'llnitcd~ta tCB ~CI1a tc WASHINGTON , DC 20510 March 9. :W12 The Ho norable Julius Gc nachows ki. Chairman Federal Commun icat ions Comm ission 44 5 121h Street. SW Washington. DC 20554 Dear Chairman Gcnachowski : wc arc writing in support of the pe ti I ion of All band Cornruunica tions CoopcrutiVI: for \Vnivcr 0 l Part 54.301 and the Frame work to Limit Reim bursable Capita l and Operating Costs. Allbund Co mmunic at ions Cooperative was the first telephone cooperat ive in the state o f Mic higan and is organized as a non-p ro fit co rpora tion . Th e Cooperative began service in 2005 and currently provides 163 lines in the Robbs Cre ek Exchange. a ll urea previo usly witho ut any telephone service. includ ing 9- 1- 1. The Exchange curren tly comprises I77 sqnarc miles 0 f rura l. heavil y forested land wi th an average pop ulation den si ty o f ap proximate ly one household or business per mile . It is also o ne o fthe mo st eco nomica lly distressed areas in Michigan comprising counties wi rh the seco nd. third. and fo urth highe st unem ployment rates in the state . Overa ll. the area has a 17.5 percent unem ploymen t rate . In 2005. Allband recei ved a U.S . Department o r Agriculture (US DA ) Rura l Development loan o r over 58 million to construct their fiber 10 the horne netwo rk in the Robbs Creek Exchange. Th en in 20 10. Allband recei ved two USDA Rural Development Broadb and Infrastructure Proje ct grants to taling almost $ 10 millio n to ex pand its fi ber optic net work to serv e 1.828 househo lds and 115 businesses in the co mm unities o r Mikado . Curran. Spra tt. Flanders. Lachine and Long Rapids. That brought the tota l fcdcrul investment in Allband to almost S 18 mi llion do llars since 200 5. lf Allbnnds peti tion is denied. it will have a pro fo und ly nega tive e ffect 011 the coo perati ve. Allbuud will sec a reduction in its Fede ral Universal Service Fund revenues 01'$5.569 per-line ann ually. an approx ima te ly 55 percent reduc tion in tota l regul ated revenue. Further. this \\ ill result in Allband de faultin g on its USDA Rural Developm ent loan and the el im ination of a cri tica l service for the residents o r the Robbs Cree k Exchange. The USDA loan was ma de based o n the ex isting Universal Service Fund cr iteria which provided Allband with the cost recovery suppor t req uired to maintain affordab le custom er rate levels while deploying the facilities nec essary for service. T his rccuvcrv mechanism was coun ted by USD,\ ill calculating Allbands abil ity to repay the loun . 0395 We ask that yOll give Allband's petition full and fair consideration. We also ask that yOll give it a prompt review and that you inform our offices ora til1leline for its disposition. This response can be directed to the Traverse City offices at the addresses below. Sincerely, Carl Levin 107 Cass Street, Suite E Traverse City, MI49684 Debbie Stabenow 3335 S. Airport Road West. Suite 6B Traverse City. MI 49684 CC: Mr. James J. Turner, State Director United States Department 01' Agriculture, Rural Dcvelopmcnt