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May 28, 2015
DAN BENISHEK M.D.
FIRST DISTRICT, MICHIGAN
514 CANNON HOUSE OFFICE BUILDING
WASHINGTON, DC 20515-2201
(202) 225-4735
WWW.BENISHEK.HouSE,GOV
Chairman Tom Wheeler
Federal Communications Commission
445 12th Street, SW
Washington, DC20554
I'm writing today in support of the further waiver application of Allband Communications
"Cooperative, filed December 31,2014. Allband is the first Michigan non-profit telephone-
cooperative, and the only entity to serve the Robbs Creek exchange, a heavily forested rural area
comprising parts of Alcona, Alpena, Montmorency and Oscoda counties in northeast Lower
Michigan.
The Federal Communications Commission's (FCC's)2011 U5F/ICC Transformation Order capped at
$250 per month ($3,000 per year) the amount of total per-line Universal Service Fund (USF)support
a carrier like Allband may receive, The current effect of this cap would be to reduce Allband's USF
support by $352 per-line per month ($4,221 per-line per year). While Allband was granted a waiver
in 2012, that waiver is set to expire on July 1, 2015.
The loss of USFrevenues of this magnitude means that Allband would be unable to pay many of its
essential operating costs. In addition, Allband would be unable to repay the scheduled interest and
principal on its Rural Utilities Service Loan, obtained to fund the construction of its network.
Before Allband commenced service in 2006, no wireline carrier had ever served the area, and
cellular service was and remains unavailable or unreliable throughout most of the In-square mile
region. Allband continues to be the only entity willing and able to provide voice and data
telecommunications services (including essential public safety services) within the Robbs Creek area
during the foreseeable future.
While I certainly understand and agree with the goals of USFreform, I request you consider an
exception to the $250 cap as being warranted in this case. It is my hope that Allband and the FCC
will be able to come to an agreement that allows the residents of the Robbs Creek exchange to
retain basic telecommunications services. Thank you for your attention to this issue. Please
contact Jordan Vivian in my office at (202) 225-4735 with any questions.
Sincerely,
Dan Benishek
Member of Congress