WTA Opposes USF Cap in Comments to FCC

On July 29, WTA filed comments with the FCC in response to its NPRM proposing a cap on the Universal Service Fund.

WTA argued that the proposed cap will not only undermine the predictability and sufficiency promised in the 2018 Rate-of-Return High-Cost Support Order, but also possesses a number of substantial legal and policy flaws that preclude its adoption. Specifically, the FCC lacks the authority to impose an overall cap and actually rejected a cap as recently as the 2018 Order. In addition, WTA argued that the four programs cannot be adequately compared for the purposes of evaluating relative effectiveness as suggested in the NPRM due to their different goals and structures, and they already have budget restrictions built into them making an overall cap is superfluous.