We will hear argument this morning in case 24-354 Federal Communications Commission versus Consumers Research and the Consolidated Case.

General Harris?

Mr. Chief Justice, I may please the Court.

Section 254 is no delegation running riot.

Congress first told the FCC what policy to follow, to give all Americans access to basic telecommunication services at reasonable charges, i.e. Universal Service. So FCC can promote phone service, but not faxes. Second, Congress said how to do it. By charging carriers a fee, then reimbursing carriers that serve universal service programs.

Third, Congress dictated how much to charge.

Only what's sufficient to achieve universal service.

So, no more than needed to support specified programs.

Fourth, Congress prescribed how to allocate fees.

They must be equitable and non-discriminatory,

so FCC can't charge by carrier size or revenue.

Fifth, Congress detailed what underserved areas FCC must target, low-income, rural, insular,

and high-cost areas, plus schools, libraries, and health care providers. On top of that,

Congress enacted

254 against the backdrop of a half-century history where FCC advanced universal service

through rate subsidies. That delegation leaves key policy choices to Congress, and is

definite and precise enough for courts to tell if FCC followed Congress's limits when filling in details.

Indeed, this scheme resembles the pipeline safety fee in Skinner, which this court deemed an easy

case. Like in Skinner, respondents do not ask this court to revisit precedents approving far

broader delegations. Respondents instead press a special non-delegation rule for taxes. The very

rule skin are rejected. Respondent's private non-delegation challenge likewise fails. They

challenged FCC's reliance on USAC to calculate carrier's proposed contribution fee. But FCC itself

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