Mike Crapo
United States Senator
239 Dirksen Senate Office Bldg.
Washington, D.C. 20510
Jim Risch
United States Senator
483 Russell Senate Office Bldg.
Washington, D.C. 20510
June 29,2012
Mike Simpson
Member of Congress
2312 Rayburn House Office Bldg.
Washington, D,C. 20515
Raul Labrador
Member of Congress
1523 Longworth House Office Bldg. .. ~
Washington, D.C. 20515 If
Julius Genachowski, Chairman
Federal Communications Commission
445 12th Street, SW,
Washington, D.C. 20554
Dear Chairman Genachowski:
The Idaho Delegation is concerned about the FCC's implementation of its Universal Service
Fund (USF)/lntercarrier Compensation (ICC) Transformation Order and its impact on rural
broadband and Idaho telecommunication services in the rural areas where our constituents
reside. We are writing to ask you to extend the implementation of the Order, including the July
1, 2012 date for implementation of the regression methodology, until the FCC can provide
greater certainty that the rules will not jeopardize the services provided by rural rate-of-return
carriers' and the consumers that rely on them for broadband and other telecommunications
services.
While we are supportive of the overall goal of increasing accountability and creating incentives
to lower costs for this sector, the Idaho delegation is concerned that the ruling does not provide
the certainty and predictability necessary for Idaho carriers to adapt in an expedited fashion.
Consistently, you have advised Congress that you have instructed staff "to get it right" on
USF/ICC reform implementation. Yet, the staff's plans for implementation through the use of a
regression methodology have created so much uncertainty among rate-of-return providers that
future investment decisions have been put on hold, chilling the broadband expansion in rural
areas that was at the heart of the National Broadband Plan submitted by the FCC to the
Congress.
Up until now, some Idaho companies may have been unable to offer true critiques of the
formula due to incompleteness of the data. Additional transparency in the ruling would support
the FCC's goals of efficiency and accountability for all companies in the telecommunications
sector. Telecommunications services, including broadband, are vitally important to the
communities of Idaho. Those services are fundamental to our schools, health facilities, public
safety-related departments (fire, police, etc.), government, and local businesses, especially
small businesses and individual entrepreneurs.
We have serious concerns that the implementation of the FCC's plans will have an immediate
economic impact further stressing the already precarious economic recovery, especially in rural
America. Before going any further, the FCC has a responsibility to demonstrate that it already
has gotten it "right". These matters are very important to us and our constituents. It is
disadvantageous to Idaho telecom companies who have not been able to certify the formula
which new reimbursement levels are based upon. By allowing policymakers and industry
experts time to study and respond to the analysis that is the basis of this reform, we can be
assured of both achieving reform and being fair to companies which have made multi-million
dollar investments.
Thank you for your attention to this matter.
Sincerely,
Mike Crapo
United States Senator
Mike Simpson
Member of Congress
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