Groups Seek Flexibility in ACP Outreach Grants, Public Housing Pilot, Enhanced Benefit

Process grant applications on a rolling basis until funding is no longer available or ACP ends, said the National Digital Inclusion Alliance. The group backed grant terms of one to three years, with a $50,000 minimum per grant. Only nonprofit organizations with a 501(c)(3) status should be eligible, NDIA said.

Make funding available for anchor institutions and "community navigator programs," said the National Urban League, citing similar programs run by the Centers for Disease Control and Prevention and the Health Resources and Services Administration to boost access to COVID-19 vaccines. Prioritize “equity-based organizations" and those with a "demonstrated track record" of reaching low-income and communities of color, it said, adding it backs allowing grant recipients to "sub grant."

Consider making funding available for a "community outreach government liaison to serve as a local point of contact for community outreach organizations," said Hawaii's Broadband & Digital Equity Office. It also backed a 20% cap on a recipient's total funding for administrative work. The National Lifeline Association backed a "multiple-year outreach program that aligns with the expectation that the ACP will extend for multiple years." The Michigan Public Service Commission favored a multiyear grant program and suggested "allocating more funding to the outreach program in year one." It's likely, the PSC said, "the number of eligible households unaware of the program will be significantly higher in the first year than at any other point in time."

Don't make grant applications "so complex that it discourages entities" from participating, said the Alaska Federation of Natives, asking for two-year minimum grant terms. The FCC "must intentionally prioritize" investing in outreach to marginalized communities and "trusted messengers," said the National Hispanic Media Coalition. Data collection and analysis should be built into the commission's "success measurement."

Several groups asked the FCC to let grant recipients spend funding on community events, mailers, broadcasting, paid advertisements, social media and newsletters. The National Urban League asked that national nonprofit intermediaries be allowed to receive "at least $5 million to cover education and awareness campaigns." It also backed a tiered model and suggested multiyear grants so recipients can "build in the necessary time needed" to onboard and train employees. The Healthcare Leadership Council backed efforts to "develop informational materials that can be shared with patients." Create a public database of organizations engaged in ACP outreach efforts to "allow for resource sharing and coordination of ACP campaigns," said Common Sense.

Several groups backed the FCC's proposal to launch a pilot program in coordination with the Department of Housing and Urban Development to boost enrollment in households that participate in federal public housing assistance (FPHA) programs. Give partnering agencies access to the national verifier to "assist FPHA beneficiaries in applying for ACP," said NCTA, noting that could assist on-site enrollment efforts. Expand the pilot's scope to "include targeted efforts to connect consumers" enrolled in other federal assistance programs, said Starry. The ISP suggested an initiative to reach recipients of HUD site-specific housing services that "may live outside of centrally managed public or affordable housing communities."

The "main barrier to enrollment" in ACP is "the lack of automatic eligibility for residents living in multifamily assisted housing," said Stewards of Affordable Housing for the Future: Work with HUD to "clarify automatic eligibility" and establish "building-wide eligibility for residents of a building where all or a substantial number of the homes are assisted under a rental assistance contract." The FCC could "facilitate cross-agency ... and ISP data sharing" so housing authorities can do "targeted outreach" to residents, said the Chicago Housing Authority, saying grant funding should be available for housing authorities and community-based organizations.

Commenters disagreed on how the FCC should structure its enhanced benefit of up to $75 per month for households in high-cost areas. ACA Connects suggested a "two-part test" to decide whether the standard up to $30 benefit for non-tribal households "would cause the subject provider the requisite economic hardship." That includes requiring a provider to show the cost of its participation "would outweigh any revenues or cost savings derived from its ACP participation" and "demonstrate that the net loss from participating" at the $30 level "would cause it economic hardship that would be impactful on its ability to maintain parts of its broadband network."

Consider a provider's "receipt of High-Cost [USF] support " when determining whether a "particularized economic hardship" exists, said NTCA, saying low-income ACP subscribers should be eligible for the enhanced benefit if they receive service in a high-cost area. The definition of high-cost areas "should include areas that have already been built out by an existing broadband provider," said the New York Public Service Commission.

It's "unnecessary to examine an individual operator's cost of doing business," said the Wireless ISP Association. The FCC "already has well-known and existing standards and tools available for determining high-cost areas," it said. WISPA suggested treating census blocks identified as high-poverty areas as eligible for the enhanced benefit. The infrastructure law required the FCC and NTIA to consider whether high-cost areas also have a high rate of poverty.