To All Firm Clients –
On March 16, 2010, the Federal Communications Commission (“FCC” or “Commission”) released its highly anticipated National Broadband Plan. The Plan, however, lacks specific details on the FCC‘s proposal to transition the Universal Service Fund (“USF”), currently supporting traditional switched service, to universal broadband support.
The Commission confirmed its recommendation to end support for basic voice services by 2020 by shifting the High-Cost portion of the Fund into the Connect America Fund (“CAF”) to support broadband-based communications services. The Commission emphasized accountability, efficiency and sustainability. To sustain the Fund, the FCC suggested expanding the contribution base but neglected to adopt a specific recommendation to achieve this goal. The Commission did suggest, without identifying specifics, that it will likely include broadband providers in the USF contribution base.
The Commission will issue a series of rulemakings seeking public comment on proposed rules to implement the Plan‘s recommendations. Congress may also propose legislation to address any issues the FCC suggested may be outside its current authority.
The FCC‘s National Broadband Plan could potentially overhaul the entire USF if approved by Congress. Clients should review this Advisory and the National Broadband Plan, available at: National Broadband Plan, or at a minimum, the Executive Summary, available at: Executive Summary. Further, clients are advised to monitor FCC rulemaking proceedings relating to USF reform generally and the National Broadband Plan in particular.
Clients are encouraged to contact the firm for further guidance. Questions about this Advisory or the FCC‘s National Broadband Plan may be directed to Michael P. Donahue at firstname.lastname@example.org or (703) 714-1319.