Service sector

Infrastructure Investment and Jobs Act, Broadband, Universal Service Fund, Federal Communications Commission,

Dear Ms. Dortch:

The U.S. Chamber of Commerce Center for Technology Engagement (“C_TEC”) appreciates the opportunity to comment on the Federal Communications Commission’s (“Commission”) notice of investigation into the above proceeding (” Opinion”) to study the future of the Universal Service Fund (“USF”) and identify policy solutions that Congress and the Commission must adopt to close the digital divide for all Americans.

America’s communications networks play a vital role in connecting Americans and revolutionizing the way people work, learn, seek medical care, and communicate with friends and family. The private sector plays a leading role in building and maintaining these communications networks, investing $1.7 trillion in broadband deployment since 1996. Industrial sectors ranging from healthcare to financial services depend on the networks of communication to operate effectively and connect with consumers. Unfortunately, more than 14 million Americans lack access to high-speed broadband, which prevents them from participating in the Internet economy and using essential Internet services.

The Infrastructure Investment and Jobs Act (“IIJA”) directed the Commission to assess the impact of the IIJA on USF and, more broadly, to report to Congress on options policies to achieve universal broadband service. The Chamber supports the goal of achieving universal service to ensure that all Americans are connected and benefit from the Internet economy. Universal service for broadband should be achieved through incentives for the private sector to deploy broadband where there is a need for improved services, including in unserved areas. Moreover, the FSU should not be the political mechanism to achieve this goal. Instead, the congressional appropriations process should provide government support for broadband rollout. The Chamber believes that there are several reasons why the Commission and policy makers should pursue this approach.

First, the COVID-19 pandemic has demonstrated the essential nature of broadband access to fully participate in the American economy and society, including e-learning, telehealth, and remote working. Additionally, businesses across all industries benefit from high-speed access to support e-commerce applications and operational efficiencies like the Internet of Things (“IoT”). Broadband access is also important for the use of online productivity tools and, of course, for companies whose business model relies on consumer access to broadband. Moreover, the economic implications are substantial; The IoT is expected to have a total economic impact of $14.4 trillion by 2025. The digital economy already provides $2 trillion in annual value to the US economy. Therefore, it would not be an understatement to say that the benefits of Internet access are widespread and affect almost every individual and every business. Considering that the allocation process aims to meet broad societal goals, such as broadband, it is the only viable solution that recognizes the realities of today’s communications market.

Second, as the Commission and many commentators have noted, USF is facing a shrinking tax base, leading to higher taxes on telecommunications service providers and resulting in higher bills. phone for consumers. One of the main causes of this trend is the rise of non-USF Internet services resulting from technological innovations in the market. Going forward, the Chamber expects the private sector to continue to make rapid advances in communications technology. Adopting a general credit allocation process for broadband programs will help to “future-proof” these programs to accommodate new technologies for delivering communications services to consumers and businesses. The appropriations process allows Congress to better adapt broadband programs on a regular basis to reflect market changes and new communication technologies. It will also avoid the challenges currently facing USF.

Third, in response to the COVID-19 pandemic, and in addition to the IIJA, Congress has established and strengthened numerous broadband-related programs through legislation such as the Aid Act, Coronavirus Relief and Economic Security (“CARES”), the Consolidated Appropriations Act, and the US bailout. These broadband programs have all been funded by general appropriations. This indicates that Congress is able and willing to fund broadband programs through the appropriations process. Additionally, even before the COVID-19 pandemic, Congress established and funded a number of broadband programs across the federal government. Examples include the United States Department of Agriculture’s Broadband ReConnect program and the Commission’s Rural Digital Opportunity Fund.

Thank you for giving me the opportunity to participate in this process. The Chamber looks forward to working with the Commission as this process progresses. If you need additional information, I can be reached at (202) 463-5973 or by email at


Matt Furlow

Policy Director

Chamber Technology Engagement Center

United States Chamber of Commerce