10-90 — Comment Digest

The need to tailor broadband support and deployment obligations to Alaska's unique conditions.

Filers split on: “The Commission should adopt a state-specific cost model to address Alaska's unique deployment challenges.”

• Alaska Remote Carrier Coalition ARCC FNPRM ACFmodify — The commenter contends that permitting tribal consent for service providers in Alaska could violate the rights of non-tribal property owners and result in unequal broadband access, while also emphasizing the need for transitional support if the BEAD program is delayed and arguing that support amounts should account for Alaska's distinct geographic and demographic challenges.pp. 7, 17, 20
• Alaska Telecom Association ATA ACFsupport — The commenter stresses that the lack of affordable middle mile transport capacity is a significant barrier to deploying broadband services in rural Alaska, necessitating flexible performance plans.p. 16
• Alaska Communications Alaska Connect Fundsupport — Alaska Communications advocates for a state-specific cost model to tailor support levels to the unique costs of broadband deployment in Alaska, aligning with the Commission's policy on forward-looking economic costs, while also arguing that limiting participation to ILECs is essential for efficient fund use and stability for existing providers.pp. 2, 23
• Alaska Remote Carrier Coalition ARCCsupport — The commenter argues that funding for Alaska should be tailored to its unique geographic and demographic realities, emphasizing that support levels must account for the distinct living, working, and travel conditions in the state, while also opposing the use of reverse auctions for funding due to past failures and the necessity for reliable service in remote areas.pp. 5, 22, 24
• WTA Advocates for Rural Broadband WTAsupport — WTA emphasizes the unique challenges faced by rural telecommunications carriers in Alaska, particularly due to the region's remote and rugged conditions, which necessitate a flexible approach in any support program.p. 1
• Alaska Telecom Association 2024.03.15 ATA Fabrmodify — The commenter contends that altering the Alaska Plan obligations undermines its original purpose of offering flexibility to address Alaska's unique challenges, while also recognizing that despite its flaws, the Fabric could enhance the estimation of population locations for mobile service commitments compared to current models.pp. 5, 13

The imposition of specific technology and speed standards for broadband services in Alaska.

Filers split on: “The Commission should reject strict technology and speed requirements for broadband services in Alaska.”

• GCI Communicationsupport — GCI argues that imposing technology and speed requirements could limit service coverage and jeopardize public safety in Alaska due to varying connectivity needs, requests an adjustment to the timeline for submitting speed test results to allow for proper testing, and contends that strict requirements would be impractical and hinder service delivery in areas where basic communication needs are met with lower speeds.pp. 3, 14, 15
• Alaska Remote Carrier Coalition ARCC FNPRM ACFsupport — The ARCC argues that additional approval requirements could hinder timely broadband deployment and should be avoided to facilitate progress.p. 4
• Nana Regional Corporationoppose — NANA believes that consistency in requirements will promote fairness and accountability in the broadband deployment process.p. 26
• Alaska Power Telephone Companyoppose — AP&T argues that Alaska should not have a lesser degree of service compared to the rest of the country, and that the same standards should apply to ensure equitable access.p. 16
• Alaska Power Telephone Company APTsupport — AP&T warns that additional regulations could complicate existing collaborations and hinder service deployment in Alaska.p. 10
• OptimERA Holdingssupport — OptimERA emphasizes the need for the FCC to act quickly to improve mobile service in unserved areas rather than maintaining the status quo, which has proven ineffective.p. 6

The feasibility of meeting new broadband deployment obligations by 2026 in Alaska.

Filers split on: “The Commission should extend the timeline for completing new deployment obligations beyond 2026.”

• Alaska Telecom Association 2024.03.15 ATA Fabrsupport — The commenter states that the timeline for completing new deployment obligations by 2026 is unrealistic due to the unique logistical and environmental challenges faced by providers in Alaska.p. 11
• GCI Communicationoppose — GCI agrees with the Alaska Telecom Association that modifying deployment obligations at this stage would be inconsistent with the intent of the Alaska Plan.p. 5
• Alaska Remote Carrier Coalition ARCC GCI PFR Aoppose — The commenter supports establishing a firm date for hex eligibility to avoid uncertainty that could undermine investment and service expansion.p. 10
• Alaska Remote Carrier Coalition ARCCmodify — The commenter believes that funding levels should align with deployment requirements to ensure effective service delivery.p. 5
• Alaska Remote Carrier Coalition ARCC FNPRM ACFmodify — The ARCC warns that without changes to current rules and planning, there will still be unserved and underserved locations in Alaska after the BEAD program is completed.p. 4
• NTCA The Rural Broadband Association 3.4.25 NTmodify — NTCA argues that many questions in the FNPRM cannot be adequately addressed without the necessary mapping data, which will not be available until later. They believe that proceeding without this data would be premature and could hinder effective decision-making.p. 2

The necessity and scope of engagement with Tribal entities in Alaska for service deployment.

Filers split on: “The Commission should mandate formal tribal consent for service providers operating on tribal lands in Alaska.”

• Nana Regional Corporationsupport — NANA emphasizes the necessity of securing site assurances to avoid future disputes and ensure landowner consent, insists that Tribal Consultation is a legal requirement that must be thorough rather than merely formal in all FCC proceedings, and expresses concern over OTZ's inadequate engagement with NANA regarding Tribal Consultation rights, highlighting a lack of acknowledgment in the waiver process.pp. 1, 9, 10
• Quintillion Subsea Operationssupport — The commenter advocates for strong engagement with Tribal Nations, emphasizing the need for formal consent to protect Tribal resources and ensure meaningful collaboration.p. 7
• NTCA The Rural Broadband Association 3.4.25 NToppose — NTCA advocates for maintaining the current effective engagement processes with Tribal entities in Alaska, arguing that existing commercial practices already meet the goals of the FNPRM without creating unnecessary delays or complications.p. 4
• OptimERA Holdingssupport — OptimERA supports the idea that tribes should have a say in who provides services on their land, emphasizing the importance of tribal sovereignty.p. 4
• Alaska Power Telephone Company APT — The company highlights its successful partnerships with tribal governments and organizations, which are crucial for navigating the complexities of service delivery in Alaska.p. 10

The creation and implementation of a dedicated fund to support broadband services in Alaska.

Filers split on: “The Commission should adopt the Alaska Connect Fund to enhance broadband access in Alaska.”

• WTA Advocates for Rural Broadband WTA Alaska Csupport — WTA urges the Commission to quickly adopt the Alaska Connect Fund to enhance broadband services in Alaska, emphasizing that it can complement BEAD grants without causing duplication due to the extensive needs in the region.pp. 5, 7
• Alaska Remote Carrier Coalition ARCCmodify — The ARCC supports the AMMES mechanism for its effectiveness and transparency in addressing Alaska's broadband challenges, advocates for a stable funding approach to alleviate financial strain on carriers during the transition, emphasizes the need for continuity in service and infrastructure development, and highlights the importance of accountability in the appropriate use of funds.pp. 4, 5, 24
• Alaska Broadband Office ABO Letter of Support support — The Alaska Broadband Office urges the FCC to expedite the establishment of the Alaska Connect Fund to enhance broadband access for Alaskans.p. 2
• Alaska Telecom Association ATA ACFsupport — The Alaska Telecom Association (ATA) supports the establishment of the Alaska Connect Fund (ACF) to simplify and increase administrative efficiency in high-cost support for all carriers in Alaska, and advocates for flexible public interest obligations for ACF participants that consider the unique challenges of providing service in the region.pp. 5, 20
• Alaska Power Telephone Companymodify — AP&T warns that while BEAD funding may support capital projects, it does not address the ongoing operational costs necessary for sustainability.p. 24

The requirement for service providers to have ETC designation to receive federal USF support.

Filers split on: “The Commission should maintain the ETC designation requirement for federal USF support eligibility.”

• NTCA The Rural Broadband Association NTCA Alassupport — The commenter argues that only Eligible Telecommunications Carriers (ETCs) should receive federal Universal Service Fund (USF) support to ensure accountability and service quality, and that performance plans and obligations should be customized for each ETC rather than applying a one-size-fits-all standard.pp. 6, 10
• NTCA The Rural Broadband Association Alaska Cosupport — NTCA argues that the statutory framework requires USF support to go to ETCs to ensure accountability and effective use of funds. They believe that abandoning this requirement would not serve the interests of consumers in high-cost areas.p. 6
• Quintillion Subsea Operationsoppose — The commenter suggests that removing the ETC designation requirement would streamline access to funding and promote competition, citing successful examples from other programs.p. 4
• National Tribal Telecommunications Associationmodify — NTTA highlights ongoing challenges that Tribally-owned carriers face in achieving Eligible Telecommunications Carrier (ETC) status, particularly when state commissions do not recognize them or refuse to cede jurisdiction to the FCC.p. 5
• GCI Communication — GCI believes that the images contain trade secrets or commercial information that should not be publicly disclosed, as they fall under Exemption 4 of the Freedom of Information Act.p. 1