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The Voice of Rural & Regional Carriers
December 8, 2010
YiaECFS
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12'h Street, SW
Washington, DC 20554
Re: WC Docket No. 10-90; WC Docket No. 05-337
GN Docket No. 09-51
Dear Ms. Dortch:
On December 7, 2010, RCA, including Steven Berry; Tim Donovan; Bob Koppel with Lukas,
Nace, Gutierrez & Sachs; and the undersigned, and several of RCA's carrier and associate members,
including Johnie Johnson and Brian Spurgeon, Nex-Tech Wireless; Gwen Donaldson, representative
for Nex-Tech Wireless; Doug Minster, Atlantic Tele-Network; Chuck Willis, Bluegrass Cellular; Patrick
Riordan, New Cell, Inc.; Ed King, Cellular Properties; Nash Neyland, Cavalier Wireless, LLC; and David
Peters, Velleros; met with Angela Giancarlo to discuss implementation of the FCC's Universal Service
Fund (USF) reform recommendations in the National Broadband Plan.
At the meeting, RCA outlined its critical public policy objectives for Universal Service reform
summarized in the attached document, copies of which were distributed during the meeting. In addition
to RCA's public policy principles, RCA members discussed how they are currently using USF to deploy
advanced services to rural and regional areas that, without support, would not be served today. RCA
members personalized how the USF reform could impact their current and future business plans, and
how phasing down USF support will negatively impact rural and regional carriers and the consumers
they serve.
RCA fully supports the FCC's goal, as outlined in the ational Broadband Plan, to accelerate
investment in broadband infrastructure and make broadband services more accessible throughout the
United States, particularly for people living in rural and insular, high-cost areas, tribal lands, and for low
income Americans. Mobile broadband is a critical ingredient for improving and enhancing the lives of
all Americans. Consumers are increasingly choosing wireless technology as their primary mode of
communicationsl This choice must be reflected in the FCC's USF reform. A success-based funding
model will ensure that funding is provided to those carriers that construct facilities and acquire
customers, while providing cost-saving measures to decrease the size of the fund.
1 Tele<vmmuni'l1tions: Enham?d Data Colledion Could Help FCC Better Monitor Competition in the JWireless Indus/l)\ GAO,
Report to Congressional Requesters; GAO-IO-779 Ouly 2010).
This exparte notification is being ftled electronically with your office pursuant to Section 1.1206
of the Commission's Rules.
Sincerely,
Rebecca Murphy Thompson
General Counsel
cc: Angela Giancarlo
RCA1 Public Policy Objectives for Universal Service Reform
December 2010
USF Reform Generally
? Funding must be competitively and technologically neutral ? cannot favor or
disadvantage any class of funding recipients or any type of technology used to provide
service in rural and high-cost areas
o Important for FCC to recognize ever expanding role of mobile wireless
communications for both voice and broadband services
square4 Consumers are increasingly choosing wireless as their primary mode of
communications
o Any phase-down of support must have equal transitions for wireline and wireless
carriers
square4 RCA opposes NBP proposal for 5 year phase-down of wireless voice
support/10 year phase-down of wireline support
square4 RCA supports 10 year phase-down of support for both ETCs and CETCs,
with no flash cuts
? Funding must be provided on a highly disaggregated basis, and efficiently targeted
to rural and high-cost areas where support is most needed
o Support must be carefully targeted to areas where the business case for voice
service or next generation technology does not exist without such support
? Funding must be success-based and forward-looking
o Success-based: support should be tied to the customer not the carrier, and should
shift with the customer if the customer switches carriers. ?Facilitate a market-
based approach whereby each end-user comes to be served by the most efficient
technology and carrier.? (Federal State Joint Board, First Report and Order,
1997)
square4 Incents cost-effective deployment and service
square4 Incents competition: lower rates and better service
square4 Eliminates risk of significant USF growth
o Forward-looking: level of support should be based on a forward-looking cost
model. If necessary, different cost models could be established for wireline and
wireless carriers.
1
RCA represents the interests of nearly 100 regional and rural wireless carriers with licenses covering more than 80
percent of the U.S.
? Reforming USF to accomplish ubiquitous broadband deployment must accomplish
the statutory principle that services in rural areas should be reasonably comparable
? in both price and quality ? to services available in urban areas
o RCA supports 4/1 speed as established in the National Broadband Plan
? USF should support the provision of advanced broadband and voice services in
rural and high-cost areas
o Transition away from legacy support must mirror industry conversion from voice
to IP networks to avoid prematurely abandoning legacy voice networks
o No phase-down of support until FCC implements an adequate replacement
support mechanism
Proposed Mobility Fund
? RCA supports FCC?s objectives to accelerate investment in broadband
infrastructure and to make broadband more accessible in rural and high-cost areas
? Proposed Mobility Fund would not be an effective step toward USF reform
o Single winner reverse auctions will not benefit consumers
square4 Would establish a monopoly provider, and thus encourage poor service or
high prices ? or require intensive government regulation to monitor
service levels and pricing
square4 Would encourage anti-competitive incentives to participate, including
blocking support for competitors or off-setting contributions
square4 Would favor larger carriers, and as proposed, could result in a single
nationwide winner
square4 Small geographic areas (census tracts) could result in an inconsistent
checkerboard of service and technology, leaving unserved areas and dead
spots
o Proposed funding level is wholly insufficient, will provide only token assistance
for broadband deployment, and will do so only on a one-time basis
square4 Critical for funding to support not only capital expenses, but also
operating expenses
o Carriers already providing 3G in rural areas should not be penalized ? they should
be eligible to participate so as to seek funding for 4G.
? Cost Model combined with success-based, portable funding is a better approach
o Cap support at an appropriate level; do not limit the number of eligible service
providers
o Encourages competition and new competitive entry