Today, WTA, NECA, NTCA and ERTA responded to the FCC’s request for comment on two proposals intended to spur broadband investment in rural America: allowing RLECs to receive support for standalone broadband and to seek Connect America Fund (CAF) Phase II model support.  In the filing, the rural associations submitted specific amendments to the FCC’s rules that would implement their proposal for standalone broadband support.  In regards to RLECs participating in the CAF, the associations concluded that “the lack of definition in the Connect America Cost Model, especially when paired with some of the policy choices embedded within the CAF Phase II program more broadly, makes it difficult at this point to identify whether this specific model-based path represents a viable option for individual RLECs to deliver universal service to the consumers they serve.”