CenturyLink, CTIA Clash on Connections-Based New Mexico USF

base rather than a declining revenue base,” and would be “relatively easy to implement, administer and enforce,” it said. It wouldn’t burden federal USF because it’s not dependent on providers’ classification of revenue as intrastate or interstate, CenturyLink said. But CTIA said New Mexico should maintain revenue-based USF contribution. Connections-based contribution is “regressive, imposing a larger burden on the consumers least able to pay it,” and could “create an illegal overlap with or a burden on the federal fund,” CTIA said. The PRC wouldn’t be able to assess prepaid customers who lack a direct and ongoing billing relationship with their providers, it said. PRC staff urged caution. “Any changes to the collection methodology for the revenue side of the Fund must not be speculative nor based on conjecture,” wrote PRC staff attorney Joan Ellis. “The Commission must have ‘substantial evidence’ to support a decision to adopt that new methodology.”