-rate service plans that are popular among these consumers," CTIA said. The flat fee would impose "far higher relative costs on low-volume users," it said. In other comments, AT&T said USF contribution reform should be addressed at the national level. The Utah USF has a surplus, so “the haste to make Utah the first state to experiment with switching to a per line contribution base is unwarranted,” the carrier said. Many open questions about the proposed rules make shifting to connections-based contributions by Aug. 1 “unreasonable and impracticable,” it said. The commission should clarify the definition of access lines and providers to include prepaid wireless and exempt non-interconnected VoIP services like Skype and FaceTime, AT&T said. Also, the PSC should ensure the rule doesn’t assess Utah USF fees to wireless consumers who don’t live in Utah, it said. “For example, an out of state college student who is included on her parents’ family wireless plan with a Utah billing address will result in the student’s line being subject to the surcharge, even though that student uses her wireless phone mostly in another state where she is likely already subject to another state USF surcharge.” The Utah Rural Telecom Association supported the change to connections-based contribution, but suggested some tweaks to language, in its comments. Comcast didn’t support or oppose the revamp, but commented that clarifying procedures for counting access lines would ensure contribution is competitively neutral and nondiscriminatory. Other states are also mulling contribution reform (see 1706300049).