Change Funding Base for USF, CPUC, PK and Other Replies Ask FCC

“Reform the contribution base to include more services, especially because of the disconnect between which services are assessed and which services are subsidized,” said the California Public Utilities Commission. “All the USF programs subsidize access to broadband services; yet, the FCC has explicitly declined to assess surcharges on broadband services when it reclassified broadband as an ‘information service.’”

Changing the base would decrease rates, “provide telecommunications services to all” and “ultimately ensure the sustainability of the USF while alleviating ratepayer’s current excessive burden,” said Public Knowledge. PK noted AARP, the National Tribal Telecommunications Association and Free Press filed similar comments. "Broaden the base by requiring a percentage of broadband revenue be added, or by requiring payments on a per-connection basis,” said PK.

New America’s Open Technology Institute also suggested expanding “classes of carriers” to include broadband. “Instead of focusing on the USF cap sideshow, the FCC should tackle genuine problems like reforming the USF contribution scheme and strengthening participation in programs like Lifeline,” said Amir Nasr, OTI policy analyst.

A cap would place E-rate at risk and also would make it more difficult for the FCC to propose such initiatives as its telehealth NPRM (see 1907290011), said AARP.

WTA maintained Section 254 of the Communications Act and “contextual discussion” of the USF make it clear Connect America Fund, E-rate, rural healthcare and Lifeline “must be supported through a specific, predictable and sufficient mechanism that is tailored” to “distinct needs.” NTCA said, “Section 254 clearly sets out the determination already made by Congress for separate universal service mechanisms, each with its own ‘sufficient, predictable, and specific’ funding.”

Brent Skorup of George Mason University’s Mercatus Center favored capping the USF at 2018 levels and said the FCC “should consider reducing the amount that US residents must pay” for the fund “and its various programs and subprograms.” The fund has been “growing despite an increasingly competitive telecommunications market,” said Skorup, calling the program “ineffective at achieving its intended goals.” Researchers, auditors and lawmakers “have long criticized the Fund … for its distortionary financing, fraud, and lack of FCC oversight of disbursements,” he said.

The CommonSpirit Health healthcare system supports “maintaining E-rate applicants’ priority over E-rate funds.” It wants “a cap sharing mechanism for the E-rate and RHC programs, as a temporary measure to protect against funding shortfalls.” It's against “a collective cap.”

AASA|The School Superintendents Association appreciated the FCC extended comments by two weeks but said that overlapped not only with summer but also with the first days of school. It urged the “FCC to be mindful and deliberate in scheduling E‐Rate related NPRMs at a time that can better capture and reflect feedback from schools and libraries.” Many school associations and school districts, large and small and including in the Washington suburbs, said a cap would harm their schools, forcing them to cut back on broadband and technology and pitting schools against rural healthcare (see here, here, here and here).