Verizon Trying to Block Community Networks & Schools From ACP Money

Local networks, schools, and new competitors were at the heart of the advocacy for infrastructure spending. Verizon wants to make sure they have no real chance.

That’s my reading of

“Certain proposals in the record, such as using the ACP to
support the ongoing cost of in-building Wi-Fi installed with Broadband Equity, Access,
and Development (BEAD) Program support2 or to replace Emergency Connectivity
Fund support for schools’ bulk purchases,3 raise statutory and implementation issues
that are too complex to address in this accelerated proceeding.”

which Tamara Preiss and Alan Buzacott of Verizon told Trent Harkradar of the Chairwoman’s office.

The right way for Verizon to compete is to offer damn good service at a fair price.

I’ve asked Harkradar how he responded to Preiss and invited comment from Verizon.

Here’s the filing.

Re: Affordable Connectivity Program, WC Docket No. 21-450
Dear Ms. Dortch:

On December 29, 2021, Tamara Preiss and Alan Buzacott of Verizon met by telephone
with Trent Harkrader, Special Advisor to the Chairwoman and Deputy Bureau Chief of
the Wireline Competition Bureau, to discuss the above-captioned proceeding.
In the meeting, we explained that the Commission should not adopt an opt-in
requirement for existing Emergency Broadband Benefit (EBB) households.
 Commenters agree that opt-in is not necessary if the benefit change does not
cause an increase in the customer’s bill, e.g., if the customer switches to a lower-priced

service or already subscribes to a $30 (or less) service. The Commission
should make clear that service providers may move an existing EBB customer to
a lower-priced service, including a service that is fully covered by the $30
Affordable Connectivity Program (ACP) benefit, after providing notice to the
customer. However, the Commission should not require providers to move
existing EBB subscribers to a lower-priced service.
 Many existing EBB customers, including most Verizon Fios customers and
Verizon Wireless customers enrolled in EBB, have already provided affirmative
opt-in to keep their current service after the EBB program ends. Especially since
the benefit reduction will be much smaller than those households anticipated
when they opted-in – $20 (at most) rather than $50 – there is no reason to
require providers to obtain a second (and likely confusing) opt-in from the
households that have already opted-in.
 Even for the minority of households that could see a bill increase at the end of
the transition and have not already opted-in, an opt-in requirement would not be
consumer-friendly. Any household that does not respond to an opt-in notice
would lose its benefit and be forced to re-apply for the ACP, which would be a
greater “shock” than the worst case under an opt-out approach (a $20 benefit
reduction on the first post-transition bill). In that case, subscribers would still
have their service and would still be enrolled in the program, and could contact
their provider to discuss the benefit change and the available options.
We also explained that the Commission should not disrupt existing service provider
processes by imposing overly-broad restrictions on credit checks or sales
commissions, or by prescribing the frequency and method of providers’ notices to
delinquent ACP subscribers.
 The Infrastructure Act1
only prohibits providers from conditioning access to the
ACP benefit on the results of a credit check. It does not prohibit providers from
simply performing a credit check or from using the results of a credit check for
other purposes.
 A commission ban is unnecessary, at least for service providers that rely entirely
on the National Verifier. At a minimum, the Commission should make clear that
any ACP commission rule only restricts commission-based compensation that is
based specifically and solely on the number of successful ACP enrollments.
 Because providers have a statutory obligation to apply to ACP subscribers “the
participating provider’s generally applicable terms and conditions as applied to
other customers,” providers must apply the same delinquency notices and
processes to ACP subscribers as to other subscribers (except that they may not
disconnect an ACP subscriber until after 90 days of nonpayment).
In addition, we explained that the Commission should not require service providers to
submit service information with their election notices, and should not impose new
reporting requirements on ACP participants.
Finally, we explained that certain proposals in the record, such as using the ACP to
support the ongoing cost of in-building Wi-Fi installed with Broadband Equity, Access,
and Development (BEAD) Program support2 or to replace Emergency Connectivity

1
Infrastructure Investment and Jobs Act, P.L. 117-58 (2021).
2 See, e.g., EducationSuperHighway Comments at 9-14.
Marlene H. Dortch January 3, 2022
Page 3 of 3
Fund support for schools’ bulk purchases,3 raise statutory and implementation issues
that are too complex to address in this accelerated proceeding.
This letter is being filed electronically in the above-referenced dockets pursuant to
Section 1.1206 of the Commission’s rules. Please contact the undersigned with any
questions.
Sincerely,
Alan Buzacott
cc: Trent Harkrad

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