IRREGULATORS Research Memo Summary: ACP

Bruce Kushnick
5 min readAug 11, 2024

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SEE FULL REPORT: ACP Subsidies Ended June 2024; Conclusion: Go After the Money.

1) Investment Amount: The U.S. government spent $14.2 billion on the ACP program to provide a $30 subsidy for low-income families to access broadband services.

2) Households Affected: 1/3 of America has issues with paying broadband charges. Over 23 million households in the U.S, 1/6th of US households could not easily afford basic broadband, indicating a significant digital divide. However, research shows that there is an almost equal amount who could have applied for ACP.

3) Minimal Subsidy Coverage: Only 24% of the population receiving ACP funds had their total broadband costs fully covered through the program and other discounts.

4) FCC Missing Investment Amount by Customers: There was a total of over $30 billion that was paid out by low-income families, an additional $16 billion dollars that added an average of $46.00 a month (Note: The Total Bill was $86, but this included other low-income subsidies, i.e.. total low-income subsidies was almost $40. a month)

5) FCC Average Total Monthly Cost Hidden: The average expense for broadband, including all charges, reported by the FCC hid basic taxes and did not supply the total bill.

6) Underreported Costs: The FCC’s “base monthly price” advertised by providers often omits 30–40% of the total charges that customers actually pay

7) Extra Fees and Charges: Importance: This shows that additional upfront and hidden costs can be a barrier to accessing broadband services. Or worse, equipment costs can further strain the budgets of low-income families.

§ 43% Faced Additional Fees including one-time “Other Amount” averaging an $74.

§ 32% Paid Installation Fees of $39.

§ 16% paid monthly modem/router fees ranging from $8.74 to $13.73.

8) Missing from the FCC: Violation of the Nutritional Labels. The FCC supplied information failed to provide a Total Bill, uses terms that are deceptive “other amounts”, and the taxes that are applied are not supplied.

9) Hiding the Actual Charges by Each Carrier. The FCC provides no access to the actual bills with all charges, by each ACP provider.

10) Price Comparison US vs Overseas: The average cost for a broadband triple play in America is $220, and increasing while similar services in other countries, such as France, are priced between $35 and $45. That is over $150 a month extra.

11) Price Comparison Wireless Overseas: Markets with 4 or more providers can pay as little as $9 for 100 GB of 5G wireless broadband, and the average cost per GB was $.03 cents.

12) Prices in America for Wireless Spectrum-Charter was selling 1 GB for $14. The US average fluctuate wildly; low volume users are punished; All GB are always rounded up.

13) FCC Provider Misrepresentation: The FCC listed 1,600 providers, but many are subsidiaries of a few companies, leading to a lack of real competition in the marketplace.

14) Only 3 Primary US Wireless Networks: AT&T, Verizon and T-Mobile are reselling their services to “MVNO’s” that include almost all of the Top ACP wireless providers, from TruConnect and Tracfone to Excess Telecom.

15) AT&T has 93 listed ACP providers including Cricket, New Cingular, to BellSouth and the original Bell state utilities, including Michigan Bell, or Southwestern Bell.

16) The top cable companies, Comcast, Charter and Cox, are all reselling Verizon Wireless.

17) Lack of Competition and Collusion of the Carriers Caused Major Price Gouging. Rewheel Research has shown that countries with only 3 carriers are 3–5 times more expensive, which is 5–7 times more expensive per GB.

18) No FCC Acknowledgement of Market Failure causing Overcharging.

CODA: The Dirty Little Secret — They Rewrote History.

America is now starting the new round of financing to ‘close the Digital Divide’ with a $42 billion dollar BEAD program. We expect the largest recipients to be the phone and cable companies that helped to create the Digital Divide.

1) All Americans have the right for a fiber optic future because as a nation we already paid for it multiple times.

2) By 2024 it is inconceivable that the FCC did not start investigations into the 3 decades of state-based fiber optic networks that were to be deployed — starting in 1993 and to be completed by 2010–2015.

3) These state laws were to have new infrastructure — modernizing the state telecommunications public utility — which still has franchises in 2024.

4) The Plan: Replace the existing copper with fiber to modernize for more capacity is “broadband”; it was not about “voice calling” only — a fact that is obscured by rhetoric.

5) What you don’t know; By 2010, the companies were able to pull a massive financial bait and switch and move the budgets that were to be used for these modernization plans to illegally build out their wireless mobile networks.

6) But — the fiber optic lines that have been put in are part of this state utility — because they were put in as an upgrade of the existing networks. By doing this the companies were able to continue to bill customers.

7) No state has stopped either the rate increases to customers or examined the cross-subsidies to wireless — and the construction budgets in 2024 are still being paid and not used by the utility but are the force creating more rate increases.

BUT, everyone has a cell phone. And the answer is:

8) Wireless is a separate affiliate company that was supposed to be competing with the wireline networks. Instead of fiber to the home it went for ‘mobile wireless’; but customers paid for infrastructure and replacing the aging copper.

9) Wireless Mobile toys vs dedicated fiber to the home. Wireless requires a fiber wire, and it is not “high speed broadband” in both directions. Moreover, the fiber is infrastructure; it is not dependent on cell sites or battery charging or screen size — (without the chicanery of the company controlling, limiting, filtering, slowing… etc.)

10) The fiber optic lines that were put in are part of the state utility as “backhaul’ or “special access” lines, but there is no accounting of any lines in service — there is no mention that these are part of a utility.

11) The accounting has also been manipulated and easily documented. Turns out that the companies along the way were able to have one line item, local service, be the cash machine illegally for all of the other lines of business.

12) No one state has even examined the financial books of the state utility.

13) Not one state has halted the budgets for fiber optics going to wireless.

14) Not one FCC or NTIA report has ever even mentioned these accounting issues or the state-based telecommunications public utilities cross-subsidies of all of the other services.

15) Every State 5 Year Broadband Plan has left out material facts, presenting a deceptive, analysis on how to solve the Digital Divide. Every state had multiple changes in state laws to build new fiber infrastructure in the state by the incumbent state utility.

16) Not one 5 Year Broadband Plan has mentioned that there are state telecommunications public utilities or that their failure to do the upgrades resulted in the Digital Divide.

More Documentation: We examined these 5-year state broadband plans with our AI and 2 decades of state and federal filings

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Bruce Kushnick
Bruce Kushnick

Written by Bruce Kushnick

New Networks Institute,Executive Director, & Founding Member, IRREGULATORS; Telecom analyst for 40 years, and I have been playing the piano for 65 years.

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