Enhanced ACAM and CAF-BLS

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The issue of Enhanced ACAM and CAF-BLS continues to garner significant attention at the FCC. Not a week goes by that doesn’t include ex-parte meetings occurring at the FCC regarding this topic. As previously discussed on this site, The ACAM Broadband Coalition and NTCA are the main proponents of the need to modify the current ACAM and CAF-BLS processes seeking improved and extended USF support in exchange for commitments to provide broadband service at greater speeds. Other parties have weighed in in opposition to changing the current ACAM and CAF-BLS processes citing numerous concerns including increasing the USF Contribution factor.

The genesis of this issue was a proposal by the ACAM Broadband Coalition (Coalition) to achieve widespread deployment of broadband at speeds of 100/20. Specifically, the proposal would require ACAM carriers to deploy broadband at speeds of at least 100/20 to 90% of locations in eligible census blocks and at least 25/3 to the remaining 10%. To fund the increased deployment costs the proposal would increase ACAM support to the higher of 80% of a company’s model estimated costs or $300 per location. NTCA filed comments in support of the Coalition’s proposal for ACAM and also proposed enhancements to the CAF-BLS process. NTCA proposes increases to the per line support cap applicable to CAF-BLS from $200/mth to $300/mth and the application of an annual inflationary factor. In exchange for the increased support CAF-BLS recipients would be required to provide broadband at speeds of 100/20 to at least 90% of locations in their study areas.

As mentioned above, the Coalition and NTCA have held numerous ex-parte meetings with the FCC in recent months to discuss their proposals and to urge immediate action by the FCC. In its discussions with the FCC NTCA has proposed modifications to its original proposal to include an option for CAF-BLS carriers to commit to provide broadband service at 100/20 to 100% of eligible locations and a second option to provide 100/20 to 97% of eligible locations. Carriers electing the 100% option would be exempt from the Budget Control Mechanism (BCM) for a period of five years and would receive support at $300/location. Carriers electing the 97% option would receive enhanced support and would be exempt from the BCM for three years. Also in a recent ex-parte the NTCA urged the FCC to waive the application of the BCM for the 2023-2024 period.

This issue has also received considerable attention from members of the U.S. House of Representatives and the U.S. Senate. Late last year 32 House members and 14 members of the Senate sent letters to FCC Chairwoman Rosenworcel regarding ACAM and CAF-BLS. The letters thanked the Chairwoman for the FCC’s prompt examination (the May,2022 NPRM) of the Coalition’s ACAM Proposal and its consideration of comments and proposals related to CAF-BLS. These letters from members of Congress urged the FCC to take action as soon as possible to enhance these programs siting the importance of insuring the availability of fast, reliable, and affordable broadband service for their constituents living and working in rural high-cost areas. In her response to these letters (April,2023), the Chairwoman thanked the members of Congress for their interest and offered assurances that the Commission shares their commitment to insuring hi-speed broadband availability in rural areas of the country. She further explained that Commission staff is currently reviewing the record in the NPRM as well as holding ex-parte meetings with interested parties and offered assurances that consideration will be given to the issues and concerns presented by all stakeholders. She also stated that the Commission is considering how and whether to align the deployment obligations of CAF-BLS carriers with any revised plan adopted for ACAM carriers and noted that the FCC plans to separately consider the deployment obligations and funding levels for CAF-BLS that will apply in 2024. There was no discussion of the timing for any changes that may occur relative to the current ACAM support levels and deployment obligations.

We will continue to monitor this extremely important and will provide updates as the situation unfolds.

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