Any reforms to a national program to subsidize telecommunications networks in high-cost areas must ensure that rural residents “are not relegated to second-tier broadband service,” NRECA told the Federal Communications Commission on Aug. 4.
NRECA filed comments with the FCC as the commission looks at modernizing the Universal Service Fund’s High-Cost Program and Congress weighs potential updates to the fund. The High-Cost fund is the largest of the USF’s four programs, with an annual budget of $4.5 billion.
With over 200 electric cooperatives involved in broadband deployment, NRECA stressed that any USF updates must ensure that all Americans, including those in rural areas, have access to next-generation services.
NRECA has advocated before agencies, Congress and courts to protect the fund, which provides vital support for rural broadband deployment and other communications services.
“Rural America must have access to reliable and robust broadband service in order to compete economically, create job growth, retain young people, enable distance education and telemedicine, support critical services, and participate in an AI-driven economy,” NRECA Regulatory Affairs Directors Erin Dobozy and Brian O’Hara said.
“These fundamental criteria require access to a network that is able to provide services comparable to those available in non-rural areas, at comparable rates—and that is scalable to meet ever-increasing downstream and upstream demand.”
NRECA outlined five main points with regard to USF reform:
- Any modernization effort for the high-cost program must ensure that rural areas are served by “reliable, robust, scalable” broadband service.
- NRECA backs the creation of a new program to support operating costs for networks in low-density, high-cost areas.
- USF funding recipients should provide symmetrical service of at least 100 megabits per second.
- The existence of terrestrial symmetrical service of at least 100 Mbps should preclude support for competitive service, and the FCC should not be “technology neutral” in determining eligibility for USF support.
- Nonterrestrial services like low-earth orbit satellite are an insufficient substitute for robust terrestrial infrastructure, with fiber optic networks representing “the most future proof technology, with unparalleled scalability to meet future demand.”
The FCC rulemaking comes as lawmakers in Congress consider ways to modernize the USF, including how the program is funded. NRECA submitted comments in September 2025 to a congressional working group on USF reform and remains engaged with the group as it works toward potential legislation.
“NRECA is urging the commission to make smart reforms to this critical program,” Dobozy said.
“USF plays a vital role in expanding rural connectivity, and partnership with rural broadband leaders and stakeholders is critical as the program undergoes much-needed reform,” she added. “NRECA looks forward to continuing to work closely with the commission on changes that support lasting, reliable connectivity solutions for rural communities.”
Molly Christian is a staff writer for NRECA.