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"The Satellite Broadband Providers strongly support the Commission's efforts to reform the federal high-cost universal service program. Competitive neutrality and fiscal responsibility are key principles to guide this effort. Greater reliance on satellite broadband to achieve universal service goals is entirely consistent with the proposed principles. The Administration and the Commission have made ubiquitous broadband a national priority, and satellite broadband providers hold the key to achieving these ambitious goals on a timely and cost-effective basis.

Contrary to assumptions in the NPRM and the National Broadband Plan, capacity limitations provide no basis to exclude satellite broadband providers from direct participation in Phase I of the Connect America Fund ("CAF") or for limiting participation in Phase II. There are no technical limitations preventing the satellite broadband industry from expanding as required to meet anticipated demand. No provider—terrestrial or satellite—currently possesses infrastructure or capacity sufficient to extend broadband service to every unserved household. Indeed, an important goal of the CAF is to offer providers an incentive to expand broadband where market forces have not otherwise provided a reason to invest in infrastructure in these areas. The relevant question is not whether satellite broadband providers can solve the nation's broadband concerns with currently committed capacity, but rather whether satellite broadband providers should be permitted to compete on an equal basis with other providers for funding to add the capacity needed to serve the unserved. Unquestionably, they should be allowed to do so.

Satellite broadband providers can offer high-speed, quality broadband services, comparable to many terrestrial technologies across key relevant metrics of service. Satellite broadband supports important broadband applications, including VoIP, streaming video, and high-definition video conferencing. Thus, there is also no valid technical reason to exclude satellite broadband providers from participating fully and directly.

By allowing satellite broadband providers to participate fully in the CAF, the Commission can use market forces more efficiently and achieve its goals more cost-effectively. Restricting satellite broadband providers' participation, by contrast, would also conflict with competitive neutrality. The NPRM's alternatives to full participation are unworkable. If satellite broadband providers are excluded from full participation, they also should be excluded from contribution obligations; no class of providers that is capable of providing the supported services has ever been required to contribute yet was excluded from participation.

Because the Eligible Telecommunications Carrier ("ETC") requirements should facilitate, and not impede, achievement of national broadband goals, the Commission should exercise its statutory authority to make support available to non-common carrier broadband providers. This is consistent with precedent. There should be federal procedures to designate nationwide broadband providers as ETCs in all states, consistent with the Commission's authority under section 214(e)(6). Similarly, the public interest obligations should reflect how broadband is delivered today. States should not be permitted to impose any obligations on funding recipients that are not otherwise subject to state jurisdiction, and legacy incumbent regulations – including particularly carrier-of-last-resort obligations, should not be carried into the CAF. Broadband should be defined without reference to any particular technology, based on a threshold of at least 4 Mbps downstream and 1 Mbps upstream."