Overhaul USF Now, Wireless ISPs Tell FCC

In comments filed at the Federal Communications Commission, the Wireless Internet Service Providers Association ("WISPA") urges the FCC to promote the objective of ubiquitous broadband availability by subsidizing providers that serve "unserved" and "underserved" census blocks. By establishing a new subsidy program, the FCC will be able to sustain the funding initiatives created by the American Recovery and Reinvestment Act. It is high time to transition the high-cost, low-income Universal Service Fund ("USF") from supporting last-century voice services to a system that supports broadband deployment. Initial funding for this program would come from the existing USF contributions for voice services that continue to generate windfall profits for carriers, with additional contributions form broadband revenues for services such as data, VoIP and video distributed over broadband networks. The current system is in sore need of repair because the cost basis for funding support is based on the high costs of wireline voice service, not the lower costs of wireless voice service. As a result, carriers that provide voice services at lower costs reap a significant windfall - the difference between the higher USF cost and the lower actual cost. Further, rural wireline Eligible Telecommunications Carriers (ETCs) have been using USF high-cost subsidies to construct new plant capable of providing both voice and broadband service and then allocate all of the capital cost to voice service, thereby successfully obtaining government subsidies for construction of broadband infrastructure. The FCC should initiate a transition period, beginning January 1, 2010, where the Commission would continue to support already-constructed wireline ETC plant for the shorter of: (a) five years, or (b) the remainder of the amortization period for the infrastructure involved. There should be no USF high-cost support whatsoever for new capital expended to construct obsolete landline voice infrastructure on or after January 1, 2010. With respect to wireless voice ETCs, there should be no USF high-cost support beyond December 31, 2010 for any wireless ETC that bases its request for support upon a landline ETC's costs, as opposed to the wireless provider's own actual costs. Support for new construction occurring on or after January 1, 201ashould be limited to facilities capable of supporting broadband service.