The FCC has four active proceedings underway right now that each make sense on their own.
IP interconnection modernization. Intercarrier compensation reform. High-cost program restructuring. USF contribution reform.
Read them separately and each one is reasonable. Each addresses a real problem that has been building for years. Each has legitimate goals and broad industry support.
Put them together and a different picture starts to emerge.
My questions are not intended to oppose modernization or to defend the current programs that need help. I just want to be sure that the end product continues to provide much needed services to rural communities.
The four proceedings are the IP Interconnection NPRM, the CAF Intercarrier Compensation reform proceeding, the High-Cost Program reform NPRM, and the long-running conversation around USF contribution reform. Individually, each addresses a problem that has been building for years. Together, they raise questions that deserve answers before any of them reach their conclusions.
Proceeding One: IP Interconnection (WC Docket No. 25-304)
The FCC's October 2025 NPRM proposes to forbear from incumbent LEC-specific interconnection obligations under Section 251(c)(2) of the Communications Act by December 31, 2028. The goal is to accelerate the transition from legacy time-division multiplexing technology to all-IP voice networks. That transition is necessary, broadly supported, and long overdue.
Nobody is arguing against modernization. The question is whether the transition has been thought through completely.
The record in this proceeding documents what happens when regulatory backstops are removed without replacement frameworks in place. Competitive carriers have reported price increases ranging from 100% to over 200,000% following prior forbearance grants. In one documented case, a 911 T1 circuit in Boise, Idaho went from $17.22 per month to $32,291.98 per month after a carrier reclassified services from regulated switched access to deregulated business data services. Actual 911 outages in California in 2025 were caused by premature TDM facility retirement. These are not theoretical risks. They are documented events in the record of this proceeding.
The record also reflects a remarkable degree of consensus across carriers as different as AT&T, T-Mobile, NTCA, INCOMPAS, and Inteliquent that mandatory default rules for IP interconnection are necessary. The question is not whether to regulate IP interconnection. It is how and in what sequence.
Recent ex parte filings present quality data for over-the-Internet interconnection showing latency and packet loss metrics that meet industry standards under normal operating conditions. That data is compelling as far as it goes. But does it address the questions rural operators are actually asking?
Rural ILECs exchanging local voice traffic through TDM tandems today are not asking whether internet-based interconnection performs well under normal conditions. They are asking what replaces their local interconnection arrangement when TDM obligations disappear. They are asking whether the public internet, which by design provides no quality-of-service guarantees, no enforceable accountability, and no protection against DDoS attacks, SIP fraud, traffic pumping, or telephony denial of service attacks, is an adequate default for carrier-grade voice services including 911.
Inteliquent's proposed National Transit Provider framework addresses these concerns directly, arguing that a default physical interconnection model separate from the public internet is necessary to preserve the reliability, security, and universality of voice services. That framework is a proposal, not a deployed solution. The NTP model or its equivalent needs to be operational before TDM obligations are removed, not after.
There is a related question the IP interconnection proceeding raises but does not fully answer in the context of the other proceedings. The December 2028 forbearance date assumes that NG911 will be sufficiently deployed by that time to handle the transition from legacy 911 routing. But NG911 deployment requires capital investment that many rural operators and public safety answering points do not currently have. E-Rate does not cover it. BEAD does not cover it. High-cost USF support is one of the few mechanisms that could. If the High-Cost proceeding reduces or eliminates that support before NG911 is funded and deployed in rural markets, who pays for the transition that the IP interconnection proceeding assumes has already happened? The sequencing dependency between these two proceedings deserves explicit attention.
The history of this industry offers a cautionary note. The rural call completion failures of 2013 to 2018, when calls to rural areas simply failed to complete at alarming rates, demonstrated what happens when rural telecommunications fall outside the regulatory safety net. It took an act of Congress to remedy that problem. The record in this proceeding reflects awareness of that history. The question is whether the cumulative effect of these four proceedings creates conditions for a repeat at a larger scale.
Proceeding Two: CAF Intercarrier Compensation Reform (WC Docket Nos. 25-311 and 25-208)
Since the FCC's 2011 Transformation Order, the industry has been moving toward bill-and-keep, a model where carriers absorb the cost of completing calls rather than charging each other for the service. The CAF-ICC proceeding now underway is accelerating that transition as voice traffic moves to IP.
The direction is right. How we get there hasn't been fully addressed.
Access charge revenues have historically been part of how rural ILECs recover the cost of building and maintaining networks in places where the economics are difficult. Not profit. Cost recovery. The 2011 order recognized this by phasing access charges out gradually rather than eliminating them overnight.
The question isn't whether to reform intercarrier compensation. It's what fills the gap in the rural operator financial model when those revenues are gone.
And here's what concerns me. The CAF-ICC proceeding and the High-Cost proceeding are both underway at the same time. Each one is addressing part of the rural financial model. But when I read both of them, I'm not sure either one is fully answering the question of what the rural operator financial model looks like when both are complete.
When two proceedings each seem to point to the other as the place where that question gets resolved, there's a real risk it gets resolved in neither.
Proceeding Three: High-Cost Program Reform (WC Docket No. 26-96)
The FCC's April 2026 NPRM titled Reforming the High-Cost Program for an All-IP Future asks fundamental questions about the future of high-cost USF support. Among the most consequential is this: what types of support are necessary in areas where the carrier already provides service or where a competitor already provides service pursuant to an enforceable commitment?
This question has a reasonable policy logic. If networks are built and competition exists, ongoing subsidies may not be necessary. The program was designed to solve a problem. If the problem is solved, why continue the program?
That logic is worth testing before it becomes policy.
First, building the network was never the finish line. Operating, maintaining, upgrading, and standing behind service obligations that require connection within 10 business days of a reasonable request is the ongoing work that high-cost support funds. A March 2025 survey of nearly 270 NTCA members found that rural broadband operators receive an average of more than $70 per month per broadband subscriber in USF support to recover invested capital, repay loans, and cover operating expenses. That support is not funding excess. It is funding the basic economics of serving rural America.
Second, the Enhanced ACAM support model already illustrates the gap between policy design and operational reality. Support is reduced upfront in areas where an unsubsidized competitor exists. The logic seems sound. If competition is present, the market can handle it. But the subsidized operator's build mandate doesn't change because a competitor showed up. The 10 business day service obligation doesn't change. The infrastructure cost doesn't change. Only the support does. That is a structural design flaw baked into the program from the start, and the High Cost NPRM appears to be considering extending that principle further.
Third, the NPRM explicitly asks how the increasing availability of low-Earth orbit satellite broadband should affect eligibility for high-cost support. This question deserves careful scrutiny.
Satellite broadband has an important role to play in connecting hard-to-reach locations. But treating it as equivalent to engineered, accountable, carrier-grade terrestrial infrastructure for support eligibility purposes rests on assumptions the operational record doesn't fully support.
Latency for satellite remains a challenge for real-time applications. Performance in dense tree canopy, severe weather, and disaster scenarios is inconsistent in ways that terrestrial fiber is not. And critically, satellite service is a commercial offering. Pricing, availability, and terms of service are decisions made by a private company without regulatory obligation to the communities it serves. A satellite provider can raise prices, reduce coverage, or exit a market without the service obligations, build mandates, or community accountability that a supported terrestrial operator carries.
If the presence of a commercially offered satellite service with no enforceable service obligations is sufficient to reduce or eliminate support for a regulated operator who does have those obligations, what assumption is being made about what happens to the communities that operator serves if the economics no longer work? And who is accountable when the satellite provider makes a commercial decision that leaves those communities without the infrastructure they depend on?
Proceeding Four: USF Contribution Reform
Underlying all three proceedings is a funding mechanism that has been under stress for decades and remains unreformed despite repeated attempts.
The USF contribution rate, assessed on interstate telecommunications revenues, has risen from approximately 5% in 2000 to 36% today. The cause is straightforward. The voice revenue base that funds USF has been shrinking for years as customers migrate to broadband and other services that contribute at lower rates or not at all. The fund hasn't necessarily grown dramatically, but the base of revenues supporting it has contracted, so the rate assessed on what remains keeps rising.
This is not a new observation. It is not a new problem. Lawmakers have introduced contribution reform legislation multiple times across multiple Congresses. Bipartisan support has existed. The structural problem has been clearly identified and broadly acknowledged across the industry, in academic literature, and in congressional testimony. And yet the contribution mechanism remains unreformed.
The consequence is a growing burden falling on a shrinking pool of contributors, increasingly the rural and lower-income consumers least able to absorb it and least responsible for driving the bandwidth demand that the networks USF supports are being asked to carry.
The modern internet economy depends on broadband infrastructure. Streaming platforms, cloud services, and AI applications generate extraordinary economic value from networks that rural operators and others have built and maintain. The entities driving the greatest bandwidth demand on those networks contribute nothing to the fund that makes rural infrastructure economically viable. That misalignment has been recognized by policymakers, documented by researchers, and debated in Congress. It remains unresolved.
The question contribution reform raises in the context of the other three proceedings is this: if IP interconnection reform reduces access charge revenues, if CAF-ICC reform eliminates intercarrier compensation, if high cost reform reduces or eliminates ongoing support, and if the contribution mechanism that funds what remains continues to erode, is the rural telecommunications financial model being reformed or simply dismantled one proceeding at a time?
The Sum of the Parts
Each of these proceedings has a legitimate goal.
IP modernization will improve voice quality, enable NG911, and reduce the cost of maintaining obsolete infrastructure. Intercarrier compensation reform will eliminate arbitrage and align compensation with actual network costs. High-cost program reform will direct limited USF resources where they are most needed. Contribution reform will eventually, when it happens, distribute the funding burden more equitably across the entities that benefit from the infrastructure USF supports.
None of these goals is wrong. None of these proceedings is, on its own merits, unreasonable.
But rural telecommunications operators are not experiencing these proceedings one at a time. They are experiencing them simultaneously, in the same operating environment, with the same teams, the same capital constraints, and the same communities depending on them.
And the timing could not be more acute. Many rural operators are currently executing two concurrent federally mandated build programs, BEAD and Enhanced ACAM, each with aggressive four-year timelines, front-loaded capital requirements, and supply chain constraints that were not anticipated when the programs were designed. The financial architecture is being reformed at exactly the moment operators are most capital-constrained and least able to absorb simultaneous revenue disruption.
The questions worth asking are these:
Is the cumulative financial impact on rural operators being modeled across all four proceedings, or is each proceeding evaluating its impact in isolation?
When IP interconnection reform reduces access charge revenues, and CAF-ICC reform eliminates intercarrier compensation, and high-cost reform questions ongoing support, and contribution reform remains unresolved, who is calculating what the rural telecommunications financial model looks like on the other side of all four?
If the NG911 transition depends on high-cost support funding that the High-Cost proceeding is questioning, and the IP interconnection proceeding assumes NG911 will be deployed by December 2028, who is responsible for identifying and closing that gap?
If the presence of an unsubsidized satellite competitor with no enforceable service obligations is sufficient to reduce support for a rural operator with a build mandate and a 10 business day service requirement, what assumption is being made about what happens to the communities that operator serves if the economics no longer work?
If contribution reform has failed to pass Congress multiple times despite broad bipartisan support, what is the realistic timeline for stabilizing the funding mechanism that all of these programs depend on?
And most fundamentally, are the communities that depend on rural telecommunications infrastructure being considered as the subjects of this policy conversation, or simply as the backdrop for it?
What You Can Do
These proceedings are open. The record is being built right now. Operator voices, community voices, and rural advocate voices matter in these proceedings and the comment windows are open.
NTCA–The Rural Broadband Association and WTA - Advocates for Rural Broadband are actively engaged in all four areas and are filing comments on behalf of rural operators. If you are a rural broadband provider, contact your association and make sure your operational experience is part of the record.
If you represent or serve rural communities, contact your congressional representatives. The USF contribution reform conversation in particular requires congressional action that FCC proceedings alone cannot deliver.
And if you are a policymaker, a researcher, or an industry participant following these proceedings, the question this article is asking deserves a serious answer before the proceedings reach their conclusions.
The parts may each be reasonable. The sum deserves a closer look.