Entries in FCC Filings (20)


Six ILECs Defend Rights of First Refusal Proposal

ABC Plan Participants Respond to Challenges from Opponents 

On September 6, the six price cap ILECs who developed America’s Broadband Connectivity Plan (ABC Plan) for USF/ICC reform filed reply comments which addressed a range of criticism that has emerged from different corners of the industry.  Since the ABC Plan was released on July 29, it has been hailed by some as a great compromise between industry parties who are normally rarely in agreement, and it has been challenged by others as extremely flawed and geared towards cementing ILEC competitive strongholds on the broadband industry.  The ABC Plan’s authors -- AT&T, CenturyLink, FairPoint, Frontier, Verizon and Windstream -- open the reply comments by insisting, “The comments filed in this proceeding demonstrate the unprecedented breadth of support for the ABC Plan and the Consensus Framework,” and urge they the FCC to adopt this proposal.  They add, “It would be futile for the Commission to continue to wait for a perfect consensus, as one will never emerge.”

One of the highly debated issues in the ABC Plan throughout the initial comments to the FCC’s Universal Service-Intercarrier Compensation Transformation Proceeding Public Notice was the ILECs’ proposal for rights of first refusal (ROFR) of broadband support in unserved areas.  Basically, the ABC Plan would allow ILECs who have made “substantial existing broadband investments” to at least 35% of a wire center where there are no other unsubsidized competitors to either accept or decline CAF support for that wire center.  According to the ABC Plan, “If [the ILEC] accepts the offer of the baseline support, then the incumbent LEC assumes all of the broadband service obligations for the ten-year term of CAF support.”  If the ILEC declines the offer, any other provider can compete for the CAF support in a reverse auction, and presumably the most cost-efficient competitor would win the support.

Opposition to the ROFR proposal primarily consisted of arguments that the proposal is anticompetitive and would result in a windfall for ILECs at the expense of consumers.  US Cellular comments that the ABC Plan in general is “a blueprint for a heist,” and “Allowing ROFR will reverse over a decade of Congressional and Commission focus on consumers, rather than carriers, as the beneficiaries of support.”  US Cellular argues that ROFR is not competitively neutral and would give the providers the power to decide which technology is deployed in rural areas, even if it is not the most cost-efficient, fastest, or most desired broadband technology. US Cellular further argues that if 80% of ILECs exercise their ROFR as anticipated, the ILECs will essentially be “catastrophically stunting entry by competitive wireless carriers for at least ten years.”

Additional noteworthy examples of opposition to ROFR come from Free Press, Alaskan telecommunications provider General Communications Inc. (GCI), and Cox Communications.  Free Press argues “The self-interested nature of this plan on the price cap side is perfectly illustrated by their proposal to have a Rights of First Refusal that allows them to insulate themselves from the competition that reverse auctions are supposed to create.” Cox also argues that ROFR would distract from the purported benefits of reverse auctions in totally unserved areas: “there is no public policy rational for preferring any provider;” and only if price cap ILECs are determined to be the most efficient provider via a competitive bidding process, “then the bidding process will award them the subsidies.”  Cox also adds that, “There is no evidence at all that granting a right of first refusal would lead to any consumer benefits.”

GCI argues against ROFR from its unique perspective as a rural Alaskan broadband provider.  GCI insists that ROFR “would be disastrous for ETCs like GCI and the customers they serve, would turn back the clock on rural wireless and broadband deployment, and more importantly, would harm public safety.”  GCI insists that both wireless and wireline services should be supported in Alaska.  GCI explains that wireless is particularly important for Alaskan public safety and the state’s job market, which “is characterized by a significant transient workforce” of individuals who relocate seasonally, work on fishing boats and oil pipelines, and “cannot depend on wireline service.”

The six ABC Plan ILECs defend the ROFR proposal and insist that its purpose is not to entrench their positions in the market; rather, “It is a narrowly-targeted means of accelerating broadband deployment and preventing inefficient duplication of existing facilities.”  The ILECs point to the limitations of the proposal -- that ROFR is not allowed unless the ILEC has deployed broadband to 35% of the wire center, and ROFR is not allowed if there is a single unsupported competitor -- as evidence that ROFR will not “tilt the competitive landscape” in favor of ILECs.

The ILECs believe that ROFR will help price cap carriers leverage existing investments to provide broadband in nearby unserved areas, and “It is essential to take advantage of existing investments in ILEC infrastructure to leverage those facilities in a way that will deliver ubiquitous access to broadband while working within the current budget for high-cost funding.”  The ILECs further argue against criticism that ROFR is not competitively or technologically neutral by insisting that the unserved areas could feasibly be served by any competitor with any technology if the ILEC refuses the support.

Do you think ROFR is intended to prevent stranded investment and help the price cap ILECs deploy broadband in unserved rural areas -- the areas where price cap ILECs have long been criticized for not making a very good effort to serve -- or is ROFR a means for the ABC Plan participants to strengthen their market power at the expense of consumer benefit and competition?  Both sides make persuasive arguments, and the ROFR proposal has gained support from other mid-sized ILECs who did not participate in the ABC Plan, such as members of the Independent Telephone & Telecommunications Alliance (ITTA).  In its joint comments with Cincinnati Bell, Hargray Telephone Company and Hickory Tech Corporation, ITTA urges the FCC to adopt the ROFR proposal as presented in the ABC Plan.

Your position in the industry will likely dictate whether you think the ROFR proposal is a boon or a bust, but one could get the impression that the ROFR opponents like cable and wireless providers are also trying to secure their competitive positions by attempting to block this proposal from being adopted.  It is possible that the FCC could impose further limitations on ROFR, such as requiring the ILEC to serve substantially more than 35% of the wire center.  A higher threshold may calm some of the opponents and even increase the number of unserved areas where support could be determined by reverse auctions, but the ABC Plan participants have warned that they will not support drastic modifications to the plan by the FCC. The ROFR issue seems to be one of the more dramatic topics, and it is also an area that may require the “shared sacrifice” that the FCC has been asking for since the NPRM was released in February—one possible outcome being that the ILECs would have to sacrifice their desired low deployment threshold. Hopefully, the rural consumers in unserved price cap ILEC areas will not have to sacrifice their need for high quality, reasonably comparable and affordable broadband service.

The reply comments by the six ILECs are available here.


Transitioning to CAF: RLEC Plan Steps and Impact

NTCA Outlines RLEC Plan’s Steps, NECA Calculates Preliminary Impact on RLECs' Slice of USF Pie

Last week, rural telecom association NTCA and the National Exchange Carriers' Association (NECA) held ex parte meetings with members of the FCC to provide additional details about the associations’ RLEC Plan for USF/ICC Reform—NECA submitted a chart illustrating how legacy USF support for RLECs may transition to the Connect America Fund (CAF) coupled with a Restructure Mechanism (RM); and NTCA presented a condensed summary of the steps in the RLEC Plan.

As shown below, NECA’s Preliminary RLEC CAF + RM Computation chart starts at $2b and accounts for modest growth of $50m per year up to “a total annual budget of $2.3b” by the sixth year.  By the eighth year, Legacy USF support is reduced by more than half, with CAF + RM support replacing the legacy funds without increasing the overall size of the fund by more than $300m.  According to NECA, “incremental funding will be necessary to enable access restructuring, promote further broadband build-out (but only to the extent supported by increases in USF/CAF funding above current levels for any individual company), and provide a reasonable opportunity to recover the costs associated with existing investments in broadband-capable plant.”

NECA’s calculations were produced “using industry-wide assumptions and growth rates, together with preliminary inputs and factors.”  NECA also provided a summary of their calculations and assumptions, and a description of the RM.  NECA explains, “The RM is designed to recover revenue losses as a result of capping interstate originating and terminating switched access rates at the start of access reform as well as revenue losses caused by reducing terminating access rates to targeted levels in three phases,” where the targeted level is ultimately the $0.0007 per minute terminating end office rate.

To calculate the RM, NECA explains, “The total revenue shortfall is the sum of the intrastate and interstate revenue shortfalls…The RM is calculated by offsetting the combined revenue shortfalls by increases in subscriber line charge (SLC) revenue.”  If residential rates in a study area are below the $25 local rate benchmark, the monthly residential SLC can be increased by 75 cents per year until the benchmark is met.  NECA further explains, “if additional SLC revenues in a given step exceed the intrastate RM, the SLC revenue in excess of the intrastate RM is then used to offset the interstate component of the RM;” and “earnings in excess of a 10% RoR for that year will be used to offset the intrastate component of the RM for that year after the SLC revenue offset has been taken into account.” 

Also helpful for understanding the potential road ahead for USF is NTCA’s summary of the steps in the RLEC Plan.  The four steps explained in NTCA’s August 26 ex parte filing are as follows:

Step 1: “Implement short-term ICC reform measures that confirm intercarrier compensation is due for all traffic originating from or terminating to the PSTN regardless of technology; VoIP pays established interstate access rates for all interexchange traffic and reciprocal compensation for local.”  The FCC should also address phantom traffic and access stimulation in this step.

Step 2: Short-term USF reform, beginning January, 1, 2012, including “a limitation on recovery of prospective RLEC capital expenditures,” and “cap recovery of corporate operations expenses by applying the current HCLS corporate operations expense cap formula to all federal high cost support mechanisms.”

Step 3: This step would initiate the process of capping interstate access rates with an 8-step “realignment program,” that includes unifying RLEC intrastate terminating access rates at interstate levels; reducing RLEC terminating local switching rates to $.005 per minute; and finally “unless the FCC determines otherwise, terminating local switching rates would be reduced to $.0007 per minute in 3 equal installments for RLECs.”  Step 3 would also see the implementation of the $25 rate benchmark (as described above in the summary of the NECA calculations).  NTCA emphasizes that “ICC rate reduction will be deferred in any year in which, for any reason, there is insufficient high-cost support and/or restructure mechanism funding available.”

Step 4: The final step in the RLEC Plan is to “implement an RLEC-specific CAF mechanism designed to re-focus existing RLEC USF support on broadband.”  As illustrated by the NECA chart above, legacy funding would decline as CAF funding is phased in.  NTCA explains that RLEC CAF support is determined “by subtracting the product of an urban broadband transmission cost benchmark times broadband lines in service, from actual RLEC network broadband transmission costs.”

If the RLEC Plan is implemented, NTCA recommends that the FCC review and modify the plan as needed after 3-5 years.  NTCA also presents several “overarching principles” that the FCC should keep in mind as the final rules are drafted; such as not imposing a hard cap on high cost support, allowing the RLEC portion of the fund modified growth of $300m by the sixth year, removing the high cost fund budget after 2017, allocating $300m for mobile broadband service, and targeting $2.2b for areas served by price cap carriers consistent with the Consensus Framework proposals.

In this final comment cycle, the RLEC Plan has gained considerable support from statewide telecom associations and a number of individual RLEC commenters, but not all RLECs are completely on board. With reply comments due this week, it will be interesting to see how the Consensus Framework parties react to the questions and critiques posed in the comments. Although not all RLECs advocate the same reform plan, the RLECs who have participated in this proceeding have presented a tremendous amount of evidence and commentary to illustrate how harmful the FCC's initial USF/ICC Reform NPRM proposals would be for these companies and for the rural Americans they serve. It is now up to the FCC to ensure that RLECs have reasonable opportunities for existing broadband investment and lost access revenue recovery, and ample opportunities to continue bringing the benefits of broadband to high-cost rural areas.

NECA’s chart and calculation explanation is available here, and NTCA’s ex parte filing is available here.


Nebraska PSC Advocates States' Role in USF

NPSC Argues State Commissions are “Valuable” and Should Not be Preempted

The Nebraska Public Service Commission (NPSC) submitted comments last week in response to the FCC’s Universal Service-Intercarrier Compensation Transformation Proceeding Public Notice, where it primarily focused on the price cap ILECs’ ABC Plan proposal to preempt state authority in the reformed USF/ICC system.  NPSC argued that parts of the ABC Plan should be rejected, while other parts could be modified.  NPSC refers favorably to the Federal-State Joint Board’s plan, and they do not comment specifically on the Rural Association’s RLEC Plan.

NPSC believes that the proposal to preempt state authority is inconstant with the current laws: “The legal framework of the ABC Plan which uses preemption of state rate setting authority, carrier designation and carrier of last resort obligations, contradicts the explicit federal-state partnership required by the Telecommunications Act.”  NPSC warns that since “many competitive carriers, cable providers, smaller wireless and wireline providers, state governments and consumer advocates” did not participate in the ABC Plan negotiations, the FCC should be wary about accepting the plan without modification.

NPSC urges the FCC not to disregard the Telecommunications Act or Congressional intent, and the Act “expressly reserves state jurisdiction over intrastate rates, terms and conditions.”  Furthermore, “the Commission has no power to act, let alone preempt validly enacted legislation of a sovereign state, unless and until Congress confers power upon it.”  NPSC also worries that states could abandon broadband programs, and preemption of state authority could discourage states from providing additional state-level universal service support.

A more appropriate framework, according to NPSC, would include a coordinated federal-state partnership, not unlike the current partnership between NPSC and the FCC.  NPSC explains that it has an effective partnership with the FCC, and Nebraska has already “implemented access reforms, rebalanced local rates, developed affordability benchmarks, and provides supplemental high-cost Telehealth and Lifeline support though its state universal service fund program.”  It should be noted, though, that Nebraska has been a much more active participant in state-level universal service initiatives and reforms than most states.

NPSC believes that state commissions “can be extremely valuable” to the FCC for the following responsibilities: identifying unserved and underserved areas, prioritizing areas for support, providing supplemental funding, and determining if support is being used efficiently and effectively.  Furthermore, “States have close knowledge of the extent to which broadband is being provided.  States are familiar with the obstacles impeding broadband deployment, [and]…many state commissions are familiar with the operating costs, investment levels, and revenue sources for the carriers.”  NPSC makes a valid point here, and states with a large number of RLECs and significant rural territory arguably have a big responsibility in terms of knowing specific geographic and demographic details as well as unique cost challenges for carriers as a result of local geographic and demographic particulars.  As a rural state with a large number of RLECs, NPSC probably has this point in mind when it recommends that states should determine provider eligibility for broadband support.

Although NPSC generally supports utilizing a forward-looking cost model to determine support in unserved areas, it is concerned that the ABC Plan’s CQBAT model has not been made available for analysis.  NPSC recommends that the FCC publish an open model as well as “results demonstrating support allocated to each state by census block or support area so that everyone may have the ability to quantify the level of universal service support which could be received by broadband services.”

Regarding ICC, NPSC agrees that “the Commission and states need to provide a sustainable framework which reduces the dependence upon an outdated Intercarrier compensation mechanism,” but it is skeptical of the ABC Plan’s methods to achieve this ICC reform goal.  First, NPSC believes that the ABC Plan could be modified “by providing state incentives to reform intrastate rates, increase artificially low local rates, and/or create universal service funds by requiring states to contribute a certain amount per line of recovery to offset intrastate rate reductions.”  Second, NPSC is not in favor of the proposed uniform $0.0007 rate, because “The ABC Plan proponents disregard the actual cost of providing access service and propose to establish a rate that appears to be non-compensatory for small carriers serving high-cost areas.”  NPSC calls the $0.0007 rate “an arbitrary rate for the convenience of the industry rather than one that reflects real costs.”  Third, NPSC believes the ABC Plan’s proposed Access Recovery Mechanism (ARM) is not addressed sufficiently, and the industry should provide more information about the impact on consumer rates.

Overall, NPSC provides a great deal of detailed information in response to many of the questions proposed in the FCC’s Public Notice.  NPSC clearly sees states as having an important role in the future of universal service and intercarrier compensation, contrary to the diminished state role that the ABC Plan parties are pushing.  NPSC provides some thoughtful comments about the need for state regulators for both consumers and carriers, and Nebraska is certainly a great example of a state that has worked very hard to implement its own universal service and intercarrier compensation reforms in the best interest of its constituents.  If adopted, it remains to be seen how the ABC Plan will impact those states like Nebraska which have been progressive in USF reform.  What do you think is the appropriate role of state regulators, and how can state and federal roles be balanced appropriately so that consumers in rural areas will have access to quality and affordable broadband?

NPSC’s full comments are available here.


ACA: ABC Plan Inconsistent with FCC’s Goals for USF/ICC Reform

Cable Association Argues ILEC Proposals are “Salvageable,” Provides Recommendations

Comments on the FCC’s Further Inquiry in the Universal Service-Intercarrier Compensation Transformation Proceeding were due on August 24. The American Cable Association (ACA) voiced its concerns with the price cap ILECs' ABC Plan and provided their recommendations about how the ABC Plan can be improved in order to meet the FCC’s goals of fiscally responsible and competitively neutral USF/ICC reform.  Although ACA was critical of the ABC Plan, it appeared to have a somewhat sympathetic position towards RLECs.  Cablecos were not involved in the industry negotiations that led to the ABC Plan and Consensus Framework with the RLEC Plan; therefore ACA warns the FCC that these proposals “are far from an industry consensus balancing diverse interests, a basic fact that the Commission should consider when determining whether these plans are in the public interest.”  

ACA believes that the ABC Plan is “deeply flawed: it would enable universal service funding to grow significantly and would tilt the competitive landscape in favor of the Price Cap incumbents.”  ACA argues that the ABC Plan is not competitively neutral, and it will not fix the myriad current problems with USF/ICC.  ACA states, “Rather than being ‘transformational,’ these proposals merely continue, if not exacerbate, current flaws in the universal service fund and intercarrier compensation regimes.  They also directly and materially harm ACA members, who provide telecommunications and broadband service in competition with these Price Cap carriers.”  Despite being peppered with problems, ACA is convinced that the ABC Plan’s proposals are “salvageable” with “targeted fixes.”

First of all, ACA believes that there needs to be a hard cap on the Connect America Fund (CAF) at the 2010 level.  Without a hard cap, ACA argues that the contributions burden on consumers will become unreasonable.  ACA further argues that the Consensus Framework proposal to limit the fund at $4.5b is actually “riddled with loopholes,” because it would allow rate-of-return carrier support to increase by $300m and the budget only remains in effect for 6 years.  As a result, “under the ABC and RLEC Plans, there is abundant opportunity for the fund to grow, which the Commission should not permit.”

ACA’s second recommendation is to distribute USF support in a “competitively neutral manner,” meaning reverse auctions.  ACA’s members believe that they could help extend broadband in rural areas with USF support, and they “are eager to see the Commission provide competitively neutral and efficient support for universal broadband so they can seek to serve these areas.”  ACA argues that the ABC Plan will effectively grant the price cap ILECs “a new government entitlement” to unserved areas, and the Rights of First Refusal proposal would especially give the ILECs an unfair competitive advantage.  ACA challenges the ILECs to accept reverse auctions, and “if they are in fact the most effective and efficient providers of broadband to unserved or underserved areas, the Price Cap incumbents would have nothing to fear from a competitively neutral distribution process.”

ACA’s next proposed fix for the ABC Plan’s flaws is a significantly limited access replacement mechanism (ARM), where carriers would only receive this support “where harm is demonstrable and severe.”  ACA ideally would like for there to be no ARM, but if the FCC decides to adopt a revenue recovery mechanism, then such funding should end after 3 years and the funding level should be less than 100% and reduced each year in the 3 year period.  ACA reasons that “transitional mechanisms like an ARM have a way of becoming permanent rights,” speculating that price cap carriers could ultimately end up collecting ARM support long past a reasonable timeframe.

When it comes to RLECs, ACA seemed understanding of the challenges that small rural companies will face if High Cost funding is reduced or eliminated: “These smaller providers are most reliant on current High-Cost funding to provide service to consumers and will suffer most if funding is reduced significantly and precipitously.  Further, these smaller telephone companies have generally demonstrated competence in providing service and have a deep commitment to their customers.”

ACA recommends that incumbent ETCs with less than 100,000 lines should have the option to continue receiving high cost support for 8 years, “so long as they agree to commit to provide broadband service in all their service areas,” at 4/1 Mbps initially and 16/4 Mbps within 6 years.  ACA’s recommendation to make funding for small companies somewhat contingent on broadband speeds provided is interesting, but the key here is that funding must be available, sufficient and predictable. Whether phasing out high-cost funding after 8 years will meet the sufficient and predictable principles, especially if large network investments must be made by year 6.

Overall, the ACA presented some interesting arguements, challenges to the proposed plans, and recommendations for USF reform.  There is growing opposition to the Consensus Framework by parties who were not directly involved with its development, but with $4.5b per year at stake, one can’t blame the dissenters for doing whatever they can to try to influence the FCC in this eleveth hour comment cycle.  Do you think the FCC will be accomodating to the parties who were not involved in the industry negotiations?

ACA’s full comments are available to read here.


$300m Mobility Fund is Arbitrary and Inadequate, Claims RTG

Rural Wireless Carriers Call RLEC-ILEC Consensus Framework for USF “Highly Flawed”

Comments on the FCC’s Further Inquiry in the Universal Service-Intercarrier Compensation Transformation Proceeding were due on August 24, and the rural wireless industry did not hold back any criticism of the wireline ILEC’s ABC Plan or the Consensus Framework negotiated by the Rural Associations and the ABC Plan participants. I have been looking forward to hearing the wireless response to the ABC Plan’s proposed $300m Advanced Mobility/Satellite Fund (AMF), and the Rural Telecommunications Group (RTG) comments did not disappoint. RTG slams the $300m amount for mobility funding as arbitrary, insufficient, inadequate, meager and measly; and they argue that the Consensus Framework “shows that the landline authors of the RLEC and ABC Plans are oblivious to the rapid changes taking place in the marketplace or have chosen to ignore them.”

Wireless carriers had no part in the industry negotiations that led to the Consensus Framework, which I think seems rather irresponsible given the significant role that wireless plays in the broadband market. Wireless broadband critics may argue that mobile broadband is not equal to wired broadband in terms of speed, service quality and capacity; but the market speaks clearly that wireless broadband is both a compliment and a substitute for wired broadband, depending on an individual consumer’s needs. Wireless service critiques aside, I can’t help but agree with RTG’s assertion that “it is a given that mobile wireless will play the most important role in the country’s broadband future and any order resulting from this proceeding should ensure the continued growth of wireless broadband.” The question then comes down to this: how much USF support should be dedicated specifically to wireless broadband, especially when the FCC is intent on keeping the size of the fund at or near the current level?

RTG unfortunately does not offer a specific amount of ideal funding, rather they argue that the funding should be based on actual costs, and “the size of the mobility fund would have to be substantially larger than $300 million and should reflect specific, ongoing support in order to spur investment and ensure the availability of existing wireless services and the expansion of mobile broadband networks.” I wonder, what constitutes a “substantially larger” mobility fund: $600m? $1b? More? There are a lot of costs involved in building and maintaining a wireless network (especially when spectrum acquisition is factored in), and I think we have all learned a thing or two about this from watching the recent drama with the AT&T/T-Mobile merger unfold. AT&T allegedly could build out 4G wireless to nearly the entire country for an additional $3.9b—equal to 13 x’s the proposed annual budget for the AMF.  I certainly do not expect the AMF to cover all costs to deploy wireless broadband in rural areas, but when put in perspective, $300m indeed seems like a pittance.

In addition to the size of the AMF, RTG is concerned about the disproportionate amount of money that wireless carriers pay into the USF while proposals on the table call for shifting support away from competitive ETCs. According to RTG, “Competitive ETCs would lose approximately 75% of their current support. In contrast, incumbent wireline carriers would lose only one third of their current support.” RTG is worried about the outcome of this proposal on rural wireless carriers, and “the consequence of applying such a large reduction of support to competitive ETCs will be a shrinking or elimination of many rural wireless networks.” RTG further argues for a transitional phase-out of CETC support of at least 10 years and a sufficient recovery mechanism to offset the lost funding.

RTG also raises concerns about including satellite support in the $300m AMF. They believe that funding for satellite broadband should come from the ILEC’s slice of the USF pie, because “satellite carriers provide a fixed Internet access service, and should not receive support from a fund proposed for ensuring that consumers enjoy the benefits of mobility.” RTG points out that the ABC Plan participants wish to partner with satellite providers and “rely on satellite in order to avoid having to serve the highest-cost areas.”

I have been highly critical of this particular large-carrier proposal in the past, and I agree with RTG that if wireline ILECs want to hand off the responsibility for serving especially remote areas to satellite providers, then the funding should come from the ILEC portion of USF. I think it is also important to look at the difference in market demand for mobile broadband and satellite broadband as an indicator that perhaps grouping these two services in the AMF is not reflective of actual consumer trends. I rarely hear of anyone clamoring for satellite broadband service, but there are stories every day about the dire need for improving mobile broadband. Expanding wireless broadband to 98% of America is a key component of the Obama Administration’s goals for universal broadband, and it is interestingly also a major point of debate in the AT&T/T-Mobile merger controversy.

RTG definitely covered some of the most contentious issues in this proceeding, and it will be interesting to see if, or how, the FCC responds to the wireless industry’s demands for a larger Mobility Fund. I imagine that RLECs would be concerned that a larger Mobility Fund could mean a smaller RLEC fund, but what do rural telecom providers who have a stake in both wireless and wireline think?

Read RTG’s comments here.