The Media Access Project, representing a number of urban and rural public service organizations, filed comments on universal service reform and the goal of universal broadband. The groups urge the Federal Communications Commission to not consider Universal Service Fund (USF) issues solely from the perspective of carriers currently receiving USF disbursements. The interest that USF must serve, they argue, is not the parochial interest of any service provider or class of carriers, but the public interest. The fund must promote universal connectivity for all Americans, and that means prioritizing the needs of people that depend on communications services - especially those still waiting for the expansion of modern communications facilities to reach them - over the needs of any particular companies. As even "basic" telecommunications services migrate to broadband, utilizing Internet Protocol ("IP") technology and the Internet to reduce the rates paid by consumers fortunate enough to have broadband access, the Commission can no longer conceive of broadband as a luxury, add-on, afterthought, or complement to the services historically supported by universal service mechanisms.
