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The Honorable Thomas Wheeler 
Chairman 
Federal Communications Commission 
445 12th Street SW 
Washington, DC 20554 
Dear Chairman Wheeler: 
WASHINGTON, DC 20510 
May 6, 2014 
We commend the Federal Communications Commission (FCC) for its ongoing efforts to 
modernize the Universal Service Fund (USF). As reforms move forward, the FCC must adhere 
to its statutory directive to provide mechanisms for universal service of advanced 
communications that are both sufficient and predictable. As part of these ongoing efforts, we 
call on the FCC to implement a mechanism for rural rate-of-return carriers allowing them to 
receive USF support for broadband-only subscribers in high-cost areas ofthe United States. 
American households increasingly choose to meet their voice communication needs by 
abandoning their traditional landline "plain old telephone service" (POTS) options in favor of 
wireless and voice over Internet protocol services. These scenarios are increasingly common 
nationwide, in both urban and rural areas. Consumers today want the choice to fashion their own 
communications solutions to suit their needs, and that no longer necessarily includes POTS. 
The rules governing USF support in rural areas have not kept up with this dynamic, consumer­
driven market development. As you know, under current USF rules small rural carriers can 
receive high-cost support only for those consumers who subscribe to POTS. USF is supposed to 
increase broadband deployment, facilitate transition to new communications technologies, and 
bridge the digital divide, but the outdated paradigm may unintentionally have the opposite effect. 
The cycle created by the FCC' s current rules could, if not addressed in a timely manner, 
undermine consumer choice, deter broadband adoption, and inhibit technological evolution. 
We recognize that USF reform requires difficult policy balancing. We support measures that 
ensure High Cost Program distributions are targeted appropriately and invested prudently. The 
fiscal integrity and accountability ofUSF provide the credibility necessary for the FCC to fulfill 
its statutory mandate to ensure rural communications services and prices are reasonably 
comparable to those in urban areas. 
Given our shared commitment to rural consumers, we urge the FCC to propose rules, under 
authority granted by section 254 of the Communications Act, to carefully update existing USF 
mechanisms to provide sufficient and predictable support where consumers in areas served by 
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smaller rural carriers affirmatively choose to adopt only broadband services even where POTS is 
also available to them. While it is important that the FCC complete its implementation of Phase 
II of the Connect America Fund in areas served by larger carriers this year, the FCC should 
nonetheless address smaller carrier support mechanisms expeditiously, accounting for their 
unique operations. Consumers in areas served by smaller rural carriers should have the same 
fundamental choices among reasonably comparable services at reasonably comparable rates as 
consumers in other rural and urban areas. 
Sincerely, 
U.S. Senator 
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