Internet2 Collaborates with The Quilt and CENIC to Submit Comments on the Future of the Universal Service Fund

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Internet2 Files Comments on USF Reform in Collaboration with The Quilt and CENIC

On July 27, 2023, U.S. Senators Ben Ray Luján (D-N.M.) and John Thune (R-S.D.), the co-chairs of the Senate’s Universal Service Fund (USF) Working Group, announced that they were seeking public input on what Congress can and should do to improve, sustain, and grow USF and the programs it supports to ensure Americans have access to affordable and reliable telecommunications services, including broadband. The announcement opened a 30-day period for comment submissions that closed on August 25, 2023.

New Questions for a Changing Landscape

For several years, increasingly active debate has been brewing about the future of USF inside of Washington, D.C., the outcome of which will be felt far beyond the halls of Congress and the offices of the Federal Communications Commission (FCC). USF is the critical funding mechanism that powers the federal support administered by the Universal Service Administrative Company (USAC) and keeps connected the millions of Americans who rely on the Lifeline, E-Rate, High Cost, and Rural Health Care programs. While the importance of these programs and the commitment to the goals of universal service are not in doubt, the way in which they are funded is likely to change. 

In recent years, USF has been impacted by many changes. Business models in the telecommunications industry are vastly different today than they were in the 1990s when USF was implemented. The pandemic expanded the scope of who should receive universal service, and our understanding of how we connect in the 21st century is constantly evolving. How effective are the USF-funded programs at actually meeting the goals of universal service today? Is USF sustainable? Do changes need to be made to how (and from whom) USF revenues are raised by USAC to continue supporting these programs into the future?

Unique Issues at Stake for Research and Education

Internet2, in collaboration with The Quilt and the Corporation for Education Network Initiatives in California (CENIC), filed comments in response to the USF Working Group’s request to highlight the unique issues at stake for the research and education (R&E) community in this debate. In the filing, Internet2 described the unique role it and the R&E community at large have played in serving researchers, students, and community anchor institutions of all shapes and sizes with specialized support that stands apart from the mass market and common carrier services that are the concern of commercial providers. The FCC has historically recognized this distinction and exempted Internet2 and the regional and state education networks (RENs) represented by The Quilt from regulations intended for mass-market, for-profit retail services. 

Internet2’s filing focused on bringing the USF Working Group’s attention to these important historical and precedential factors as they weigh potential reforms for USF. Without a continuation of these exemptions, Internet2 and the RENs will not be able to continue to deliver the benefits of the services we provide to communities across the nation as we have for more than two decades.

We look forward to seeing the USF Working Group’s response and to playing a constructive part in the next steps in this important process of shaping the future of a robust universal service support system. The challenges facing USF will not be solved overnight, and it is important that any reforms Congress may implement carefully consider the unintentional impacts that the R&E community and others may feel.

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