Yesterday, WTA submitted comments to the FCC in response to its Notice of Inquiry approved in July along with the E-ACAM Order and CAF-BLS Notice of Proposed Rulemaking.

WTA stated that as broadband funding programs result in increased 100/20 Mbps broadband deployment, the FCC’s existing sufficiency, reasonable comparability and other statutory mandates can and should be supplemented by a “full service network” definition that looks to determine and distribute the future USF support necessary to achieve sustainable networks and evolving services and speeds. Scalability constitutes the critical element of such “full service networks” and the resulting future USF support. Fiber to the Home and any other scalable broadband networks in high-cost rural areas can be sustained in the long term with operating expense support and some additional capital investment, and can do so successfully and economically as broadband demands and services evolve.

In addition to sufficient support to sustain “full service networks, WTA also recommended that USF programs should include additional mechanisms for: (1) the completion of the construction and deployment of broadband networks in unserved and underserved areas; and (2) the repair and recovery of broadband networks destroyed
or severely damaged by natural disasters.