WTA Discusses E-ACAM Locations With FCC

On February 22, representatives from WTA and JSI met with staff from the FCC’s Wireline Competition Bureau and Office of Economic Analysis to discuss concerns regarding the true-up of Enhanced Alternative Connect America Cost Model (E-ACAM) locations that is scheduled to be completed by December 31, 2025.

Specifically, WTA expressed its concern with the material and substantial change between the WCB’s assertion in its August 30, 2023 Enhanced A-CAM Offer Public Notice that WCB and OEA would ultimately rely on Version 3 of the Fabric and the National Broadband Map showing serviceable locations as of June 30, 2023 to make true-up adjustments of E-ACAM locations versus the WCB’s post-election statements in its January 25, 2024 E-ACAM Eligible Locations True-Up Public Notice that it intends instead to use Version 4 of the Fabric and Broadband Data Collection data as of December 31, 2023 for the true-up process. The proposed use of data that includes a period of four months after the August 30, 2023 E-ACAM offer date has raised concerns that the true-up will include changes in locations, unsubsidized competitor services and enforceable commitments that occurred after the August 30, 2023 offer date that was repeatedly asserted by the FCC and WCB to be the cut-off date for location true-ups and upon which carriers relied in major part in making their E-ACAM elections.

WTA made it clear that, whatever approach is ultimately employed, the December 2025 true-ups must reflect the actual Fabric locations, unsubsidized competitor situations and enforceable commitments that were in existence as of the August 30, 2023 E-ACAM offer date as repeatedly promised by the Commission and WCB.

WTA also discussed this concern with staff from the offices of Commissioners Starks and Simington, along with other broadband policy issues.