USTelecom Letter to Commerce Secretary Adresses BEAD Low-Cost Service Requirement

USTelecom and more than 30 other broadband industry groups sent a letter to Secretary of Commerce Gina Raimondo covering several ideas for how the National Telecommunications and Information Administration (NTIA) can remedy the issues posed by the rates being approved for the low-cost service option requirement in the Broadband Equity, Access, and Deployment (BEAD)Pprogram.

• Require each State to revise the low-cost service option rate proposed or approved in its Initial Proposal so that the rate is more reasonably tied to providers’ realistic costs, such as by using the FCC’s Urban Rate Survey benchmark. 
• Clarify that for purposes of the Part 200 federal interest period, the rate approved in the State’s Initial Proposal for the low-cost service option requirement lasts for two years. Thereafter for the remainder of the federal interest period, States must adjust the low-cost service option rate threshold annually based on either (1) a rate consistent with the FCC’s Urban Rate Survey benchmark, or (2) a rate consistent with the provider’s most competitive promotional offering for that tier of service in their entire footprint (not to exceed the Urban Rate Survey benchmark).   
• Adjust the BEAD low-cost service option eligibility criteria to mirror that of the Lifeline program, so that providers can confirm consumers’ eligibility for the low-cost service option using the existing National Lifeline Eligibility Verifier. 
• Issue a blanket waiver of the rate approved in each State’s Initial Proposal for the low-cost service option requirement, so long as it does not exceed the Urban Rate Survey benchmark. Alternate approaches, such as case-by-case waivers, will be unwieldly and impractical and disincentivize participation.
• Issue guidance that the low-cost service option rate is the effective rate after applying any applicable federal or State subsidies.