OPASTCO: Reject Big Cable's Universal Service Plan

The Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO) responds to the National Cable and Telecommunications Association proposal for new universal service rules with a resounding "no." Almost all OPASTCO members are rural telephone companies and most receive the majority of their cost recovery and operating revenues from a combination of high-cost universal service support and intercarrier compensation.

OPASTCO writes:

The FCC should reject NCTA's petition for rural service areas. By focusing solely on the support needed to provide voice service to customers that lack a competitive alternative, adoption of NCTA's proposal would virtually guarantee that the Commission's goal of ubiquitous, robust broadband availability will not be achieved in these territories. There are other ways the Commission can address concerns regarding the current USF contribution factor that would not harm broadband investment in rural service areas. They are:

1) expanding the base of providers and services that contribute to the Fund including, at a minimum, all broadband Internet access providers;

2) limiting support in each rural service area to one fixed broadband provider and one mobile wireless provider; and,

3) abandoning the identical support rule and, at least in rural service areas, basing support for competitive eligible telecommunications carriers (ETCs) on their own costs.

Finally, the Commission's National Broadband Plan should recommend that OPASTCO's plan for a Universal Service High Speed Broadband Fund be used as a starting point for further rulemaking proceedings on USF and ICC reform for rural service areas.