Dear Chairman Pai:
We thank the Federal Communications Commission (FCC) for its recent Order addressing certain High-Cost Universal Service Fund (USF) budget shortfalls. The recent Order is an essential near-term step in the right direction, but we encourage the FCC to adopt longer-term USF budget solutions that will ensure rural Americans the opportunity to obtain voice and broadband services on a basis that is reasonably comparable to what other Americans enjoy.
In multiple letters, Congress has expressed broad support for addressing High-Cost program shortfalls. In May 2017, nearly 160 Members of Congress wrote to the FCC, expressing concern about the impact of insufficient USF resources on rural consumers. In October 2017, nearly 75 Members of Congress asked the FCC to immediately address the budget shortfall and continue collecting the same USF budget levels for the High-Cost program pending development of a longer-term solution.
The FCC's recent Order approving an infusion of funds into the USF is greatly welcomed, but it also represents a recognition of, and an incomplete salve for, a more significant problem -- the fact that the High-Cost USF program has been and remains insufficient (notwithstanding the recent injection of support). This persistent insufficiency is affecting the ability of smaller rural broadband providers to effectively deliver broadband services in the most rural areas of America. For example, we understand the FCC's cost model for smaller operators is still not funded at the levels as designed, while those smaller carriers that do not receive model support may face even steeper support cuts than before when the program's new "fiscal year" takes effect on July 1. For all the work just undertaken, these recurring budget shortfalls will yet again translate to lower speeds, more unserved locations, and higher prices for rural consumers and businesses.
To be clear, we greatly appreciate the steps taken by the FCC thus far to address such concerns. However, until longer-term budget solutions are addressed as well, many smaller operators will remain unable to offer high quality, affordable broadband to consumers across rural America. For these reasons, we encourage the FCC to act as soon as possible pursuant to the notice of proposed rulemaking included with the order to provide support that is both sufficient and predictable on a longer-term basis as mandated by statute.
Thank you for your consideration. We share your goal of eliminating the digital divide and look forward to working with you to ensure rural American consumers and businesses have access to quality, affordable broadband.