NASUCA Says Broadband Cannot Completely Replace Traditional Telephone Service

In comments filed with the Federal Communications Commission on Universal Service Fund (USF) reform, the National Association of State Utility Consumer Advocates agrees that the dollars saved from "cutt[ing] inefficient funding in the legacy high-cost support mechanisms" are appropriately used to support broadband deployment and adoption. But NASUCA raises questions about the "long range goal" stated in the National Broadband Plan to "replace all the legacy High-Cost programs" with the new Connect America Fund.

Based on the explicit descriptions of the CAF, it appears that its focus is to provide support only "where there is no private sector business case to provide broadband and high-quality voice-grade ser-vice...." Although NASUCA fully supports providing support for broadband, this does not mean that support for broadband can completely replace support for traditional voice services, or that such support can be limited to areas where, in the absence of support, there is no "business case" for sup-plying "high-quality voice-grade service." The statutory directives still exist for "affordable" basic telecommunications services, and for telecommunications services in rural areas that are reasona-bly comparably priced to those in urban areas; they have not been replaced by the statutory direc-tives regarding advanced services.