Just as the dog days of August begin, the folks at the FCC finally released the long-awaited Alternative Connect America Model (A-CAM) offer of support, with the 90-day election deadline on November 1, 2016. Rate-of-return carriers considering this option have only a limited amount of time to make this critical, future-forward decision.
With the Public Notice released today, the FCC released the final version of the A-CAM, version 2.3. Similar to the previous version, this one has four reports. The first report shows a list of state-level support for each eligible carrier, including the amount of annual support for 10 years and the total number of funded locations in each eligible census block. As a reminder, companies with multiple study areas are required to elect on a statewide basis. The second report shows the specific broadband deployment obligations for each carrier, including “fully funded” and “capped” locations, the number of locations where 25/3 Mbps, 10/1 Mbps, and 4/1 Mbps will be required, and the number of very high-cost locations subject to the reasonable request standard. The third report shows which carriers are ineligible based on their own reporting of 10/1 Mbps broadband available to 90% or more locations. Finally, the fourth report shows the state, carrier, study area and study code for each rate-of-return carrier.
The election letters are due by November 1 and must be submitted to ConnectAmerica@fcc.gov. The letter must be signed by an officer of the company and confirm that the carrier elects support for the state(s) in which it serves, and the carrier must commit to satisfying the service obligations. Carriers that do not wish to elect the A-CAM may send a letter declining the support or they may do nothing – if no letter is submitted, it will be a decline by default.
The Public Notice also addressed some questions raised by JSI in an ex parte meeting we conducted in June. During that meeting, we requested confirmation that buildout obligations were on a statewide level and not on a census block basis. In the Public Notice, the FCC provided the guidance we sought by stating that a carrier electing A-CAM support will be deemed in compliance with the buildout obligations “if the total number of reported locations in each required speed tier (25/3 Mbps, 10/1 Mbps, 4/1 Mbps) meets the total required number of locations for each tier in the state.” The FCC also clarified that the locations “may be in any funded census block, regardless of whether A-CAM identifies a block as fully funded or capped” and that the buildout obligations are merely a “floor” that can be exceeded if carriers are able to do so.
To assist clients in making this decision, JSI has developed an analysis which compares the support that a company would receive under A-CAM with projected support under the modified rate-of-return path. Clients for which we have already performed this analysis should discuss with their JSI consultant any changes to their A-CAM support offer that may have been revised in A-CAM v.2.3. We can produce updated maps of your funded location analysis with the newly-released data and provide templates for acceptance and decline letters, as well as submit the letters on your behalf. Please contact your cost consultant, Steve Meltzer or Brian Sullivan in JSI’s Maryland office at 301-459-7590 if you would like JSI to perform an in-depth A-CAM analysis, would like our mapping service, or if you have any questions regarding the A-CAM offer.
Source: JSI e-Lert