In the Emergency Broadband Benefit (“EBB”) Order (FCC 21-29), the FCC expressed an expectation that the program and the beneficiary enrollment process would begin “in less than 60 days.” That 60 day mark will be April 26th. In brief, the EBB program will provide discounts of up to $50/month ($75/month in Tribal areas) on residential internet service and discounts of up to $100 on “connected devices” for low-income families (see our newsletters of March 1st and March 8th).
Eligible telecommunication carriers (“ETCs”) are automatically eligible to participate; non-ETCs must apply. To be able to offer EBB discounts, however, all internet service providers (“ISPs”), ETCs, and approved non-ETCs, must proactively elect to participate. USAC is currently processing EBB applications and elections. The FCC has just announced the first list of participating ISPs. A list of participating providers to date, sorted by state, is available online and will presumably be updated as additional providers are added. It is interesting to note that well less than half of the participating providers plan to offer device discounts.
It should be stressed that this is not an E-rate program nor will it provide discounts only for families of school-aged children or library patrons. Although EBB internet discounts are available to all low-income families, we believe that schools and libraries can and should take the lead in encouraging participation by their student families and library patrons.
For schools and libraries already providing — and paying — for home internet access their needy students and patrons there are two options.
- Encourage those families to transition from the schools’ or libraries’ bulk subscription plans to individual family EBB-discounted internet service plans for the duration of the program. To be effective, and without disrupting remote access in the interim, this is likely to require extensive coordination efforts with both the families and the ISPs.
- Alternatively, but also requiring a coordinated approach, the EBB program does permit (subject to some restrictions) discounts to be applied, on a family-by-family basis, directly to the schools’ or libraries’ bulk subscription services. Although bulk service discounts are permitted under the EBB Order (see Para. 45), there has been no formal guidance issued by either the FCC or USAC. Based on informal guidance we received, we believe that bulk subscription services can be discounted under the following conditions:
- The associated ISPs have elected to participate in EBB (see link to the list of participating providers above);
- The residential-type internet service plans covered by the bulk subscriptions are of a type offered by the ISPs as of December 1, 2020;
- The families being served meet the income eligibility requirements (one measure of which is NSLP (including CEP) eligibility); and
- The families’ “consent” to have their EBB discounts applied to their bulk subscription services (as opposed to using their EBB discounts themselves on their own home service, thus “double dipping”).
For a more complete discussion of coordinating EBB discounts on bulk service plans, see our more detailed school and library strategy memoranda.