Crown Castle (NYSE: CCI) asked the FCC to clarify that new required broadband labels containing metrics about internet service apply only to mass-market retail and not to the services provided to schools, libraries and healthcare under FCC universal service programs.
During a call with representatives of the Wireline Competition Bureau and the Consumer and Governmental Affairs Bureau, Crown Castle discussed its involvement in the Universal Service Fund (USF) E-Rate program and recent entry into the Rural Health Care (RHC) program. Crown explained that it provides telecommunications and broadband services to enterprise customers, including schools, libraries and healthcare providers.
Crown Castle said it’s participated in the E-Rate program for the last 25 years and during Funding Year 2021, provided services to over 500 E-Rate recipients. For this current season of E-Rate bidding (i.e., for 2023-2024 funding), Crown has already responded to more than 200 Form 470 requests from E-Rate participants. “These bids primarily provide customized solutions, which may involve network builds, and require customization, multiple pricing options at multiple bandwidths and for multiple terms of years and include service level agreements,” according to a Crown summary of the discussion.
Crown expressed its support for the adoption of the broadband labels for mass market retail consumers so they may make informed decisions about service offerings. It also supports the exclusion of enterprise and special access services from the label requirement. However, Crown strongly urged Commission staff to clarify that enterprise and special access services provided through the E-Rate and RHC programs are not subject to the label requirement.
Crown noted that the broadband order states that enterprise broadband services are often provided through “customized or individually negotiated arrangements” and found that such services could not be subject to the label requirement. The intent of the label is to provide clear, standard information to consumers so they can compare mass-market retail broadband service offerings of multiple providers. Such a requirement is not necessary for complex E-Rate and RHC services provided through competitive bidding “because the beneficiaries are similar to enterprise customers in that they are sophisticated customers with unique requirements and the ability to negotiate customized solutions to meet their needs,” noted Crown.
The company referenced two footnotes in the label requirement rules that it believes appear to be contradictory. It indicated that the new broadband labels would not benefit the E-Rate and RHC recipients and would instead create confusion and misleading information, “undermining the goals of the competitive bidding regulations,” stated Crown.
Crown also noted that imposing a label requirement for the broadband offerings that Crown sells to E-Rate participants would be “extremely” burdensome. The company estimated that it would require Crown “to incur substantial costs to hire and train additional staff and hundreds of hours of extra work for each bid.”
By Leslie Stimson, Inside Towers Washington Bureau Chief
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