Comprehensive USF Contribution Reform Rulemaking Set for Late April Vote by FCC


The Federal Communications Commission (“FCC”) schedules consideration of a Universal Service Fund Contributions Notice of Proposed Rulemaking at its monthly Open Meeting, set for April 27, 2012.  The FCC will consider a Further Notice of Proposed Rulemaking seeking comment on proposals to reform and modernize how Universal Service Fund contributions are assessed and recovered.

FCC Open Meeting is scheduled to commence at 11:00 a.m. in Room TW-C305, at 445 12th Street, S.W., Washington, D.C. The event will be shown live at

Full Agenda for this month’s Open Meeting is linked here:

Universal Service is, without question, the single most important issue impacting the regulation of the communications services industry.  The current “revenue-based” contribution system is plagued with problems, not the least of which is a USF Contribution Factor rapidly approaching 20%.  As USTelecom recently pointed out in its ex parte letter to the Commission:

“Problems with the current interstate revenue based contribution mechanism are many, and they go beyond the size of the base or the dizzying height of the contribution factor.  The current USF contributions system is also rife with outdated methods and procedures that create waste, inefficiency and destabilizing competitive discrepancies. Merely broadening the base will not fix these procedural issues, but rather will simply result in spreading these problems to other services.”

April 27, 2012 will undoubtedly mark a vitally important date in the history of the communicatons services and broadband industries with likely implications for Internet commerce, in general, as well.  How the FCC decides to fund Universal Service will more than likely have an impact on every single business that touches a communications network, whether public or private, narrowband or broadband, switched or non-switched.  The importance of the upcoming USF reform proceeding cannot be overstated.  If one needs a reminder of the consequences that may result if the Commission is incapable of developing Rules modeled for the rapid pace of technological and entrepreneurial development embodied by the communications sector, look no further than the Introduction to our Firm’s Law Review article, entitled:  “THE MIS-ADMINISTRATION AND MISADVENTURES OF THE UNIVERSAL SERVICE FUND: A STUDY IN THE IMPORTANCE OF THE ADMINISTRATIVE PROCEDURE ACT TO GOVERNMENT AGENCY RULEMAKING.”

We urge all clients and interested parties to plan for the release of the Further Notice of Proposed Rulemaking.  If you are interested in participating in the proceeding either individually or as part of a Coalition of similarly-situated service providers, please contact Jonathan S. Marashlian at  Our firm has experience organizing and coordinating FCC advocacy and rulemaking participation campaigns on behalf of industry segments (as an example, visit

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