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The Honorable Tom Wheeler 
Federal Communications Commission 
445 12th Street, SW 
Washington, DC 20554 
Dear Chairman Wheeler: 
WASHINGTON, DC 20510 
November 1, 2013 
We commend the Federal Communications Commission (FCC) for recently making changes to 
its 2011 Universal Service Fund (USF) reform order to begin the immediate deployment of broadband to 
rural areas served by price cap companies. Additionally, we appreciate the FCC's decision to 
temporarily relieve the impacts of Quantile Regression Analysis (QRA) on small rate-of-return carriers. 
However, we remain concerned the reform order is limiting the ability of small rate-of-return carriers to 
provide rural consumers with the broadband service they need to compete in today's global economy. 
The 2011 USF reform order's lack of predictability is resulting in declining private sector 
investment in hard-to-reach rural areas, which threatens the long-standing requirements that consumers 
in rural and high cost areas should have access to telecommunications and information services that are 
reasonably comparable to those services provided in urban areas. We urge the Commission to take 
immediate steps to re-establish predictability, sufficiency and transparency in the USF program so that 
these small businesses can resume critical investments in rural broadband. At the same time, we believe 
this process should neither upset nor slow implementation of Phase II of the Connect America Fund for 
consumers in areas served by larger carriers. 
The Universal Service Fund provides small rate-of-return regulated telecom carriers with support 
to keep consumer rates affordable in high cost areas. These small companies use a limited number of 
public and private loan programs to make long-term capital investments to expand the reach and 
effectiveness of broadband in hard-to-serve rural areas. Both potential borrowers and lenders have 
indicated hesitation in moving forward with loans for broadband infrastructure improvements due to the 
uncertainties created by the reform order. 
One ofthe main causes of uncertainty is the reform order's Quantile Regression Analysis (QRA) 
approach to providing high-cost support for rural companies. A recent analysis by former FCC Chief 
Economist Simon Wilkie underscores this uncertainty, noting that the QRA caps and redistributes USF 
support in arbitrary and unpredictable ways, fails to provide incentives for broadband deployment, and 
generates regulatory uncertainty that is discouraging investment. While we appreciate the FCC's recent 
steps to temporarily relieve the impacts of the QRA approach, more must be done to resolve the 
lingering uncertainty it creates. 
1115
The benetits to health, education and economic development from robust broadband 
infrastructure will be delayed or denied for many rural Americans unless the Commission finds a way to 
re-establish predictability and transparency in the USF program through re-examination of the QRA 
approach and other common-sense steps that enable rural carriers to respond to consumer demand for 
broadband. We appreciate your attention to this matter, and we look forward to your response. 
Sincerely, 
ester 
ited States Senator 
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Tim Johnson 
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Robert P. Casey, Jr. 
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Deb Fischer 
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Chuck Grassley 
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Mike Crapo 
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Jerry Moran 
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