Montana's Data-Driven Affordability Plans

Benton Institute for Broadband & Society

Thursday, September 12, 2024

Digital Beat

Montana's Data-Driven Affordability Plans

In Montana, over 63,400 Broadband Serviceable Locations (BSLs) remain unserved and nearly 24,000 remain underserved. The Montana Broadband Office’s vision is to close the digital divide in support of Montana’s economic, workforce, health, and educational goals by ensuring reliable, affordable internet access for everyone in the state. Montana aims to increase broadband access and adoption by pairing broadband deployment with digital opportunity efforts. To do this, the state has developed six goals, each with its own objectives, covering broadband deployment, access, adoption, affordability, digital opportunity, and economic growth and job creation.

On affordability, Montana planned to leverage the Federal Communications Commission's Affordable Connectivity Program (ACP)—before the program ended—to ensure that cost is not a barrier to accessing broadband for all Montanans, irrespective of their income level. The objective is to ensure that more residents can access internet services, and that the internet is more affordable for them. Montana adopted two objectives related to broadband affordability:  

  1. Increase the percentage of eligible Montana households enrolled in ACP to 47 percent, and
  2. Have a high uptake of the affordable broadband offerings discussed below. 

For Montanans, affordability is a main hurdle preventing access to high-speed internet.  

According to BroadbandNow, in 2021, Montana ranked 49th among US states in access to affordable plans, as only 62 percent of households had access to wired plans, including DSL, copper, cable, or fiber, of 25 Mbps download/3 Mbps upload or higher and a standalone broadband speed plan that is $60/month or less.

According to a survey commissioned by the Montana Broadband Office, affordability was the second most commonly cited reason (after availability) for not having access to high-speed internet. Nearly 17 percent of Montanans without high-speed internet cited lack of affordability as the primary reason for not having adequate internet access. Thirty-five percent of Montana households with an income under $20,000 do not have broadband at home, versus 17 percent for those with incomes $20,000-75,000, and five percent of those earning above $75,000, indicating a strong relationship between income and internet adoption.

At least 31 percent of Montanans live in a household with an annual income below 200 percent of the federal poverty line, which could pose a barrier to adoption of broadband. Although this group was eligible for ACP enrollment, which would have subsidized the cost of their internet service, the program ended in June 2024. Counties with lower populations are more likely to have households with income below 200 percent of the federal poverty line. Counties with smaller populations were also more likely to have a lower percentage of households enrolled in ACP while the program was active. 

In the Infrastructure Investment and Jobs Act, Congress mandated that networks built with Broadband Equity, Access, and Deployment (BEAD) Program support offer at least one low-cost broadband service option for eligible subscribers. Each state (in consultation with NTIA and subgrantees) will define what ‘‘low-cost broadband service option’’ means for this purpose and the NTIA will determine who the eligible subscribers are and approve state definitions of low-cost broadband service options.

Some states—and this week we learned this week that Montana is one of them—have balked at NTIA's suggestion that low-cost broadband service options be priced at or near $30/month which, in combination with the ACP, would make broadband service affordable for any low-income household on a BEAD network.

While the Montana Broadband Office (MBO) recognizes the importance of affordable access to broadband, the MBO philosophically disagrees with the NTIA’s position that rate requirements are not rate-setting. At a House Commerce Committee oversight hearing, Misty Ann Giles, the Director and Chief Operating Officer of the Montana Department of Administration, said, "The position of NTIA is ... that this is a voluntary program, so it's not rate setting. However, I would state that is a farce." However, the MBO has worked to find a data-driven solution that meets the NTIA’s requirements, improves the potential for companies to participate in the program, and serves all Montanans.

Montana's Low-Cost Broadband Service Option for BEAD-Supported Networks

Analysis conducted by MBO indicates that the costliest BSLs may require upwards of $300,000 each to serve. Given this estimate, MBO is trying to balance affordability with the challenges inherent in deploying broadband infrastructure in order to increase participation, competition, and the sustainability of the BEAD infrastructure investment.

Montana has developed two approaches to the low-cost option: first, through application evaluation scoring criteria and, second, designing plans that are affordable for low-income households.

Affordability Scoring Criteria 

MBO first designed its BEAD application evaluation scoring rubric to incentivize providers to offer low-cost plans at the lowest possible prices. Rather than setting a single price to which all providers would be required to adhere, Montana structured affordability scoring criteria to award more points to providers that propose to offer low-cost plans at lower prices. 

For both fiber and non-fiber projects, the affordability criteria carries the second-highest weights in the scoring rubrics.  

For fiber-to-the-household (FTTH) projects, Montana is offering subgrantee applicants who commit to offering 1/1 Gbps service to customers in BEAD project areas at the same rates they offer in their existing markets in other areas of the state with the ability to earn 20 points. If applicants do not currently offer 1/1 Gbps service, they may make forward-looking commitments to offer the same rates for 1/1 Gbps plans across all locations to earn 20 points. BEAD applicants who do not make one of these commitments will earn zero points. 

For projects using other technologies, Montana is offering subgrantee applicants who commit to offering 100/20 Mbps service to customers in BEAD project areas at the same rates they offer in their existing markets in other areas of the state the ability to earn 20 points. If applicants do not currently offer 100/20 Mbps service, they may make forward-looking commitments to offer the same rates for 100/20 Mbps plans across all locations to earn 20 points. BEAD applicants who do not make one of these commitments will earn zero points. 

Low-Cost Plan Design 

MBO revised its draft low-cost plan to reflect the needs of Montana’s diverse stakeholders and ensure that high-quality internet is both affordable and that internet service providers participate in the BEAD program. Here's a look at what the service provider needs to offer, eligibility for these service offerings, and pricing.

Offering

MBO aligned its low-cost plan offering with the model low-cost plan provided by NTIA. All BEAD subgrantee applicants will be required to offer plans that provide typical download speeds of at least 100 Mbps, typical upload speeds of at least 20 Mbps, and latency measurements of no more than 100 milliseconds. Further, providers will be required to allow subscribers to apply the Affordable Connectivity Program benefit (or any successor plan should Congress create one) toward the low-cost plan. The proposed low-cost plans may not be subject to data caps, surcharges, or usage-based throttling. Also, if, after the establishment of its low-cost plan the provider offers another low-cost plan with higher speeds, the provider will be required to permit its existing low-cost subscribers to upgrade to the new low-cost plan at no additional cost. 

Eligibility

ACP-eligible households will be eligible for the low-cost plan on BEAD-supported networks in their area. 

Pricing

Montana analyzed FCC data on the average and median costs of plans offering ~100/20 Mbps speeds in Arizona, New Mexico, Utah, Wyoming, Colorado, Idaho, Montana, Nevada, California, Oregon, and Washington—and found that both average and median plan costs were approximately $70 per month. On an annual basis, MBO will repeat this analysis—reviewing the previous three years of FCC broadband rate survey data on the monthly cost to consumers of ~100/20 Mbps plans in the Western United States—to inform the appropriate not-to-exceed low-cost plan price. Re-calculating this benchmark annually, MBO believes, will help ensure that the price remains current and accounts for inflation. The not-to-exceed low-cost plan price to consumers should be inclusive of all taxes and fees, except for those that may be imposed by the government. Even though the ACP has ended, MBO will still follow the approach above to determine the price for the low-cost plan requirement (i.e., the plan price would remain $70 in the example above). 

Montana's Middle-Class Affordability Plans for BEAD Networks

MBO believes that most middle-class Montanans have access to adequate internet speeds at a cost that is not unaffordable.

In 50 out of the 56 counties in Montana, two percent of the average household income is above $100/month. The average cost of an internet plan that represents two percent of average household income by county in Montana is $121/month. And, according to MBO  analysis, ~326,400 BSLs in Montana (84.9 percent of total served locations) currently have access to an internet plan with at least 100/20 Mbps speeds at $100/month or less. Given the two percent benchmark, average income by county, and the existing provider landscape, MBO believes that most Montanans who could be reasonably considered “middle class” (based on average income) have access to adequate internet speeds at a cost that is not unaffordable. MBO anticipates that BEAD subgrantees will offer plans that are consistent with current offerings.

Additional Coverage on Montana's Broadband Priorities

See the latest Montana broadband news

More in this Series

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Kevin Taglang

Kevin Taglang
Executive Editor, Communications-related Headlines
Benton Institute
for Broadband & Society
1041 Ridge Rd, Unit 214
Wilmette, IL 60091
847-220-4531
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