The Benton Foundation, the New America Foundation Wireless Future Project and the Office of Communication, Inc for the United Church of Christ (collectively, “Public Interest Commenters”), respectfully submit this reply to comments on the Federal Communications Commission’s Public Notice seeking input on the proposed Mobility Fund.

Public Interest Commenters support the general premise of the Mobility Fund. However, the FCC must first make a determination that the 3G mobile expansion falls under the statutory definition of “supported services”. The Public Interest Commentors believe that the proposed reverse auction process is at odds with principles of universal service and should be targeted to unserved areas with the greatest need. The Public Interest Commenters also believe that performance requirements need to favor forward-looking advanced services and public interest requirements that include data roaming, non-discrimination and interconnection. Finally the Public Interest Commentors urge the Commission to seek out examples of best practices for mobility expansion programs around the world.

The comments are available to download on the right.