January 19, 2022 – The ACAM Broadband Coalition has proposed further modifications to its ACAM Enhancement Plan.[1]
The ACAM Coalitions’ proposed modifications “would increase buildout obligations for 90 percent of eligible locations to a minimum speed of 100/20 Mbps and the remaining 10 percent of eligible locations to a minimum speed of 25/3 Mbps.” However, the Coalition’s proposed modifications would require an increase in the yearly ACAM funding level for each year of the revised program, from $1.087 billion to $1.474 billion (assuming all ACAM companies participate).

Original ACAM Enhancement Plan

In November 2020, the ACAM Broadband Coalition 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.[2] In exchange for lengthening the funding term, the ACAM Coalition proposed new 100/25 Mbps deployment obligations beginning in either 2022 or 2025. Here are the other general details of the plan, as originally proposed by the ACAM Coalition:

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.

Modified ACAM Enhancement Plan

The ACAM Broadband Coalition’s plan is all about deploying more robust broadband infrastructure. The proposed modifications would require ACAM support recipients to deploy higher speeds to more locations:

• ACAM providers must deploy 100/20 Mbps broadband service to 90 percent of eligible locations

• ACAM providers must deploy 25/3 Mbps broadband service to 10 percent of eligible locations

With higher speeds, of course, comes more annual support. The Coalition’s proposed modifications would require an increase in the annual ACAM funding level for each year of the revised program. Two different funding methodologies would be used to determine each company’s increased annual ACAM support amount, which take into account the “vast differences among ACAM-electing companies across the country, including in geography, density, and cost structures.” Here are the two funding methodologies proposed by the Coalition:

The proposal envisions that to fund the significant additional speed obligations, each company would receive the higher amount of support resulting from one of two methodologies: 80 percent of a company’s ACAM-derived costs for eligible locations, or up to $300 monthly per eligible location.[3]

It’s important to remember that the Coalition’s ACAM Enhancement Plan would be voluntary – same as the other ACAM offers were when the FCC launched them. Accordingly, the estimated funding increase provided by the Coalition is based on all ACAM I and II companies participating in the proposed enhanced plan:

If all ACAM I and ACAM II companies were to participate in the ACAM Enhancement Plan as it is now being proposed (i.e., deployment to 90% of eligible locations at a minimum of 100/20 Mbps and 10% of eligible locations at a minimum of 25/3 Mbps), additional funding of approximately $387 million annually for the years 2022 through 2034 would be required. The current ACAM annual budget is $1.087 billion. Therefore, the new annual maximum funding, assuming adoption by all ACAM companies, is $1.474 billion.[4]

The ACAM Broadband Coalition has provided an Excel spreadsheet with details how every ACAM company would fit into the modified plan and the two funding methodologies. Here are how the ACAM Enhancement Plan’s two funding methodologies would play out, in the aggregate, with respect to funding and buildout, assuming all ACAM companies participate:

Under the proposal, a maximum of 291 ACAM companies would qualify for the up-to $300 per-month per-eligible location methodology, with buildout obligations to approximately 795,000 locations based on the model. Additionally, 136 ACAM companies would qualify for the 80 percent of total ACAM annual cost funding for eligible locations methodology, with buildout to approximately 421,000 locations based on the model.[5]

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[1] Letter from Genevieve Morelli, ACAM Broadband Coalition, to Marlene H. Dortch, FCC Secretary, RM No.11868, WC Docket No.10-90 (Jan. 19, 2022) (Ex Parte), https://www.fcc.gov/ecfs/filing/1011948411718. The modifications were first proposed in a December 17, 2021 ex parte. Letter from Genevieve Morelli, ACAM Broadband Coalition, to Marlene H. Dortch, FCC Secretary, RM No.11868, WC Docket No.10-90 (Dec. 17, 2021), https://ecfsapi.fcc.gov/file/12171799321573/12.15.21%20Ex%20Parte%20WCB.pdf. The recent ex parte includes an Excel spreadsheet showing how the plan could apply to all ACAM companies.

[2] Expanding Broadband Service Through the ACAM Program, RM No. 11868, Petition For Expedited Rulemaking (filed Oct. 30, 2020) (ACAM Petition), https://ecfsapi.fcc.gov/file/103051469192/ACAM%20Broadband%20Coalition%20Petition%20Final.pdf.

[3] Ex Parte at p. 1. The proposal also makes eligible for funding ACAM I companies’ fiber-to-the-home (FTTH) locations that were designated ineligible in the original ACAM I offer, thus treating those locations the same as ACAM II FTTH locations that have been funded since the inception of the ACAM II program. Ex Parte at pp. 1-2.

[4] Ex Parte at p. 1.

[5] Ex Parte at p. 2.