Ad Hoc Coalition Files Comments in USF Reform Rulemaking Proceeding


The Ad Hoc Coalition of International Telecommunications Companies filed early comments on June 26, 2012, on the USF Contribution Methodology FNPRM.  The Coalition said it is not taking a position on the merits of retaining the revenue-based system or adopting an alternative USF contribution methodology, but said in the event the FCC maintains the revenue-based system, the issues the Coalition has raised in numerous filings must be addressed and resolved within the context of the FCC’s initiatives announced in the FNPRM.

Comments are due July 9; Reply Comments are due August 6.

IMPORTANT MESSAGE:  The Coalition is currently unfunded and needs the financial support of its members, supporters and other international industry participants to continue its efforts ADVOCATING ON BEHALF OF EQUITABLE AND EASILY-ADMINISTERED FCC REGULATIONS FOR INTERNATIONAL SERVICE PROVIDERS, WHOLESALERS, PREPAID PROVIDERS AND INTERNATIONAL TRANSPORT (VOIP-IN-THE-MIDDLE) CARRIERS.

For the past three and a half years, the Ad Hoc Coalition has been able to advocate on behalf of the diverse interests of the international telecommunications community on a shoe-string budget funded primarily through donations and a significant investment of “pro bono” time and resources from our firm, The CommLaw Group.  The Coalition’s further participation in the FCC’s USF reform rulemaking proceeding on behalf of international service providers will no longer be possible without additional outside funding.

There remains much work to be done, including review, analysis and summarization of Comments filed in the proceeding by other industry members, identification of issues commanding responses and rebuttals from international service providers, and the development, drafting and submission of Reply Comments.  These are all actions we would highly recommend taking.  However, without additional funding commitments, the Coalition will be unable to take any further actions and will be unable to advocate for fair, equitable and administrable reforms to the Universal Service Fund, Telecom Relay Services Fund and other FCC programs that disproportionally impact international service providers, particularly when compared to the relative benefits universal service offers this industry segment.  In short, without additional funding, the recent filing of the attached Comments will be the final action taken by the Coalition.

Our financial goal to conduct the Comments review, summary and preparation of Reply Comments is $10,000.  If you would like to pledge your support and help fund the Coalition’s efforts, please contact Jonathan Marashlian at

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