Today, NTCA, WTA and NECA submitted additional information to the FCC in support of the associations’ Data Connection Support proposal (formerly the Data-Only Broadband Plan). The information contains:
(1) an updated sheet showing the troubling disparity in what consumers pay today in the absence of USF support for broadband data connections and what they might pay if ICLS-like DCS support were available for such connections (even as such ICLS-like DCS support would need to be reduced to fit within the Commission’s USF budget targets);
(2) a description of the simple DCS mechanism that provides a targeted update to existing rules;
(3) a rule summary and updated proposed draft rules, revised to reflect continuing conversations with Commission staff over the past nearly two years;
(4) a chart and reference to existing cost accounting and allocation rules to demonstrate how double recovery of costs would be precluded under the DCS proposal; and
(5) a “priceout” comparing, on a study area-specific basis, support available under the DCS proposal over time as consumers migrate to broadband connections (both with and without budget controls described in the proposed draft rules) with support that would be available under legacy USF mechanisms and/or A-CAM Scenario 1.1.