Industry Split on Proposed Enhanced A-CAM Program

Industry disagreed whether the FCC should consider an Alternative Connect America Cost Model (ACAM) Broadband Coalition proposal to extend the program through increased deployment obligations in exchange for additional funding (see 2205190023). Some sought to expand eligibility to carriers receiving other high-cost USF support, in comments posted Tuesday in docket 10-90. Others said the FCC should defer new high-cost support until programs funded through the Infrastructure Investment and Jobs Act are completed.

The program "has been doing a commendable job since its inception” and the proposed revisions would "vastly improve the speeds and accelerate the deployment of broadband where it is needed most,” said the ACAM Broadband Coalition. The coalition backed expanding eligibility for rate-of-return carriers receiving legacy support and adopting an “annual inflation adjustment.”

The group proposed increasing performance obligations for recipients to a minimum speed of 100/20 Mbps to at least 90% of eligible locations in exchange for “80% of the company’s model-based costs or up to $300/month per eligible location.” It would “dramatically increase the speeds and accelerate the deployment of broadband to over 1.13 million unserved and underserved locations in rural communities,” it said.

"Each carrier should have the option of evaluating whether its circumstances permit extension of 100/20 Mbps service to the entirety of its eligible locations," said NTCA. The FCC should "decline to mirror A-CAM service level commitment timelines with [broadband, equity, access, and deployment] program buildout schedules," the group said, noting an enhanced A-CAM and updated CAF-BLS "would likely deliver far better broadband sooner to far more rural Americans." NTCA also backed "deferring application of the budget control for several years so that providers can ramp investments to fulfill these materially increased obligations on a study area-wide basis."

Let Connect America Fund broadband loop support and high-cost loop support recipients be eligible for the proposed enhanced program, said WTA, saying the FCC should align current recipients' service obligations and funding levels with the enhanced model. WTA asked the FCC to “follow through quickly on its stated plan to consider the deployment obligations and funding levels of providers receiving CAF-BLS support that will apply beginning in 2024."

Consumers in areas currently served by A-CAM recipients "may suffer through years of lower performance service" if the program "is not enhanced and extended," said ACA Connects: The proposed plan is "most likely to deliver higher-performance broadband service to consumers sooner and with greater certainty than other potential efforts."

The reasons for establishing the A-CAM program's original tribal broadband factor are "still valid" and "must continue" in any new support mechanism, said the National Tribal Telecommunications Association: "[M]ore must be done to ensure any broadband deployment enabled by the enhanced A-CAM program results in a narrowing of the tribal digital divide." New support should also "recognize the need for ongoing support for the operations and maintenance of deployed broadband networks," NTTA said.

Recipients of any enhanced A-CAM support should be required to "annually report the total amount of A-CAM support received to the states from which they are also receiving state funding," said the California Public Utilities Commission: It would “prevent the carrier from receiving more government funds than necessary to meet their intrastate revenue requirement.” The PUC backed requiring recipients to either participate in the affordable connectivity program or establish a low-cost service offering. CTIA supported streamlining certain reporting requirements: There's "no reason to require high-cost recipients to provide substantially the same information in a different format through another portal."

The FCC should "adopt the coalition’s proposal quickly and begin disbursing funding before the end of this year," said a coalition of state and regional telecom associations. Implementing the proposed model before year's end would ensure NTIA and states are "aware of which locations in A-CAM carrier study areas will be subject to an enforceable commitment to deploy broadband at a minimum speed of 100/20 Mbps" and avoid duplicative funding, the coalition said.

NCTA opposed the proposal, saying the FCC shouldn't consider any additional high-cost support "until the funds from new federal broadband programs have been awarded and the effects of such funding can be evaluated." Such support would be "premature because Congress has already committed significant resources to deploy broadband in unserved or underserved areas," NCTA said. Incompas agreed and said the IIJA programs funded are "likely to deliver much greater network capacity than what the A-CAM proposal will deliver."

Congress "tacitly acknowledged that existing programs such as A-CAM are insufficient on their own to meet modern demands for high-speed" by establishing the BEAD program, said Windstream. The "sheer cost per location requested in the proposal should be an indication that the coalition’s suggested approach has its limits," it said: The FCC should expand the USF contribution base and "stabilize the contribution factor" instead of expanding funding obligations "until the effects of current unprecedented broadband funding opportunities ... are known."