20180131City of Ammon Position Paper.pdf

2135 South Ammon Road, Ammon, Idaho 83406
RECEIVED
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lli.1.i'iC PUBLICil !, iTi:S COMMISSI0N
Wednesday, January 31, 2018
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
RE: Case #GNR-T-17-05, Order # 33951 Position Paper
Dear IPUC Commissioners and Staff,
The unsustainable state of the ldaho Universal Service Fund (IUSF) substantiates the need to
develop a new modelthat addresses the changes affecting the current model.
Unexpected technology improvements are affecting the IUSF by enabling service competition
in a traditionally monopolistic model. These competing services often make use of the same
underlying infrastructure as the regulated service, providing adequate equal functionality to the
consumer for a lesser cost. lncreasing the contributors to the IUSF pool to include these new
technology providers like VolP and wireless will not halt service evolution or the established
trend of repurposing infrastructure formerly dedicated to an analog service to data.
Additionally, introducing new contributors to the poolwill likely create increased complexity as
pressure to provide parity between fund 'contributors' and fund 'recipients' evolves. All of the
foregoing demonstrates the need to unbundle services from infrastructure, as the 'essential
service' provided today is the infrastructure, not any specific service. This is especially true
with the rapid evolution of services and functionality happening across our communications
infrastructure today.
The fact that disruptive technologies such as VolP and mobile wireless services have been
built on top of infrastructure constructed and supported with public contributions by means of
the universal seruice fund must be recognized. Unbundling the services from the infrastructure
has occurred technically and economically, but has not been reflected in universal service
support. Therefore, a new model is required. The new model should include infrastructure
cost recovery, while at the same time unbundling services from the supported infrastructure.
This would have the effect of opening up the services, not the infrastructure, to competition for
the benefit of the infrastructure owner and the public contributors supporting the infrastructure.
These realities suggest that the State recognize Broadband as an essential service, and
require utility treatment for the high cost wireline infrastructure. Failure to treat the
infrastructure as the regulated utility and continuing to tie cost recovery to either the service or
operations will tie universal support benefits to that regulated seryice's market. This will have
the already-observed effect of encouraging disruption as technology becomes motivated to
Phone: [phone] . fax: (208)61L4C[9 . web: www.ci.ammon.id.us
2135 South Ammon Road, Ammon, Idaho 83406
deliver the same functionality outside of the regulated service, and will entice an artificial
consumer shift to avoid the fees necessary to support wireline ubiquity. Any such modelwill
prove unsustainable in the face of technology advancement.
Finally, we believe that the State should include a broad and diverse set of stakeholders in the
development of this new model, which also needs to include logical migration paths for
infrastructure owners to systematically transition from the current model to this new model as
desired.
The City of Ammon has a vested interest in seeing that smart solutions are implemented to
resolve the issues facing the IUSF. We would appreciate an opportunity to participate in the
development of these solutions.
Sincerely,
Sean Coletti
Mayor, City of Ammon
Bruce Patterson
Technology Director, City of Ammon
Phoner ( 208)6 1 2-4000 . f axr (208)6 1 L4009 . webr www.ci.ammon.id.us