FCC Comments on the Emergency Broadband Benefit Program

By at 16 February, 2021, 11:28 am

Marlene H. Dortch, Secretary

Federal Communications Commission

Office of the Secretary

445 12th Street, SW

Washington, DC   20554

Via Electronic Submission


REDocket 20-445, Emergency Broadband Benefit Program


Dear Secretary Dortch:

On behalf of the Small Business & Entrepreneurship Council (SBE Council), I am pleased to provide comments on the Emergency Broadband Benefit (EBB) program. Access to broadband is critical to the self-employed, new business creation, workers, families, small businesses and the communities they operate in. Obviously, broadband access has become a lifeline – a necessity – during the COVID-19 crisis. The EBB program can positively impact the lives of many Americans if executed in an efficient and prompt manner. SBE Council is also hopeful that the program can serve as an impetus for needed reforms that will sustain broadband access for households and individuals most in need, and over the longer term.

SBE Council is a nonpartisan, nonprofit advocacy, research and education organization dedicated to protecting small business and promoting entrepreneurship. With more than 100,000 members nationwide, SBE Council is engaged at the local, state, federal and international levels where we collaborate with elected officials, policy experts and business leaders on initiatives and proposals to enhance competitiveness and improve the environment for business start-up and growth.  For 26 years we have worked on a range of issues to strengthen the policy ecosystem.  Technology and telecommunications policy has remained one of our core issues, as participation in the digital economy – with all of its tools and opportunities – is critical to small business success and growth, and the health of U.S. entrepreneurship and the economy in general.

SBE Council is pleased that the latest round of COVID-19 relief signed into law at the end of last year included the $3.2 billion EBB program. At the same time that internet service has become essential during the pandemic, Americans are struggling to pay for this service.

COVID-19 has upended America’s small business ecosystem, and “pivoting” to digital tools was and is the only way many small businesses have been able to survive. With access to broadband, many newly unemployed individuals also have the opportunity to start businesses, and most from their homes. The same applies to many women, who have had to leave their jobs due to school closings and the need to be home with their children. Therefore, it is vital that all Americans have equitable access to broadband, as starting a business is a key path to financial security and wealth creation.  As I noted in my recent testimony before the House Small Business Committee, there is good news to share from the COVID-19 crisis: More and more people are starting their own businesses – with greater numbers of “high propensity” businesses (likely employers) launching in 2020 than 2019.

Access to the digital economy and all of its tools through the internet means more opportunity and entrepreneurship, and it is why we focus so passionately on broadband access and deployment.

Key lessons have been learned by the federal government in executing the Paycheck Protection Program (PPP) for entrepreneurs and small businesses, and we believe some of these are quite relevant and applicable to EBB in terms of providing seamless and broad access to ensure the program reaches those most in need, and to ensure policymakers are developing longer-term strategies that provide certainty by meeting the needs of intended beneficiaries through the recovery period and beyond COVID-19 relief programs.

Inclusive and Broad ISP Participation: First, it is important that EBB be inclusive to all providers – to encourage widespread ISP participation – to ensure EBB reaches all consumers in need with a broad array of choices. As we are learning through PPP, a greater number of lenders, especially including diverse lenders, has been critical to reaching small businesses most in need. These include the smallest of small businesses and those in disadvantaged communities. A bigger distribution system provides for greater choices and the varied options consumers need based on individual circumstances. In the case of broadband options, this includes service that supports working from home, attending school from home, telehealth, or running or starting a business. It is important to launch the program with significant ISP representation, which means Eligible Telecommunications Carrier (ETC) designations must be an inclusive, efficient and prompt process.

Easy Navigation and Simplicity: Complexity, red tape and confusing rules hurt PPP access from the start, and we encourage those constructing the EBB program to “keep it simple” and smart. To ensure the program encourages participation and reaches eligible consumers quickly, the national verification process should be updated to include all EBB statutory eligibility criteria for household verification. It needs to be simple. Such a verification system will also help to guard against fraud and waste.

Transparency and Reporting: Real-time tracking of funds being used by PPP allowed Congress and SBA officials better track trends or emerging issues to make adjustments more quickly and intelligently. That same 24-7 transparency and regular reporting on the status and distribution of funds is important for EBB, especially given the great need for aid and limited dollars available. Consistent updates regarding funds available (and the exhaust rate) is important data for EBB coordinators at the FCC, providers and consumers alike in order to better prepare for financial budgeting and other related decisions (both in the short and long-term).

Long-Term Funding Reform: Rather than continue with a band-aid or emergency approach through EBB, thought leaders at the FCC and members of Congress need to begin planning for needed structural changes to the Universal Service Fund (USF) regarding its unsustainable contribution mechanism. When EBB funds are exhausted and/or the program concludes, USF will not be able to support expanded E-rate benefits or benefits provided by EBB. This is an opportunity to fix the funding source for the full complement of USF programs, especially given the fact that the contribution factor has escalated dramatically to 31.8%.

SBE Council appreciates the opportunity to provide comments. Please do not hesitate to call upon the SBE Council team for additional information or questions.


Karen Kerrigan, President & CEO







News and Media Releases