Comments Filed on the Future of the Universal Service Fund

The Federal Communications Commission asks a series of questions about the current set of programs supported though the Universal Service Fund, particularly in light of the broadband initiatives funded through the American Rescue Plan Act of 2021 (ARPA) and the Infrastructure Investment and Jobs Act (IIJA). Commenters have focused heavily on how to fund universal service programs given the problems with the current contribution mechanism and ways to modify existing support programs. We have reviewed these comments and respectfully submit reply comments. We make six points in these reply comments:

1. Fund Universal Service Through General Revenues, Not Taxes on Services
2. Stop Mandating Minimum Projected Demand for High-Cost Subsidies
3. Set Budgets for CAF and Other Infrastructure Programs
4. Include Measurable Objectives and Evaluation
5. Continue Using Reverse Auctions
6. Create a Task Force to Overhaul USF and Monitor ARPA and IIJA Funds