Last week marked the close of the initial comment period of the FCC’s Further Notice of Proposed Rulemaking (“FNPRM”) on the Affordable Connectivity Program (“ACP”). From the perspective of schools and libraries, already being funded through the E-rate and ECF programs, ACP developments may be important in two respects, namely:
- Prospectively, as the ECF program draws to a close, during or shortly after the 2022-2023 school year, ACP discounts may be a way to provide affordable home internet services for low-income families with students and patrons currently covered by reimbursed ECF services.
- Properly structured, ACP discounts for low-income housing buildings and homeless shelters would permit bulk subscription internet services for student and patron families that have otherwise been difficult to serve under the ECF program.
In this respect, the most expansive set of comments proposing Pilot Programs for better administrating ACP discounts for low-income housing complexes and homeless shelters were filed jointly by E-Rate Central and Westhab (Westhab is the largest non-profit provider of affordable housing and support services in Westchester County, NY). Other important comments on these points were filed by California Emerging Technology Fund (“CETF”), Microsoft Corporation, and Stewards of Affordable Housing for the Future (“SAHF”).
CETF asked the FCC to “not adopt overly strict measures that make enrolling and engaging in ACP difficult for school districts, schools, and parents.” CETF also argued that that the ACP rules should “[e]xplicitly include homeless centers as eligible for support under multiple dwelling unit (“MDU”) provisions. The MDU definition and eligibility should include multi-family serving organizations and local government entities that purchase in bulk.”
Focusing specifically on MDUs administered under Federal Public Housing Assistance (“FPHA”) programs, which was a key part of the FNPRM, several responders urged ACP building management control. The New York Public Service Commission, for example, stated that:
Moreover, the FCC should examine means to simplify ACP enrollment for FPHA beneficiaries and other beneficiaries of federal or state programs that guarantee ACP eligibility. Such beneficiaries should have a streamlined means to enrollment that can be managed and advanced at the local or state level, in part, utilizing the increased access to relevant tools as outlined above. For example, a state housing provider could be able to administer ACP enrollment locally, requesting simple documentation from FPHA beneficiaries, then enrolling such individuals collectively or on a simplified or expedited basis.
Reply comments on the ACP FNPRM are due April 15th. Hopefully we’ll see additional support for low-income and homeless MDUs.
In a separate, but potentially related action last week, the FCC opened a proceeding on “how to prevent and eliminate digital discrimination to ensure that everyone has equal access to broadband internet access service…regardless of income level, ethnicity, race, religion, or national origin.”