The FCC’s 7/24/23 Enhanced ACAM (EA-CAM) Order (Order) provided a new offer of USF support to carriers receiving ACAM and Legacy Rate of Return Support. In exchange for defined support amounts, electing carriers are required to provide 100/20 broadband service to a specific number of locations identified in the EA-CAM offer by 2028. The Order established interim deployment milestones of 50% by 12/31/26, 75% by 12/31/27, and 100% by 12/31/28 with an additional 12 months to come into compliance with the 100% requirement. In addition, the Order requires that no later than 12/31/25 adjustments may be made to the deployment obligations and support amounts to identify locations that were already served by an unsubsidized competitor at the time the EA-CAM offers were made or were subject to an enforceable commitment to provide 100/20 service at the time the offers were made. Per the Order, if a location adjustment is a decrease of less than 5% (de minimis) then no adjustment to the original EA-CAM offer will be required. In cases where decreases to a carrier’s required locations are between 5% and 15%, adjustments to the original EA-CAM offer will be required. Finally, in cases where the decrease in locations is greater than 15%, the carrier’s deployment obligations will be entirely recalculated.
In the ensuing months, Petitions for Reconsideration (PFR) have been filed and many ex partes by industry groups have occurred urging the Commission to consider various points of view regarding several issues related to the rapidly approaching adjustments required by 12/31/25. Points of discussion include the following issues:
* The ACAM Broadband Coalition urged the use of obligated locations instead of required locations as defined in the EA-CAM offers. The FCC agreed to this suggested change in June 2025. (see ICORE Blog dated 6/5/25)
* Industry groups have urged the Commission to extend the final deployment deadline to 12/31/2030 to be aligned with the BEAD Program’s deployment schedule. To date the Commission has not agreed to this request. (see ICORE Blog dated 4/11/25)
* Interested Parties urged the Commission to calculate support adjustments in a manner that would mitigate potential volatility on providers’ support amounts.
* Various Parties have expressed concerns over the identification of unsubsidized competitors and the use of the National Broadband Map for this purpose.
* Interested Parties have urged the Commission to rerun the ACAM cost model to develop updated average per location costs that reflect the network required to serve the final location counts.
As mentioned above, the 12/31/25 deadline for the Commission to calculate potential adjustments to the original EA-CAM offers is rapidly approaching. It is our hope that the Commission will favorably consider the issues discussed above and will make their determinations regarding required adjustments soon in order to allow affected carriers to review the findings and react accordingly. ICORE is prepared to assist our EA-CAM clients in this regard and will continue to provide updates on this important issue in the interim.
