Recent ex parte filings made by NTCA–The Rural Broadband Association and rural broadband providers show that the FCC’s fixed budget for the high-cost portion of the universal service fund is obstructing rural broadband deployment. It’s estimated that the high-cost budget will produce a support shortfall of $173 million over the next 12 months, which has already forced rural carriers to roll back deployment plans. NTCA claims the FCC is obligated to review the budget by the end of this year, which presumably will lead the FCC to conclude that the budget is insufficient to maintain and increase deployment of rural broadband networks. NTCA’s assertion is based on language in the Tenth Circuit’s decision upholding the 2011 USF/ICC Transformation Order. Is the FCC required to make a review or is this something that is merely within the discretion of the FCC?