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Comments Sought on Additional High-Cost USF Reforms

Changes would impact both A-CAM and Legacy companies

As reported in our March 27 e-Lert, the FCC released a series of orders granting additional A-CAM and Legacy funding, along with an associated Notice of Proposed Rulemaking (NPRM) seeking comment on ways to modify the budget control mechanism and other reforms. This morning, the Federal Register (FR) published the NPRM, setting May 25 as the deadline for filing comments and June 25 for reply comments. The related orders, however, have not yet been published in the FR so their effective date is still not known. Once that occurs, JSI will alert clients to key dates, including the timeframe when the FCC will disburse the additional Legacy funding allocated in the orders.

Below we highlight some of the topics raised in the NPRM, which could ultimately lead to major decisions impacting your company. Given the critical nature of these topics, we encourage clients to consider filing comments, either individually or jointly.

In the NPRM, comment is being sought on:

  • Proposals to modify the budget control mechanism to provide greater long-term stability and predictability for Legacy carriers
  • Proposals related to A-CAM:
    • Allowing Legacy companies whose support is greater than A-CAM support (glidepath carriers) to elect A-CAM
    • Fully funding the A-CAM to the $200 cap
    • Opening a new window for Legacy non-glidepath carriers to elect A-CAM under the existing timetable
  • Changing the current every-other-year process by which Legacy support is eliminated if competitors prove they serve 100% of the locations in a study area to a process where a reverse auction would occur if competitors serve a lower percentage (such as 90%)
    • Comment is also sought on whether this process should replace the rate-of-return challenge process which has yet to occur
  • Lowering the $250 per line monthly cap on federal support
  • Whether the Capital Investment Allowance (CIA) and OpEx caps have been effective, and if not, if they should be eliminated

If you are interested in filing comments or have any questions regarding the NPRM or orders, please contact John Kuykendall, Brian Sullivan or Steve Meltzer in the Maryland office at 301-459-7590 or Douglas Meredith in Utah at 801-294-4576.

2018-04-25T16:19:38+00:00 April 25th, 2018|e-Lerts|