Earlier today, the American Cable Association, the Competitive Carriers Association, the National Cable & Telecommunications Association, the Wireless Internet Service Providers Association, DISH Network, EchoStar and ViaSat co-signed a letter to Marlene H. Dortch, secretary of the Federal Communications Commission, regarding “significant concerns” with agency proposals for continuing Phase I of the Connect America Fund (CAF) for price-cap carriers as well as with the direction of the overall CAF program implementation. “The proposals in the recent FNPRM represent a giant step backwards in the Commission’s efforts to modernize the universal service high-cost program and should not be adopted as proposed,” they noted. “Instead, the commission should issue a supplemental notice seeking comment on proposals that would provide all service providers, both incumbent and competing providers, an opportunity to receive support. More broadly, the commission should ensure that its upcoming decisions addressing issues pertaining to CAF distributions put the support programs on a more competitively and technologically neutral path, and ensure that support is distributed efficiently.”

The signatories contend the pending FNPRM “completely ignores the principles of competitive and technological neutrality emphasized in the National Broadband Plan.” In addition, they say the FNPRM continues to ignore the needs of remote and tribal areas. “The Commission stated that it would establish a Tribal Mobility Fund to award up to $50 million to support deployment in tribal areas,” the letter says. “It also stated that it would complete work by the end of 2012 on a Remote Areas Fund (RAF), which would provide at least $100 million to support deployment in areas too costly to serve with wireline technology. In the year since the CAF Order was adopted, the Commission has yet to achieve either of these objectives.”

As such, the groups advice the FCC to “issue a supplemental notice seeking comment on proposals that would more equitably distribute CAF Phase I funding, including proposals that the undersigned entities submitted on the record in advance of the FNPRM.”

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