Patrick Halley

With over 23 million households relying on the Affordable Connectivity Program (ACP) to financially support their connection to…well, everything…it is jarring to think the program may soon no longer exist. Losing this broadband subsidy program will force families to make hard choices and will likely lead to many losing connectivity altogether.  With the value of a network based upon its ability to connect everyone, this is not a good result for our country. Worse yet, a lack of ACP fu

States have a lot to think about as they determine how to prioritize investing federal broadband dollars. Every state that receives federal funding via the Infrastructure Investment and Job Act’s (IIJA) Broadband Equity, Access, and Deployment (BEAD) Program should have the flexibility to design and implement a plan that meets its policy prerogatives.

USTelecom met with FCC Commissioners Geoffrey Starks and Jessica Rosenworcel and their chiefs of staff on August 7 and 8, 2019 to discuss preliminary findings from the Broadband Mapping Consortium Pilot Project that USTelecom is leading along with ITTA and WISPA. USTelecom said structure counts per census block in the pilot states versus 2011 census housing structure data are incorrect for nearly 50% of census blocks, and the 2011 census housing structure data is both over-inclusive and under-inclusive.

Closing the Wi-Fi Gap by connecting all schools and libraries is a laudable goal, but how do the numbers add up over a five-year period? We are on track to free $2 billion in reserves that we are prepared to spend over the next two funding years.

Funds for the following three years would come from two significant changes. First, we would phase down support for non-broadband services, like pagers, email and, over a multi-year period, voice service. Those funds -- nearly $1.2 billion in the E-rate program -- would be repurposed to support Wi-Fi. Second, we would achieve significant cost savings in the program within the new “category two” Wi-Fi bucket (see recent announcement with GSA for example), and for the priority one (proposed to be called “category one”) services we continue to fund through improved pricing transparency and facilitating increased use of consortia-enabled bulk purchasing.

Is anything being done to address non-Wi-Fi connectivity needs in the Chairman’s proposal? Yes. In addition to closing the Wi-Fi gap, the proposal would make E-rate rules fairer so funding for internal connections is available to the vast majority of schools and libraries, rather than just a few. In addition, the proposal would streamline the program and institute reforms to ensure current funds are maximized.

What will this plan mean for rural schools and libraries? The Chairman’s modernization proposal, if adopted, would significantly expand access to Wi-Fi funding in rural areas. The proposal would close the Wi-Fi gap that currently exists in the program -- a change that would enable at least an additional 6 million children, disproportionately in rural areas, to access Wi-Fi and the 21st Century educational tools it enables during the 2015 funding year alone.

What will the effect of this plan be on urban districts? Urban schools will benefit significantly under the Chairman’s proposal.
Does the proposal make E-Rate funding more equitable? Yes. The Chairman’s proposal maintains the basic structure of the E-rate program -- discounts on the services each applicant actually needs, based on their circumstances. The difference is it would require a common sense budget for Wi-Fi spending, which would keep a few big spenders at the front of the line from using all the funding.

[Sohn is Special Counsel for FCC External Affairs, Office of the Chairman; Halley is Associate Chief, FCC Wireline Competition Bureau]