Reply comments sent by EDUCAUSE to the Federal Communications Commission on August 6, 2012 in the matter of the Universal Service Contribution Methodology (WC Docket No. 06-122), A National Broadband Plan for Our Future. This document follows earlier comments submitted by EDUCAUSE in this matter and is a response to some of the other commenters regarding the proposed reform of the Universal Service Fund (USF) contribution methodology. The document reinforces the EDUCAUSE views that 1) basing USF contributions on telephone numbers, unrelated to actual usage of the network, would impose an inordinate burden on low-volume users, would not be sustainable, and would violate the principle of fairness, and 2) private networks that do not serve the general public, such as those operated by colleges and universities, should not be subject to USF fees. It also points out that most of the initial comments in this proceeding support these views.
The reply comments are filed on the FCC site at http://apps.fcc.gov/ecfs/document/view?id=7021996870.