Additional Problems

• Funding and the Models

  • $125M falls far short of requirements

    • HAI w/Defaults $3 Billion
    • BCPM w/Defaults $9 Billion
    • Either w/FCC Common $4.5 Billion

  • Output very sensitive to inputs and platform (see above)
  • FCCs Synthesis” model still not finalized
  • If model is delayed, so is funding

• “Non-Rural vs. Rural Issues

  • “Non-rural” must be funded at least 115%
  • Forward-looking vs. Embedded

• Averaging is Fundamentally Incompatible With Competition

  • False entry signals in over-priced areas
  • False protection for high-cost rural customers