On July 29, NRECA filed comments with the FCC opposing a proposal to cap the universal service fund which supports rural broadband deployment.  The comments state that capping the program at this time would be premature due to the lack of reasonably verifiable data on residential and small business locations at which fixed broadband service is not available at the 25Mbps/3Mbps benchmark.  The FCC, the National Telecommunications Information Administration (NTIA), and Congress, along with consumers and industry stakeholders, recognize that the Commission's current methodology for determining where broadband is available is seriously flawed and requires substantial revision. 

The FCC has circulated a draft item for consideration at the Commission's August 1, 2019, Open Meeting to substantially update and improve the broadband service reporting and mapping obligations of broadband services providers. If an improved data collection program reveals the digital divide to be broader than current estimates in the future, as is generally expected, a cap based on current Form 477 data could limit funding available to the FCC to adequately address the rural broadband access gap.  Therefore, any decision to cap the universal service  program should be deferred until the revised reporting and mapping obligations outlined in the Draft Data Collection R&O take effect and the reported data are compiled, establishing a far more accurate and granular description of the unserved locations in rural areas.