Advocates Bring USF Reform Message to FCC

Representatives of several civil rights, media reform, and public interest organizations (collectively, the “Public Interest Representatives”) met separately with Federal Communications Commission staffers to discuss potential reforms to Universal Service Fund (“USF”) mechanisms, as contemplated in an array of ongoing and upcoming FCC proceedings. The Public Interest Representatives focused their comments on four general areas within the broad range of issues potentially to be dealt with in these expansive and comprehensive USF reform proceedings.

• Broadband as a Universal Service. The Public Interest Representatives repeated the point that broadband is the essential telecommunications platform of the 21st Century, and thus should be considered a universal service. This means that broadband-capable facilities and broadband services should be not only permitted, but required of providers receiving support from the Connect America Fund, or from any other subsequent iteration of or successor to the current high-cost mechanisms; and also that adoption support should be available for broadband service provided to low-income individuals. The Public Interest Representatives acknowledged that the Commission will need to make several choices in order to balance various priorities during the transition to a broadband-oriented fund. Nevertheless, the Commission cannot shy away from making these decisions necessary to modernize and revitalize USF.
• Lifeline/Linkup Expansion and Modernization. The Public Interest Representatives indicated that the Commission generally should proceed along the lines suggested in the Joint Board’s most recent recommended decision on Lifeline and Link Up, and should do so expeditiously. While the Commission may focus also in the immediate near-term on Notices of Proposed Rulemaking in other USF dockets, revisions to these critically important adoption support programs cannot be left to linger. The Public Interest Representatives reiterated their support for expanded eligibility measures and other reforms, though modified in some respects from the Recommended Decision conclusions in the ways suggested by their organizations’ respective filed comments. They also encouraged the Commission to move ahead with pilot programs to facilitate broadband adoption by low-income individuals, and cautioned against potential pitfalls in creation of any national database – noting that, if not carefully designed and safeguarded, such a database could dampen enrollment by verifiable and fully eligible beneficiaries.
• Creation of the Connect America Fund and High-Cost Fund Reform. While most of the Public Interest Representatives’ organizations have reserved comment on high-cost fund reform and creation of the Connect America Fund to this point, they expressed their eagerness to continue and broaden their engagement on these issues as the Commission develops and proposes concrete rule changes. The Public Interest Representatives agreed that there are several paths the Commission could take to reform current mechanisms, in order to improve the accountability, efficiency, and usefulness of the fund. Yet, they explained that changes to distribution and contribution methodologies must neither discourage broadband adoption by unduly increasing the contribution burden on consumers, nor improperly limit the choice and quality of service available to residents of unserved and underserved areas.
• Mobility Fund Issues. Finally, the Public Interest Representatives briefly presented very general views on the ongoing Mobility Fund proceeding, indicating that some number of the organizations they represent intend to file reply comments in that docket this month. During these meetings, they expressed some reservations about reverse auction mechanisms that might encourage a “race to the bottom” approach or provide no support for ongoing mobile wireless service operations.

Attendees represented American Civil Liberties Union; Benton Foundation; Consumers Union; Leadership Conference on Civil and Human Rights; Media and Democracy Coalition; Media Access Project; the Media Action Grassroots Network; New America Foundation; and Public Knowledge.