New Street Research: Update on Bulk Billing

Federal Communications Commission Chairwoman Jessica Rosenworcel has asked her fellow commissioner to consider either a ban or constraint on bulk billing. We predicted the Chair’s proposal would hit significant resistance. The record reveals that the resistance is strong, coming not just from the expected ISPs but also from groups traditionally at odds with ISPs, groups generally aligned with low-income consumers, and those concerned about low-income adoption. Considering the opposition:

• We don’t see the proposal moving forward anytime soon.
• We think that if a vote goes forward the two Democrats are not likely to vote against the Chair.
• Still, If the FCC moves forward with its proposal, it will likely adopt a more modest approach than what the FCC Chair suggested in her initial press release.
• A ban is highly unlikely, but an opt-out requirement is still possible.
• The November 2024 election also plays a significant role. If the Notice of Proposed Rulemaking isn't approved beforehand, its fate will hinge on the results, as will any enforcement.