Dear Chainnan Genachowski:
The Honorabl.e Julius Gen,achowski
Chainnan
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554
DISTRICT OFFICES
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iIl1 ESTATE CANE
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CRUZ BAY, ST. JOHN
u.S. VIRGIN ISLANDS 00831
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PLEASE ReSPOND To:
WASHINGTON OFFICE
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December 21, 2011
MEMBER, -SUBCOMMITTEE ON
OVERSIGHT AND INVESTIGATIONS
MEMBER, SUBCOMMITTEE ON
COMMUNICATIONS 4.ND TECI-lNOLo.G.Y
COMMITTEE ON
ENERGY AND COMMERCE
DONNA M, CHRISTENSEN
DELEGATE, VIRGIN ISLANDS
FIRST, VICE PRESIDENT,.
CONGRESsiONAL BLACK"CAUCu'S
MEMBER, CONGREMIONAL CAUCUS'FOR
WOMEf":I;:S,lssyES
ASSISTANT MINORITY WHIP
I am writing to express concern over the economically-damaging impact that the FCC's
Universal Service Fund ("USF")-Intercarrier Compensation Refonn Order ("Order") and the
new rules adopted by the FCC in the Order will have on existing and future telecommunications
services and infrastructure in the U.S. Virgin Islands. Providers in the U.S. Virgin Islands face
telecommunications challenges that carriers serving the rural U.S. mainland do not face. It is
important that the Commission take these unique challenges into account when drafting new
rules. Unfortunately, neither the USF Order, nor the new rules adopted by the FCC sufficiently
address the unique telecommunications challenges that carriers in the U.S, Virgin Islands face.
As you are aware from our earlier correspondence, the U.S. Virgin Islands does not enjoy the
same level of telecommunications services available on the mainland. Broadband service is
being deployed slowly due primarily to the costs associated with the terrain and the insular
nature of the territory. In addition, there is a single provider of home telephone service, two-way
cable is still in the future, and there remains little or no competition in video services.
USF support is a critically important part of bringing telecommunications infrastructure in line
with 21 st Century expectations and demands, especially in insular areas. As a result, I advocated
for special treatment for insular areas and was joined in that effort by the other Congressional
Delegates to the U.S. Territories, as well as the U.S. Department of the Interior's Office of
Insular Affairs. Unfortunately, it appears that the only special treatment afforded insular areas in
the Order is a fast-track process for insular area-serving carriers that elect to undertake the
burdensome and uncertain path of requesting a waiver of the new rules.
In making its decision that insular areas did not deserve treatment akin to Tribal Areas and the
Hawaiian Home Lands, the Commission provided no rationale nor a citation to justify its
conclusion. The combined failure by the Commission to include insular areas with other
historically protected entities and merely afford insular area-serving carriers an accelerated
review of a petition for waiver process is insufficient to address the telecommunications needs of
insular areas.
PRINTED ON RECYCLED PAPER
Letter to Chairman Genachowski
12/21/11
Pg. 2
Despite an overwhelming need for additional high-cost support, the FCC's rules will result in an
immediate and on-going reduction of millions of dollars of USF support for consumers in the
U.S. Virgin Islands for years to come. Unfortunately, the Commission has elected to adopt
reforms that may inhibit the provision of broadband service in the U.S. Virgin Islands.
It is my hope that the Commission will reconsider their approach with respect to USF reform as
it affects the U.S. Virgin Islands and other insular areas. I encourage the Commission to take
remedial action to ensure that, at least for USF purposes, insular areas are treated on par with
Tribal Lands and the Hawaiian Homelands by the Commission, even ifthat result has to now be
achieved through the grant of future waiver requests from insular area-serving carriers.
I respectfully request the opportunity to discuss this matter with you at your earliest convenience.
~~./7/ <
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DaM. Christensen
ember of Congress
Cc: Chairman Greg Walden
Ranking Member Anna G. Eshoo
Commissioner Michael J. Copps
Commissioner Robert M. McDowell
Commissioner Mignon Clyburn
Sharon Gillett, Chief, Wireline Competition Bureau
Rick Kaplan, Chief, Wireless Telecommunications Bureau