November 1, 2020 – The ACAM Broadband Coalition has filed a petition for expedited rulemaking with the FCC requesting that funding under the Alternative Connect America Cost Model (A-CAM) program be extended at current levels for an additional six years – 2029 through 2034.[1] In exchange for lengthening the funding term, the ACAM Coalition proposes new 100/25 Mbps deployment obligations beginning in either 2022 or 2025. Here are the basic details of what the Coalition has proposed in its petition:

Voluntary Participation – Rate-of-return carriers currently receiving revised A-CAM I and A-CAM II support would have the option to participate on a state level basis.

Additional Six Years Of Support – Participating A-CAM carriers would receive six years of additional A-CAM support at current levels – 2029 through 2034.

New 100/25 Mbps Deployment Obligation – Participating carriers would be required to deploy 100/25 Mbps broadband service to an increasing amount of locations each year, with a final milestone in 2028, 2029, or 2030, depending on the type of A-CAM carrier.

Less Low-Speed Deployments – The number of locations required to receive 25/3Mbps and 10/1 Mbps service would decrease, as some of those locations would move to the 100/25 Mbps requirement. The requirement to deploy 4/1 Mbps broadband service would be eliminated.

No Change To A-CAM Framework – The proposals would not alter the A-CAM program’s current framework or annual budget.

Rate-of-return A-CAM carriers have known there would have to be a conversation about what to do when A-CAM support runs out. But they probably didn’t think the discussion would start this early. The ACAM Broadband Coalition thinks now is as good a time as any – it is seizing the moment here.[2] The COVID-19 pandemic has placed a new emphasis on broadband Internet access service because so many are working from home, seeing their healthcare provider through telemedicine, and attending school in a wholly-online environment. Much of this will become permanent for many Americans, regardless of when the pandemic comes to an end.

To address “the desire and the need for high speed broadband,” there have been massive efforts at the federal and state levels to provide new, immediate funding for deploying new broadband networks and purchasing broadband service. Since the FCC’s A-CAM program has already proven its worth by helping carriers deploy broadband to previously underserved and unserved areas, the ACAM Broadband Coalition wants the support program added to the broadband funding discussion. Strike while the iron is hot. Hence, the expedited petition for rulemaking.

The key part of this proposal is that there is no increased funding when the 100/25 Mbps deployment obligations kick in. This may be doable for some carriers, but definitely not all. In fact, this proposal may only make sense for a handful of A-CAM carriers. We won’t know until others weigh in on it. It’s important to note that the ACAM Broadband Coalition consists of a very small number of the total A-CAM carriers. Ok, let’s take a look at the petition more closely...

ACAM Broadband Coalition Petition For Rulemaking

Generally, the ACAM Coalition would like the FCC to amend the A-CAM program, as soon as possible, to extended the distribution of support at current levels for an additional six years – 2029 through 2034. In exchange for lengthening the funding term, the ACAM Coalition proposes new 100/25 Mbps deployment obligations which begin in 2022 or 2025, depending on the type of A-CAM carrier.

Voluntary Participation – Rate-of-return carriers currently receiving revised A-CAM I and A-CAM II support would have the option to participate. Carriers could choose either to participate in the enhanced A-CAM program or continue to operate under the current plan with no changes to deployment schedule, obligations, term, or support level. Carriers would be required to choose whether to participate on a statewide basis. The Coalition proposes a 30-day election window.

Additional Six Years Of Support – Participating A-CAM carriers would receive six years of additional A-CAM support at current levels – 2029 through 2034. This funding would be added to the back end of the current term, but the 100/25 Mbps deployment requirement would have a deadline in 2028, 2029, or 2030. Specifically, the accelerated deployment of broadband at higher speeds under the Coalition’s enhanced A-CAM plan would impose significant additional costs to upgrade participating carrier’s facilities at the beginning of the plan in exchange for an additional six years of support at the back end of the plan. Alternatively, the Coalitions says the FCC could enhance the A-CAM program by offering an increased level of annual support during the current term of the plan in return for accelerated broadband deployment at higher speeds.[3]

New 100/25 Mbps Deployment Obligation – Participating carriers would be required to deploy 100/25 Mbps broadband service to a certain amount of eligible locations by 2028, 2029, or 2030, depending on the type of A-CAM carrier. The Coalition claims the proposed enhancements could result in deployment of broadband service at speeds of 100/25 Mbps or higher to over 600,000 eligible locations (605,373 to be exact).

Less Low-Speed Deployments – The number of locations required to receive 25/3Mbps and 10/1 Mbps service would decrease, as some of those locations would move to the 100/25 Mbps requirement. The requirement to deploy 4/1 Mbps broadband service would be eliminated. The amount of “reasonable request” locations would stay the same. Also, there would be no change to the current usage allowances and latency standards for A-CAM carriers.

No Change To A-CAM Framework – The proposed changes would not alter the A-CAM program’s current framework or annual budget. The annual interim milestones in effect today for A-CAM carriers would be retained, and the general oversight and compliance framework would be unchanged. The ACAM Coalition claims the proposed changes could be incorporated into the existing administrative structure with a minimum of engagement and would not require ongoing regulatory support beyond what the program requires today.

Proposed 100/25 Mbps Broadband Deployment Obligations

In one way, the ACAM Coalition is highlighting something that, in hindsight, many see as a mistake – funding low speeds. Today, speeds of 25/3 Mbps don’t cut it. The Coalition’s proposing a course correction. But, it’s as if the group is proposing a longer term of ongoing support in a way.

If the FCC adopts the ACAM Broadband Coalition’s proposal, participating carriers would be required to deploy 100/25 Mbps broadband service to a certain amount of eligible locations beginning in 2022 or 2025, and ending in 2028, 2029, or 2030, depending on the type of A-CAM carrier.

The existing broadband deployment obligations for A-CAM I carriers vary based on the carrier’s density zone. The ACAM Coalition’s proposed 100/25 Mbps deployment obligation varies in a corresponding fashion.

A-CAM I Low Density Zone Companies

• The 4/1 Mbps deployment category would be eliminated and all partially funded locations that are subject to 4/1 Mbps would move to the 10/1 Mbps deployment category.

• 75% of 10/1 Mbps locations would be moved to the 25/3 Mbps deployment category.

• Beginning in 2022, 10% of fully funded locations in the 25/3 deployment category would be obligated to be served at speeds of 100/25 Mbps or higher. This obligation to serve fully funded 25/3 Mbps category locations at 100/25 Mbps or higher would increase 10% annually. A total of 70% of fully funded locations would be required to meet the 100/25 Mbps speed standard by 2028.

A-CAM I Medium Density Zone Companies

• The 4/1 Mbps deployment category would be eliminated and all partially funded locations that are subject to 4/1 Mbps would move to the 10/1 Mbps deployment category.

• 50% of 10/1 Mbps locations would be moved to the 25/3 Mbps deployment category.

• Beginning in 2025, 10% of fully funded locations in the 25/3 deployment category would be obligated to be served at speeds of 100/25 Mbps or higher. This obligation to serve fully funded 25/3 Mbps category locations at 100/25 Mbps or higher would increase 10% annually. A total of 60% of fully funded locations would be required to meet the 100/25 Mbps speed standard by 2030.

A-CAM I High Density Zone Companies

• The 4/1 Mbps deployment category would be eliminated and all partially funded locations that are subject to 4/1 Mbps would move to the 10/1 Mbps deployment category.

• 50% of 10/1 Mbps locations would be moved to the 25/3 Mbps deployment category.

• Beginning in 2025, 10% of fully funded locations in the 25/3 deployment category would be obligated to be served at speeds of 100/25 Mbps or higher. This obligation to serve fully funded 25/3 Mbps category locations at 100/25 Mbps or higher would increase 10% annually. A total of 50% of fully funded locations would be required to meet the 100/25 Mbps speed standard by 2029.

A-CAM II Companies

• The 4/1 Mbps deployment category would be eliminated and all partially funded locations that are subject to 4/1 Mbps would move to the 25/3 Mbps deployment category.

• Beginning in 2022, 10% of fully funded locations in the 25/3 deployment category would be obligated to be served at speeds of 100/25 Mbps or higher. The obligation to serve fully funded 25/3 Mbps category locations at 100/25 Mbps or higher would increase 10% annually. A total of 80% of fully funded locations would be required to meet the 100/25 Mbps speed standard by 2029.

What About The R-O-R Carriers Receiving Non-Revised A-CAM I Support?

The ACAM Broadband Coalition’s proposal does not include the 19 A-CAM I companies that, in April 2019, declined to accept increased ACAM I support in exchange for increased deployment obligations.[4] Support for those companies ends in 2026. The ACAM Broadband Coalition’s petition recommends seeking comment on whether and how to include those carriers in an extended A-CAM program.

This Is Not An A-CAM III Petition

The ACAM Broadband Coalition states that its proposal is not an A-CAM III proposal:

The proposed enhanced plan is designed to address the immediate needs of American consumers. If adopted, it would not obviate the need for the Commission to begin a more comprehensive inquiry into the longer-term future of the ACAM program, including a potential ACAM III offer. That inquiry should include an assessment of the appropriate forward-looking speed requirements and budget as well as whether changes to the ACAM cost model are warranted and what measures should be taken to address the location accuracy problem.[5]

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[1] Expanding Broadband Service Through the ACAM Program, RM No. __, Petition For Expedited Rulemaking (filed Oct. 30, 2020) (ACAM Petition), https://ecfsapi.fcc.gov/file/103051469192/ACAM%20Broadband%20Coalition%20Petition%20Final.pdf.

[2] The ACAM Broadband Coalition is a group of rural broadband providers that receive A-CAM model-based support. Members include TDS (operates in numerous states), Great plains Communications (Nebraska), Consolidated Companies (various companies in Nebraska), Pineland Telephone (Georgia), Arvig (Minnesota), Ritter Communications (Arkansas), Farmers Mutual Cooperative Telephone Company (Iowa), Northeast Iowa Telephone Company, and others.

[3] ACAM Petition at p. 14, footnote 52.

[4] The proposal does not include the 19 ACAM I companies that declined to accept the revised ACAM I offer which increased deployment obligations in return for up to $200 per month per location in support for an additional two years. Those 19 companies are receiving up to $146.10 per month per location in support for a term that ends in 2026. The rulemaking notice requested by this Petition should seek comment on how to incorporate those companies into an enhanced ACAM plan. ACAM Petition at footnote 45.

[5] ACAM Petition at footnote 43.