The Effects of the USF Reform Order on Broadband Deployment

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1 The Effects of the USF Reform Order on Broadband Deployment Presented by: Bob Gnapp Director Member Training and Network Analysis (303)

2 Disclaimer Presentation is based on NECA s current understanding of FCC rules and tariff provisions. Ongoing FCC discussions and pending proceedings may result in future changes. 2

3 USF before the latest reforms High Cost Loop Support - Supports the recovery of costs for those ILECs with considerably high loop costs Exceeding 115% of national average Interstate Common Line Support - established in 2002 to replace implicit support contained within the Carrier Common Line rate Connect America Fund Intercarrier Compensation Established in 2011 to allow for the recovery of some lost ICC revenue as a result of phasing down some ICC rates 3

4 Support choices Model support Support based on Alternative Connect America Fund Model (A-CAM) Monthly support amounts are fixed for 10 years Non-model support Support based on reformed legacy support mechanisms HCLS Connect America Fund Broadband Loop Support Voice (formerly ICLS) Subject to true-up Data Only Subject to true-up Alaska Plan Frozen 2011 legacy support for 10 years 4

5 Support calculation Model support equals the model predicted cost per location less a funding benchmark, subject to a cap per location ($52.50) and overall budget ($ per location) Non-model support = HCLS plus CAF BLS (Voice plus Broadband Only) All subject to budget controls CAF Broadband Only support equals the difference between a carrier s consumer broadband only loop RRQ and its consumer broadband only loop revenues 5

6 Buildout obligations Model support At least 10/1 Mbps to all fully funded locations at end of 10 years based on established milestones At least 25/3 Mbps to a percentage of fully funded locations at end of 10 years based on density At least 4/1 Mbps to a percentage of capped locations at end of 10 years based on density 6

7 Buildout obligations Non-model support Non-model support 5 year ( ) buildout 10/1 Mbps locations = Target CAF BLS support / average cost per location Target CAF BLS support = 5 year FCC projected CAF BLS amount X CAF BLS factor 7

8 Buildout obligations Non-model support Example Assume: 5 years projected CAF BLS = $5,000,000 Assume: 10/1 locations = 30% CAF BLS Factor = 25% Target CAF BLS = $5,000,000 X 25% Targeted CAF BLS = $1,250,000 Assume: Cost per location = $1,000 Build out = $1,250,000/1,000 = 1,250 locations 8

9 Support limits Non model support OPEX limit based on double log formula incorporating 1.5 standard deviations Affected carrier s reduction will be phased in CAPEX limit based on new Capital Investment Allowance mechanism CAPEX allowance based on each carrier s depreciated loop plant (adjusted for inflation) CAPEX allowance adjusted based on the level of the carrier s current broadband deployment Applies to prospective investments only 9

10 Support limits Non model support Other non-model support limits Corporate operation expense limit $250 per line/month limit Rate floor limits may affect local rates Budget Control Mechanism limits Competitive overlay - Once implemented will also reduce support payments where applicable 10

11 Rate-of-Return reduction Model support The model calculates support amounts immediately at 9.75% Non model support - Rate of return transitions from 11.25% to 9.75% beginning July 1, 2016 Applies to HCLS and CAF BLS Current July 1, 2016 July 1, 2017 July 1, 2018 July 1, 2019 July 1, 2020 Applies also to interstate special access rates for both model and non-model takers effective July 1, 2016 July 1, % 11.00% 10.75% 10.50% 10.25% 10.00% 9.75% 11

12 Budget control mechanism Non-model support only - Reductions (if necessary) based on line and percentage reductions for both HCLS and CAF BLS ILECs permitted to recover budget shortfall via broadband only rates Potential to place large upward pressure on rates, particularly where broadband only demand is limited 12

13 Election results Number of RoR Study Areas by Election Type Projected 2017 RoR Support by Election Type ACAM % AK Plan 15 1% Legacy % ACAM $556M 28% AK Plan $54M 3% Legacy $1,363M* 69% * Before BCM 13

14 New Broadband-Only rate structure As of January 2017 costs for broadband-only transmission will be recover via: A new Consumer Only Broadband Only Loop charge Loop costs moved to Common Line A modified A/SDSL Data-Only charge The costs for 2 nd mile transport remain in Special Access High cost support Model or Non-Model support CBOL rate = (Monthly CBOL RRQ CAF BLS BO support)/ forecasted CBOL Loops 14

15 New Broadband-Only rate structure Voice-Data Broadband using DSL and special access DSL SWC DSL and ASCP SWC Internet Backbone Provider N I D ASCP ISP DSL Voice Data ISP Interconnection 15

16 New Broadband-Only rate structure Data-Only Broadband using CBOL, DSL and special access DSL SWC DSL and ASCP SWC Internet Backbone Provider N I D ASCP ISP CBOL and DSL Data-Only ISP Interconnection 16

17 New Broadband-Only rate structure CBOL options The FCC has delinked the CBOL from other DSL rates. ILECs may: Tariff CBOL (common carrier regulations) Detariff CBOL (common carrier regulations) Detariff CBOL (non-common carrier regulations) Non-model companies might loose support ILEC offers Broadband Internet Access Service No separate transmission components Many questions remain on this option 17

18 New Broadband-Only rate structure CBOL tariffing options Companies may tariff a CBOL rate that is less than the full CBOL rate including below the $42 benchmark Lowering your rate will lower federal USF contribution obligation to USAC USF contribution are calculated based on the rate actually billed to the customer For NECA and USF Support reporting purposes, companies are required to impute the revenues using the full calculated CBOL rate based on the Part rule 18

19 Effects of underfunding Model support Location with 25/3 Obligation Location with 10/1 Obligation Location with 4/1 Obligation Reasonable Request Standard Total Locations Fully Funded ACAM Final ACAM Offer 362, ,257 26,552 64, , , ,519 51, , ,973 Difference -35,444-35,738 24,659 46,523 0 Percent Change -11% -16% 48% 42% 0% 19

20 Effects of underfunding Non-model support Large shortfalls in support will need to be recovered through rates that far exceed the national average and the urban benchmarks 20

21 Questions? 21

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