In comments filed in response to the FCC’s 2018 Biennial Review of Telecommunications Regulations, the American Cable Association has urged the FCC to modify its universal service fund contributions rules because they are implemented in such a manner that is unfair to smaller communications providers. Among other things, ACA wants the FCC to revise downward the VoIP contributions safe harbor so that it more reasonably approximates the actual percentage of VoIP revenues derived from interstate and international services.