Commissioner Starks Statement on Universal Service Contribution Methodology

The FCC’s Universal Service programs are among the most significant “tools in the toolkit” possessed by the federal government to ensure that all Americans have access to voice and broadband services comparable to their fellow citizens. Considering both the success of [USF] programs and the FCC’s statutory mandate from Congress, a cap on the Universal Service program’s overall budget is not the right approach. The proposal would pit deserving beneficiaries—anchor institutions, students, patients, and Americans who lack broadband—against one another in a fight for Universal Service funds. This would be a terrible result. It would threaten connectivity for the nation’s students. It would restrict the ability of the Rural Health Care program to enable rural clinics to deliver services in areas that have no other options for patients to get health care services in their communities. It would impinge on the reach of the FCC’s Lifeline program, the only Federal program designed to address the affordability of communications services for low-income consumers. And, it would curtail the FCC’s ability to address the problem of internet inequality.

In particular, the NPRM proposes to combine the E-Rate and the Rural Health Care programs under one cap. That raises an alarm for me, and would have the effect of immediately lowering one program’s budget if the other is oversubscribed.3 I believe that kind of a budget cut runs counter to the FCC’s statutory obligations. Furthermore, the cap is arbitrary because it has no relation to the actual nature of the internet inequality problem in this country. How can we cap the amount of money needed to support broadband when we don’t even know the number and locations of the Americans that still need to be connected? As I have outlined in another statement, the FCC’s data troubles raise serious questions about whether the agency understands the problem it seeks to solve. Instead of imposing an arbitrary cap, the FCC should be improving its data collection and analysis capabilities so it can understand the true nature of the problem and measure its progress. In short, the FCC should be focused on mapping not capping.