Other Issues: In conjunction with its decision to refocus the universal service system on broadband services, the Order also modifies obligations of existing ETCs. First, it establishes a revised, technology-neutral definition of the voice services eligible for support, mainly in order to ensure that VoIP services count as supported voice services. Second, it requires ETCs currently receiving support under the High Cost program to offer broadband service in “their supported area” consistent with basic performance requirements, and to report on their performance measures. The basic performance requirements are 4 Mbps downstream / 1 Mbps upstream, latency suitable for VoIP, and reasonable usage limitations (presumptively no less than 10 GB per month).

It does not appear that competitive ETCs whose support will be phased down under the new system will be subject, during the phase-down, to the broadband performance requirements, unless those ETCs win bids for providing broadband through the CAF or Mobility Fund.

Voice Telephony Services: The Order establishes a new definition of “voice telephony services” with four components: (1) voice grade access to the public switched network or its functional equivalent; (2) minutes of use for local service provided at no additional charge to end users; (3) toll limitation to qualifying low income customers; and (4) access to 911 and enhanced 911 services to the extent the local government in an ETC’s service area has implemented 911 or enhanced 911 systems. The FCC did not preempt additional state requirements for voice service (e.g., carrier-of-last resort obligations), but encouraged states to review their existing rules and policies in light of the changes made by the Order. The revised definition is intended to be technologically neutral and to allow entities to provide voice service using either the PSTN or IP networks. ETCs shall be required to offer voice telephony as a standalone service throughout their service area, at rates that are reasonably comparable to urban rates.