Commentary 2021 is well underway and the new leadership at the FCC is taking shape. While we don’t yet know who will fill the Chair on a permanent basis, the FCC under Acting Chairwoman Rosenworcel is proceeding without delay. On the Universal Service front, the principal activity surprisingly has as much to do with non-USF programs as with the USF itself. Yes, the $9 billion per year fund with its four primary programs continues to serve broadband needs in the country. And it is true that the FCC has extended many COVID-19 waivers and is considering additional waivers such as a proposal to allow E-rate funds to be used for off-campus purposes. But the big news of 2021 is turning out to be the