PEDRO R. PIERLUISI 
P UERTO RICO 
WASHINGTON OFFICE: 
1213 LoNGWORTH HousE O FFICE BuiLOING 
(202) 225-2615 FAx: (202) 225-2154 
SAN JUAN OFFICE: 
157 AVENIDA DE LA CONSTITUCION 
ANTIGUO EDIFICIO DE MEDICINA TROPICAL 
ALA DE E NFERMERIA 200 PISO 
SAN JuAN, P uERTO R1co 00901 
(787) 723-6333 FAJt: (787) 729-7738 
March 26, 2014 
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• asbtngton. ]JB(IC 20515-5401 
Hon. Thomas Wheeler 
Chairman 
Federal Communications Commission 
445 121h Street, SW 
Washington, DC 20554 
Re: Connect America Fund Phase I and Phase II Funding in 
WC Dockets J0,-90 and 05-337, FCC DA 13-2304 (rei. Dec. 2, 2013) 
Dear Mr. Chairman: 
COMMITIEES: 
E THICS 
J UDIC IA R Y 
N ATURAL RESOURCES 
I write in my capacity as Puerto Rico's representative in the U.S. Congress. As you 
know, Puerto Rico continues to lag far behind the rest of the United States in both 
broadband and telephone subscribership and deployment. The Federal Communications 
Commission's broadband progress reports consistently observe that, of all U.S. states and 
territories, Puerto Rico has the largest number of residents that are unserved by fixed 
broadband. In its 81h Broadband Progress Report, the FCC noted that more than half of 
Puerto Rico's residents-54 percent of the population or 1.9 million people-lack access 
to fixed broadband at speeds widely available throughout the rest of the United States. 
This is nine times the national average of 6 percent. This glaring disparity must be 
addressed. Closing this gap is critical to Puerto Rico's economic future and the ability of 
its residents to access the many educational, social, political and health-related benefits of 
broadband that the rest of the United States enjoys. 
I understand that the FCC is currently considering how to distribute $9 billion in 
broadband support over a five-year period as part of Phase II of the Connect America 
Fund (CAF). In its 2011 USF Transformation Order, the FCC spoke directly about 
Puerto Rico when it recognized the unique challenges of serving the non-contiguous 
areas. The FCC specifically directed its Wireline Competition Bureau to "reflect the 
unique circumstances and operating conditions in the non-contiguous areas of the United 
States" in any model it adopts to distribute CAF Phase II funding. The FCC further 
stated that, if the Wireline Bureau is unable to follow this directive for whatever reason, 
the Bureau must maintain existing universal service support for the price cap carriers in 
such non-contiguous or insular areas_ 
At present, price cap carriers in Puerto Rico receive $36 million annually in existing 
universal service support. However, the current distribution model proposed by the 
Bureau would award Puerto Rico only $7 million annually. The FCC is increasing the 
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total money available by 67 percent, yet also proposing to decrease the amount made 
available to Puerto Rico by 77 percent. This result makes no sense, given that the FCC 
has consistently found Puerto Rico to be the U.S. jmisdiction with the weakest level of 
fixed broadband deployment. Put simply, the proposed model does not adequately 
account for the unique operating conditions in Puerto Rico, including its low per capita 
income, the very low "take rate" for fixed broadband where the service is available (30 
percent compared to 80 percent in the model), and the relatively high cost of goods and 
certain services in the territory due to its geographical location. As per the FCC's 
directive, the Bureau must maintain the level of universal service funding Puerto Rico 
currently receives. 
Adequate broadband infrastructure is essential to educate children, attract and grow 
businesses, and build a robust economy. The CAF Phase II funding provides an 
important opportunity to substantially improve the state of broadband deployment in 
Puerto Rico. Oversight by the FCC is needed to ensure that the CAF support is 
distributed to those communities, like Puerto Rico, where it is needed most and will have 
the greatest impact. 
Sincerely, 
~~ - ~o R. Pierluisi 
Member of Congress 
cc: Hon. Mignon Clyburn, Commissioner 
Hon. Michael O'Rielly, Commissioner 
Hon. Ajit Pai, Commissioner 
Hon. Jessica Rosenworcel, Commissioner 
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