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In non-competitive areas the FCC rightly should ensure wholesale access at reasonable rates.

Unfortunately, the FCCs current position argues rates frozen in 2005 for non-competitive rural areas were, in retrospect, set too high. Its solution is a draconian rate cut – as high as 20% – that essentially punishes companies that obeyed the rules the FCC created. Plus the Commission would also impose an arbitrary annual 3-5% rate cut – indefinitely – with no recognition of actual costs required to deliver service.

The FCC should not change the rules after the game is over. Instead of retroactive rate adjustments, the commission should only regulate rates in truly non-competitive areas going forward and base that regulation on real cost to provide service.

Let’s Put Rural Communities and Small Businesses on a Path to Broadband Connectivity.

If the current FCC proposal is ratified, rural communities and small businesses will be hit particularly hard. The FCC proposal hopes that these consumers will be covered by 5G Technology. However, there are no standards as to what is considered 5G – and won’t be until 2018 at the earliest – and broad deployment of 5G will not happen in densely populated areas until 2020, with rural areas left to wait.

In order for higher speed wireless to be deployed in rural areas, fiber backhaul will need to be built. In a case of regulatory bait and switch, this is the same fiber backhaul that the FCC wants to slash pricing for – making further deployment uneconomical. This creates a perfect storm for small business in the highest cost areas to be marooned using a technology with the same concerns as current wireless offerings: reliability, security, and price.

The fact is that wireless networks in rural areas will continue to struggle with line of sight, long distances, unsecure transmissions of sensitive data, and data plans that would make high speed access unaffordable for most small business, following today’s pricing structure. Reliability could be addressed with further build of the business broadband infrastructure – the exact investment put at risk by the FCC proposal.