In the 6/24/23 ICORE Blog we reported that an Order and Further Notice addressing Enhanced ACAM was circulating at the Commission. We believe that at the present time this Order represents the most important issue for rural ILEC’s being considered by the Commission as it will have significant impacts on all ILEC’s, both existing ACAM companies and those legacy carriers receiving CAF-BLS support. Although the Order has not been released a great deal of activity has occurred in recent weeks.
In response to inquiries from several members of the U.S. House of Representatives regarding the status of Enhanced ACAM, Chairwoman Rosenworcel provided an update on the Order in circulation. She reported that if adopted the Order would provide a voluntary pathway where current ACAM carriers could elect to serve all locations in their service areas at broadband speeds of 100/20 or greater in exchange for an extension of the ACAM program and an increase in support for expensive- to- serve locations. In addition the Order would provide a pathway for carriers receiving CAF-BLS support to transition to the model-based Enhanced ACAM program. Also the Enhanced ACAM plan would include requirements that will complement other funding programs including the BEAD program. Regarding legacy rate of return company support, she referenced a proposed rulemaking that would address existing support mechanisms including the Budget Control Mechanism.
As mentioned above the Order has not been publicly released, however, a review of recent ex-partes regarding this issue indicates that at least certain aspects of the proposed Enhanced ACAM Program have been shared with industry organizations that been active participants in discussions regarding Enhanced ACAM and CAF-BLS over the past several months.
The Enhanced Broadband Coalition (Coalition) has continued its lobbying efforts via the ex-parte process while the Order is circulating at the Commission and have suggested that certain aspects of the Order warrant further consideration, clarification, or modification. The Coalition believes that the deployment schedule included in the Order to provide 100/20 service to every eligible location by 2028 is too short and would discourage participation. The Coalition recommends extending the time frame to 2030. The Coalition also recommends a higher level of ongoing support for locations that are currently receiving 100/20 service. Also the Coalition suggests that ACAM I carriers should be provided with support for unfunded fiber based locations consistent with that provided to ACAM II and CAF-BLS carriers. Finally the Coalition has urged the Commission to adopt the same standards as utilized in the BEAD Program in determining the presence of qualified unsubsidized competition in the Enhanced ACAM program.
NTCA has also continued to discuss the future of the USF and the CAF-BLS program in particular. In recent ex-partes NTCA has urged the Commission to consider the need for reasonable and sufficient ongoing support for all locations that are currently served as well as the need for new deployment and to treat both as equally important to the goal of universally available and affordable broadband service. In addition NTCA also stresses the need for the Commission to carefully consider the technological capability of competitors when determining the presence of unsubsidized competitors in rural areas. Finally NTCA urged the Commission to develop deployment schedules that are comparable to those envisioned in the BEAD program.
As always we will continue to monitor this extremely important issue and will provide updates as the situation unfolds.