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Re: Universal service
by Bruce Regal
It seems as if you are mixing a couple of different issues together: (1) is the universal service fund as a whole structured in the most efficient or rational way? and (2) is it appropriate to treat VOIP the same as circuit-switched voice service for purposes of USF fund contributions? It may be that the USF is administered inefficiently, or that its goals should be pursued through a tax on general revenues instead of a charge on providers or users (although in this age of politicians running screaming from anything with the word "tax" in it, query whether any insistence on funding a policy goal via a "tax" rather than some other mechanism may be tantamount as a practical matter to simply de-funding the policy goal). But the question of whether USF could be administered better, or whether it should exist at all, ought to be analyzed separately from the question of whether the difference between VOIP and circuit switched voice service somehow justifies one participating in USF and the other not. It is unclear that the public interest is served if consumers deciding whether to obtain voice services via VOIP or via traditional circuit switched systems are incentivized to choose one or the other based on the fact that for one they would pay a USF charge and the other not. Presumably if VOIP is a better or more efficient choice than circuit-switched for voice service it should stand as such on its merits and not based on a cost advantage that would merely be a function of differential USF treatment. Maybe USF charges are bad policy generally (or maybe not), but if they are applicable to one form of voice service, why not both?
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