ACA Connects concerned about BEAD's 'middle class affordability' requirement

The Broadband Equity Access and Deployment (BEAD) Program's Notice of Funding Opportunity (NOFO) directs States and Territories to include in their Initial Proposals “a middle-class affordability plan to ensure that all consumers have access to affordable high-speed internet.” ACA Connects believes each State and Territory should provide a rational basis for its plan and justify its methodology.  For instance, States and Territories could produce evidence on middle-class income levels and the amount or percentage of income that existing subscribers are spending on broadband service.  A State or Territory could then confirm whether its proposed affordability plan is reasonable by examining prices, terms, and conditions for broadband service in areas that are competitively served. Another, somewhat related, approach would be for States and Territories to require subgrantees to offer the same pricing and service packages in BEAD-funded areas that they offer in competitive areas in the same State or Territory.