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WC 10-90, 13-184 & CC 02-6 et al: USTelecom Reply Comments in Response to the Public Notice from the Wireline Competition Bureau

Reply Comments

The United States Telecom Association (USTelecom) submits these reply comments in response to the Public Notice (Notice) issued by the Wireline Competition Bureau (Bureau) of the Federal Communications Commission (Commission). Multiple parties filed comments on the two petitions (collectively, “the Petitions”) identified in the Notice: one filed by Microsoft Corporation, Mid-Atlantic Broadband Communities Corporation and others (Microsoft Petition), and the other filed by Boulder Valley School District (BVSD) and the Samuelson- Glushko Technology Law & Policy Clinic (BVSD Petition) (the filing parties are referred to collectively as, “the Petitioners”).

The Petitions seek to extend E-Rate subsidized broadband networks and services into residential areas for the express goal of helping to close the “homework gap.” As noted by others in this proceeding, while closing the homework gap is a laudable goal, grant of the Petitions represents an inappropriate and inefficient use of the universal service fund (USF) that would jeopardize the integrity of the E-Rate program and the sustainability of the E-Rate fund. The Petitions should either be denied, or only considered by the full Commission in a formal rulemaking proceeding.