AT&T Statement on FCC’s Action on Mobility Fund II and CAF II Auctions

Posted by: AT&T Blog Team on February 23, 2017 at 12:33 pm

The following may be attributed to Joan Marsh, AT&T Senior Vice President of Federal Regulatory:

“While many of us take broadband services for granted, many Americans living in rural communities remain unconnected.  Low population density, topographical barriers, and significant geographical distances make it economically unviable to deploy broadband in many rural areas. Today, the FCC, under Chairman Pai’s leadership, took significant steps toward addressing the digital divide and bringing mobile and fixed broadband services to hard-to-serve rural communities.  The FCC’s actions today move both the Mobility Fund II and CAF II Auctions closer to reality and are a big win for rural Americans.  By making these items a top priority for 2017, Chairman Pai is delivering on his commitment to Universal Service and his pledge to bring the benefits of the digital age to all Americans.”

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Walking in L.A.

Posted by: Joan Marsh on February 21, 2017 at 10:42 am

When I was a student at UCLA, my car (that was uninsured for theft) was stolen. I suddenly found myself without basic transportation in Los Angeles. The logistics of getting to school and work became quite challenging, forget about attempting a doctor’s appointment or a social event. I became a slave to bus schedules and favors from friends. And, contrary to the admonition in the Missing Persons’ song that was popular at the time, I walked in LA.

After six months, I scraped together enough money to buy a friend’s 10-year-old dented Subaru mini-wagon. I loved that car as if it was a Cadillac. To this day, I remember my first day in the car driving down Santa Monica Boulevard feeling an enormous sense of freedom and opportunity. I learned that transportation in LA was not a luxury – it was a necessity.

This week, the FCC will consider two items central to delivering broadband – the 21st century necessity – to rural communities that have been left behind. That these items are moving forward quickly is no surprise given Chairman Pai’s enduring commitment to closing the digital divide, particularly in rural America. The FCC’s Connect America Fund (CAF) and Mobility Fund Phase II (MF II) programs represent the best and perhaps only path to broadband deployment in these rural communities. And the MF II item now on circulation appears to take huge steps toward the adoption of a clear and fair framework that will increase both the efficiency and effectiveness of the program.

But the hard fact is that there are clear limits to the amount of subsidy money available in both programs, and tough policy cuts will need to be made on the breadth and scope of the services that will ultimately be delivered to these communities.

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Making Access to Broadband
A Reality for Low-Income Americans

Posted by: Joan Marsh on November 23, 2016 at 2:34 pm

AT&T has long supported universal access to broadband for all Americans.  And through our Access from AT&T low cost broadband program, we are making broadband a reality for low-income consumers for $10 a month or less.  We believe that, at this time, Access from AT&T is a better way for AT&T to address broadband adoption than by participating in the new Lifeline broadband program.  So, today, we are notifying the FCC that we are “opting-in” to the forbearance granted in the Commission’s 2016 Lifeline Modernization Order.

AT&T has consistently supported including broadband in the Lifeline program.  And we still do. Broadband is unquestionably the service that must be universally available to all Americans.   But the structure and administration of the Lifeline program itself needed major modernization before it could be relied upon as an agent of change.  Our support for comprehensive reform of the federal Lifeline program included proposals on consumer empowerment and eliminating the inefficient service provider role in administration of the Lifeline program.  Recognizing this, the FCC adopted important process reforms at the same time that it updated the program to cover broadband.  Chief among these was the decision to take service providers out of the role of determining eligibility and administering other program rules by establishing a new National Eligibility Verifier, which will be run by the Universal Service Administrative Co. (USAC).

The problem is, while the new Lifeline broadband requirements for service providers take effect in a little over a week, the National Eligibility Verifier will not be fully implemented until 2019.  In the interim, service providers are left carrying the same administrative load and compliance risks they had before the reform.  AT&T wireline currently has less than 3% of the voice Lifeline market.  Accepting the forbearance means we still have the option to offer Lifeline discounts on broadband.  But it makes little sense to spend resources on implementation of soon-to-be-replaced administrative rules for a new service when we are already offering low-income consumers a better deal through our Access from AT&T program.

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Making Mobility Fund II Work

Posted by: Joan Marsh on November 7, 2016 at 1:15 pm

As part of the Connect America Fund (CAF), the FCC created the Mobility Fund – a universal service support mechanism dedicated exclusively to mobile services – and in 2012 held the first Mobility Fund (MFI) auction. Since that time, the FCC has gained substantial experience with other CAF programs, including CAF I and II. So, as the FCC considers a draft order on the Mobility Fund II (MFII) framework, the FCC has a substantial CAF history on which to assess any MFII framework, and consider whether methods and procedures that have been effective elsewhere should apply consistently to all CAF programs.

Unfortunately, with the MFII proposals now pending for a vote, it would appear that many of the important CAF learnings have been lost. This is all the more regrettable as MFI continues to face significant implementation challenges, with substantial funds still undisbursed and compliance challenges mounting.

There are three areas in which the Commission could act to make the MFII program stronger, more sustainable and more attractive to participants.

First, the MFII proposal parts ways with the sensible build-out milestones adopted in CAF II. With CAF II funding, the deployment milestones progress evenly over six years. This approach better reflects how networks are planned and deployed and thus reduces obstacles to carriers accepting funding obligations. All CAF II recipients must deploy in even increments over six years with the first enforceable milestone of 40% in year three (to allow initial time for planning and procurement) and 20% increments in the following years to full deployment.

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The FCC’s Half-Shoveled Sidewalk

Posted by: Hank Hultquist on January 13, 2016 at 11:40 am

Many communities have laws that require residents to shovel their walks within 24 hours of a snowstorm. Where I live, it’s become something of a game to take pictures of the unshoveled sidewalks of politicians or other prominent citizens and post them on the Internet. But the people who really get under my skin are the ones who apparently think they’ve discharged their duty by clearing a narrow, shovel’s-width path that may not even connect to the path shoveled by their neighbor. I suspect this half-hearted approach is sometimes taken by kids who are told that they can’t play in the snow until they shovel the walk.

Unfortunately, the FCC appears to have its own half-shoveled sidewalk. At its December open meeting, the Commission acted on a petition for forbearance that was filed by USTelecom. While the FCC granted some of the relief that was sought, it denied USTelecom’s request for forbearance from universal service obligations in places where price cap incumbent local exchange carriers (ILECs) receive no high-cost universal service support. In explaining this denial, the FCC sounds an awful lot like a kid explaining why he shoveled only part of the sidewalk.

The FCC acknowledges that the places where ILECs continue to have these universal service obligations “are expensive to serve.”  In fact the FCC goes so far as to say that “[d]ue to the challenges of serving such [high-cost and extremely high-cost areas, the FCC] cannot reasonably predict that the price cap carrier or another provider would have a business case to maintain voice service at reasonably comparable rates absent support. . . .” 

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