With a Notice of Inquiry (NOI) issued April 8, 2009, the Federal Communications Commission (FCC) laid out plans to finally reform universal service high-cost support for non-rural carriers by April 16, 2010.1 Comments in response to the NOI are due by May 8, 2009; reply comments are due June 8, 2009.

The FCC’s non-rural high-cost support mechanism has twice been remanded by federal courts, most recently in 2005, when the Tenth Circuit invalidated the revised rules adopted in 2003 and ordered the FCC to craft a revision. The universal service high-cost program is intended to ensure that consumers in all parts of the country have access to and pay rates for telecommunications services that are reasonably comparable to the services provided and rates paid by consumers in low-cost urban areas. Non-rural high-cost support is made available to carriers which do not meet the specific definition of a rural carrier,2 but which nevertheless provide telecommunications services to high-cost areas.

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