220317 Reply Comments Universal Service Fund FCC


March 23, 2022


Dear Ms. Dortch:

The U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to submit reply comments on the Federal Communications Commission’s (“the Commission”) Notice of Inquiry on the above referenced proceeding (“Notice”) to study the future of Universal Service Fund (“USF”) and to identify policy solutions for Congress and the Commission to take to close the digital divide for all Americans (1).

As many commenters have correctly noted, the USF is in dire financial straits and requires fundamental reform to stabilize USF programs (2). This Notice represents an important first step to stabilize the USF. The Chamber urges the Commission, and policymakers, to thoughtfully consider the range of proposed policy solutions and fully understand the impacts of all proposals on statutory USF objectives, digital innovation, and American global competitiveness.

(1) Report on the Future of the Universal Service Fund, Notice of Inquiry, FCC-21-127 (rel. Dec. 15, 2021) (Notice).

(2) See AT&T Comments at 1; Public Knowledge comments at 18-19; INCOMPAS comments at 14.

The Notice requests comment on the Commission’s definition of universal service goals as well as how to measure progress towards the goals (3). The Chamber supports the Commission maintaining the Infrastructure Investment and Jobs Act’s (“IIJA”) definition of universal service goals for broadband and does not believe that the definition should be expanded to include other objectives. Consequently, we urge the Commission to reject the proposal offered by some commentators to include “competition” as a goal (4). The Commission has several existing mechanisms to support competition in the broadband market to address any concerns pertaining to competition (5). Moreover, including competition as an objective for universal service would muddle the overall goals of the Commission’s universal service programs and distract the Commission from the actual goal of universal service, which is ensuring that all Americans have access to high-speed internet.

The Notice also requests comment on the evolution of goals and how to measure progress for universal service goals (6). Connectivity technologies and innovations stemming from increased connectivity are rapidly evolving so the Chamber agrees with the Commission that the universal service goals may change over time. However, the Chamber emphasizes that the Commission, in executing any of its broadband deployment programs, should ensure that Americans living in unserved areas are prioritized first to fully close the digital divide as well as preserve a technology neutral approach that recognizes the wide range of broadband technologies in the market. Moreover, we encourage the Commission to conduct additional proceedings as needed to evaluate current and future broadband and connectivity requirements in full collaboration with impacted stakeholders.

Finally, the Chamber notes that in this proceeding, the Commission should refrain from providing recommendations on new benchmarks for broadband considering Section 60505 of the IIJA directs the Government Accountability Office to study broadband internet access service speeds by November 2022 (7).

(3) Notice, FCC-21-127 at 2-3, para 4.

(4) See Benton Institute comments at 25; INCOMPAS comments at 5.

(5) Jon Sallet, A Brief History of Competition Policies and Networks, FED. COMMC’N COMM’N (Sep. 5, 2014), https://www.fcc.gov/news-events/blog/2014/09/05/brief-history-competition-policies-and-networks.

(6) Notice, FCC-21-127 at 8, para 18.

(7) Infrastructure Investment and Jobs Act, Pub. L. No. 117-58, 135 Stat. 429 (2021) (IIJA).

Thank you for the opportunity to participate in this proceeding and working to identify solutions to stabilize the USF. If you have any follow up questions, I may be reached at 202-463-5973 or by e-mail at mfurlow@uschamber.com.


Matt Furlow

Policy Director

Chamber Technology Engagement Center

U.S. Chamber of Commerce

220317 Reply Comments Universal Service Fund FCC