In the May 21, 2026 edition of the ICORE Blog we reported that at its May 20, 2026 Open Meeting, the Commission adopted a Notice of Proposed Rulemaking (NPRM) seeking comment regarding updating the FCC’s High-Cost Program. The NPRM seeks comment on updating the legacy high-cost mechanisms, namely, Connect America Broadband Loop Support (CAF BLS) and High-Cost Loop Support (HCLS) and in addition requests comment on what steps, if any, should be taken regarding the sunsetting Alternative Connect America Cost Model (A-CAM) I, Revised A-CAM I, and A-CAM II. The NPRM does not seek comment on the Enhanced A-CAM (EA-CAM) program. Three potential paths forward were identified for the legacy and A-CAM mechanisms: 1) updating these mechanisms to align with the current landscape; 2) establishing a new fixed-support mechanism; or 3) maintaining the status quo for legacy support and allowing the A-CAM programs to sunset.
The NPRM specifically requested comments regarding the types of support required where a carrier already provides service or where a competitor provides service or will provide service pursuant to an enforceable commitment. Further input was requested on the appropriate deployment obligations for USF support and the level of support that should be provided. In addition, the NPRM seeks input regarding a short-term extension of the A-CAM I program through the end of 2028 to align the terms of the three sunsetting A-CAM programs to all conclude at the end of 2028. Finally, the NPRM seeks comment on the emergence of low-Earth satellite service and on what role the USF can play in encouraging the transition to all-IP networks.
Comments have now been filed in this proceeding and below we provide a summary of selected comments filed by ICORE and other advocates for the rural ILEC industry.
ICORE’s comments point out the critical role played by the USF High-Cost programs in supporting connectivity in rural America and stresses the requirement under Section 254 of Communications Act (Act) for the FCC to establish programs designed to ensure universal access to advanced telecommunications at affordable rates. In addition, ICORE notes that the Act requires USF programs that support not only the deployment of advanced networks, but also the sustainability of these critical investments. ICORE supports the FCC’s efforts in this proceeding to address the legacy and sunsetting A-CAM programs and recommends that as an initial step, the FCC should adopt a short-term extension of the A-CAM I program through the end of 2028. Next, the Commission should develop a new, voluntary support mechanism, EA-CAM II, and extend offers to participate in this new program to all legacy rate of return and A-CAM carriers. Patterned closely after the EA-CAM program, carriers electing to participate in the EA-CAM II program must commit to provide voice and broadband services of at least 100/20 Mbps to 100% of unserved locations by the end of 2030 with the availability of a one-year extension for the final deployment milestone if needed. EA-CAM II support is proposed to be at least equal to the support levels provided by the EA-CAM program and support is provided beginning in 2028 and continuing through the end of 2038. EA-CAM II electing carriers would be subject to performance testing obligations and supply chain and cybersecurity risk management requirements consistent with the relative requirements of the EA-CAM program. The EA-CAM II program would include a “glide path” mechanism to address cases when an EA-CAM II electing carrier’s support level declines as a result of its election. Finally, ICORE urges that when considering the presence of unsubsidized competitors, the Commission must consider hold true to Section 54.5 of its Rules and also cautions the FCC when considering emerging technologies as a viable option in providing service in rural markets.
USTelecom (UST), in its comments, urges the Commission not to make permanent policy decisions until the results of unprecedented federal and private broadband investments are better understood. UST recommends that the Commission allow providers participating in A-CAM I, Revised A-CAM I, A-CAM II, and CAF BLS to voluntarily extend those programs through December 31, 2030, providing sufficient time to evaluate the outcomes of BEAD, the Capital Projects Fund, RDOF, CAF II, EA-CAM, and ongoing private investment before adopting permanent changes. UST offers that by 2030, the Commission will have a more complete factual record upon which to design a modern, efficient, and sustainable High-Cost program. UST further suggests that providers utilizing the extension upgrade existing locations where they are currently required to provide 25/3 Mbps service to at least 100/20 Mbps service by the conclusion of the extension period. Further, UST urges the Commission to recognize that fiber-based terrestrial broadband infrastructure remains the superior long-term solution and cautions that while low-Earth orbit satellite service plays an important complimentary role in the most remote locations, it should not displace investment in terrestrial fiber where such deployment is economically feasible. Finally, UST urges the Commission to expand the USF contribution base to ensure the long-term stability and sustainability of the USF.
NTCA also filed comments in this proceeding. NTCA proposes a path forward that ensures the Commission fulfills the directives of Section 254 of the Act which require that consumers in rural areas have access to communications that are “reasonably comparable” to those available in urban areas and that are subscribed to by a “substantial majority” of Americans. Specifically, NTCA proposes an extension of the A-CAM I program through the end of 2028. Prior to the end of 2028, transition all A-CAM carriers (not including EA-CAM) to the “Extended A-CAM” program that mirrors (but updates) the EA-CAM program including a 2038 sunset date. In implementing the Extended A-CAM program, NTCA urges the Commission to update the A-CAM cost model to reflect the current environment and cost levels and strongly urges the Commission to consider the standards of Section 254 when considering the presence of unsubsidized competition. Regarding low-Earth satellite service, NTCA submits that no low-Earth satellite service can meet the Section 254 standard. NTCA urges the Commission to seek comment on the levels of service that a substantial majority of Americans currently subscribe to today and submits that applying a 100/20 Mbps standard does not satisfy the requirements of Section 254. Regarding CAF BLS carriers, NTCA’s proposal provides that legacy carriers should be able to voluntarily opt in to the Extended A-CAM program. CAF BLS carriers that decline to participate in Extended A-CAM should continue under CAF BLS and HCLS until 2038 but with obligations mirroring the Extended A-CAM program.
Reply Comments in this proceeding are due September 3, 2026. We will continue to monitor this important issue and will provide updates accordingly.
