The American Cable Association said in comments filed at the Federal Communications Commission that voice providers with 100,000 access lines or fewer must not lose access to Universal Service Fund (USF) funding under any interpretation of ACA’s own proposal that would eliminate subsidies to telephone carriers that face competition in their markets from entities that are not dependent on government support.

"ACA agrees with those who believe that USF reform is needed to bring program costs under control and finance the new mission of providing support to operators that would provide broadband to consumers in unserved and underserved areas," ACA President and CEO Matt Polka said in a statement. "However, ACA does not believe that cutting off small voice carriers that receive the lion’s share of their revenue from USF mechanisms cold turkey would, as some have suggested, serve the public interest."

ACA’s comprehensive USF reform proposal would cap the size of the $4.4 billion fund and withdraw support from large voice providers and all wireless providers that face competition from entities that have demonstrated they can compete against incumbents without USF support. Realized savings would provide the FCC with billions of dollars on a recurring basis to support broadband deployment projects for the first time in the agency’s 76-year history.

ACA’s comments came in response to an FCC public notice seeking comment on USF reform proposals volunteered by the National Cable & Telecommunications Association. Unlike ACA, NCTA would employ a competitive-carrier test to all incumbent phone carriers receiving USF support, regardless of the number of subscriber access lines that have been placed into service by any particular carrier.

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