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The Honorable Mignon Clyburn 
Acting Chairwoman 
Federal Communications Commission 
445 12th Street, SW 
Washington, DC 20554 
Dear Chairwoman Clyburn: 
October 4, 2013 
We commend the Commission for the hard work it has undertaken and the milestones it 
has accomplished in carrying out its Universal Service Fund (USF) reform orders. We also 
commend the Commission for recently making a number of changes to its 2011 order to begin 
the immediate deployment of broadband to unserved consumers in rural areas served by price 
cap companies. However, we are concerned that the reform order is undermining the ability of 
small rate-of-return regulated telecom carriers, serving more than 40% of the nation's land mass, 
to provide rural consumers with the broadband service they need to compete in today's global 
economy. Instead, the reform order is resulting in declining private sector investment and, thus, 
failing to achieve the purposes required by Congress in the Communications Act for "access to 
communications services reasonably comparable in price and quality to those available in urban 
areas." 
One of the main causes of uncertainty and resultant declining investment is the reform 
order's "Quantile Regression Analysis" (QRA) approach to providing high-cost support for rural 
companies. In May 2013, several ofus asked the Government Accountability Office to conduct 
a study on the effects the QRA on rural carrier investments, as well as broadband speeds, 
adoption of services, and access to broadband. A recent analysis by former FCC Chief 
Economist Simon Wilkie underscores the uncertainty rural carriers have faced, noting that the 
QRA caps and then redistributes USF support in arbitrary and unpredictable ways; fails to 
provide incentives for broadband deployment; and actually generates the regulatory uncertainty 
that is discouraging investment. While the FCC has taken some steps recently to relieve 
temporarily the impacts of the QRA approach, more must be done to resolve the lingering 
uncertainty it creates. And many of these carriers have sought waivers from the QRA for good 
faith investments, but their applications have languished at the Commission for long periods. 
We urge the Commission to take immediate steps to re-establish predictability, sufficiency and 
transparency in the USF program so that these small businesses can resume critical investments 
in rural broadband. For example, the QRA should be reexamined and the 
Commission should consider the effects on small carriers when waiver requests are left 
unanswered for over a year. Nonetheless, the steps the Commission takes to remedy these issues 
should not slow progress on implementation of Phase II of the Connect America Fund for 
consumers in areas served by larger carriers. 
The benefits to health, education and economic development from robust broadband 
infrastructure will be postponed or denied for many rural Americans unless the Commission 
finds a way to re-establish predictability, sufficiency and transparency in the USF program 
through re-examination of the QRA approach and other common-sense steps that enable rural 
carriers to respond to consumer demand for broadband. If not addressed and recalibrated soon, 
consistent with the core statutory mandate from Congress to the Commission, the reform order 
will have profound and long-lasting ill effects on rural communities. 
Thank you for your service on the Commission and for considering our views. We look 
forward to your response. 
Bruce Braley 
Member of Congress 
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Tim Murphy 
Member of Congress 
Member of Congress 
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Member of Congress 
Brett Guthrie 
Member of Congress 
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Member of Congress 
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Ed Wrutfield 
Member of Congress 
Co Gardner 
Member of Congress 
Billy Long 
Member of Congress 
Member of Congress 
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