Although the final rules are not yet in place, the Affordable Connectivity Program (“ACP”) is set to commence on December 31st replacing the Emergency Broadband Benefit (“EBB”) Program that is set to end on December 30th (with a 60-day transition period for existing EBB subscribers).
Last week, USAC announced the establishment of a special Affordable Connectivity Program Consumer Website.
The primary reason that we are highlighting ACP in our weekly E-rate newsletter is that the program could potentially be used to support household internet services for students, library patrons, and staff. Some schools and libraries did promote the use of EBB discounts for this purpose and may choose to do the same with ACP. Two advantages of the ACP program are that it is funded at the $14.2 billion level, which should support ongoing internet discounts for 4-5 years, and that the program has increased eligibility by raising the income ceiling from 135% of the federal poverty guidelines to 200% of the federal poverty guidelines.
More interestingly, depending upon the final FCC rules, ACP could provide even greater benefits for schools and libraries. In their initial comments on the FCC’s NPRM (DA 21-1453), the Schools, Health & Libraries Broadband (“SHLB”) Coalition and E-Rate Central proposed the following:
- The NPRM’s provision making multiple dwelling units (“MDUs”) — e.g., low-income apartment complexes and mobile home parks — eligible for bulk ACP discounts should be expanded to explicitly include homeless shelters. This would provide schools with a tool to reach students residing in these facilities. Particularly in large cities, the number of students being deprived of remote learning opportunities is significant. In New York City, for example, an estimated 28,000 students were living in homeless shelters last year.
- More broadly, by allowing discounts on bulk internet subscriptions, as are currently being funded for schools and libraries under the Emergency Connectivity Fund (“ECF”), ACP could become a transitional replacement for ECF as that funding runs out later this year or next. Providing a seamless ECF-to-ACP transition would avoid a potentially major disruption of internet service to student families and library patrons who would otherwise have to establish their own individual ACP subscriptions.
We highlight these two proposals at this point because the reply comment deadline on the ACP NPRM is tomorrow, December 28th. We strongly encourage anyone agreeing with one or both positions, to file supporting reply comments. In the simplest form, this would take only a few sentences filed as an Express Comment (see our Guide to Reading and Filing FCC Comments) in FCC docket 21-450.
As one example of a slightly more detailed statement of support, here are two paragraphs from the Wisconsin Department of Public Instruction's reply comments:
