Yesterday, WTA filed comments with the FCC in response to its Notice of Proposed Rulemaking that accompanied its Enhanced ACAM Order, which was adopted July 23.

WTA stated that no changes should be made to CAF-BLS and other legacy support mechanisms until the FCC and the industry have had sufficient time to determine the changes in broadband deployment and support needs that are likely to result from some portion of CAF-BLS recipients adopting E-ACAM.  In addition, it is likely that 100/20 Mbps or greater speeds will soon become the FCC’s defined standard for universal service, the FCC should wait to see the types of areas that will continue to require CAF-BLS support to deploy high-speed broadband before setting CAF-BLS deployment obligations and re-examining the impact of the costs of such deployment obligations on its budget control mechanism.

WTA also stated that because legacy support is based on the actual capital and operating expenditures made by RLECs, federal and state broadband grants are not included in the calculation of support and therefore will not result in duplication of broadband deployment funding. To the extent that capital grants may potentially impact the allocation of certain operating expenses, the FCC should wait to determine the nature and extent of any actual impacts before addressing the matter.