Contact: Brenda Cordwell, bcordwell@jsitel.com, 301-459-7590
GREENBELT, MD, April 17, 2008 – John Staurulakis, Inc. (JSI), in comments filed today, asks the FCC to eliminate the “identical support” rule, reject reverse auctions and an overall cap of the Universal Service Fund, and consider contribution reform along with any further changes to the universal service program. The comments are in response to the FCC’s three Notices of Proposed Rulemaking (NPRMs) released January 29, 2008 (WC Docket No. 05-337 and CC Docket No. 96-45).
“Today, federal universal service support plays a critical role in the development and maintenance of the public switched telephone network. Upon review of the issues raised in the three NPRMs, JSI recommends the Commission take actions designed to support and reinforce the longstanding aims of the program,” the comments argue.
JSI agrees with FCC’s tentative conclusion that elimination of the identical support rule should be the first step in any federal USF reform agenda. Federal universal service support distributed under the identical support rule has nothing to do with the actual cost of providing service in rural areas.
Reverse auctions, on the other hand, should be rejected as a way to determine high-cost universal service support, the JSI comments say. Adopting reverse auctions would have a chilling effect on investment in infrastructure in rural communities.
JSI also recommends that the FCC set aside the Federal-State Joint Board’s recommendation to cap the overall Fund at $4.5 billion and place caps on individual programs during a transitional period. JSI feels that the Joint Board has not demonstrated that $4.5 billion is sufficient to fulfill the current purposes of the Fund, and therefore a cap on the program is not in the public interest.
JSI also points out that FCC failed to address contribution reform in any of the NPRMs and urges the Commission to finally modify the contribution base prior to moving forward with the arduous process of reforming the entire universal service mechanism. “Without taking this essential step, the sufficiency and stability of the very fund that the reforms are intended to address would be placed in even greater peril,” JSI argues in its comments.
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JSI provides a full array of financial, management, regulatory, business development, marketing/public relations and strategic services, as well as education and training. Established in 1962, JSI today provides these services, and more, to hundreds of companies across the nation. JSI also offers analysis and review of such competitive-focused issues as pricing and bundling, VoIP and IPTV assessment, CLEC and video/cable operations, strategic partnerships, image and identity, and mergers/acquisitions. With more than 95 professionals on staff, JSI remains a leader in offering business solutions to independent providers. In addition to its Greenbelt, Md., headquarters, JSI has regional offices in Atlanta, Minneapolis, Austin, and Salt Lake City.
