|Bravo: $9.95 Comcast Connection for Every Poor Kid|
|Thursday, 23 December 2010 17:15|
In a remarkable move that goes far beyond any previous U.S. program, Comcast will offer a $9.95/month connection and free modem to any family with a kid eligible for free school lunches. That includes those with a family income of up to 30% over the poverty line. They are going beyond that to include partner offers of a netbook or (possibly used) PC for $150 as well as substantial training and outreach. The only important limit is that those who already have Comcast connections are not eligible. This is not a "12 month only" deal and would be offered for three years at least.
Comcast reaches nearly half the U.S.. If they can do this, so should the other major carriers. The actual cost to a big carrier of an additional customer is under $10/month per wall street (UBS & Bernstein), so they don't lose money at that price. Most of these poor families would not be customers otherwise and many will be upsold to faster speeds. So there is little net cost of an offer like this and obvious social benefits.
Comcast has also committed to reaching many of the 100,000's of thousands of their customers who can't get service now. The offering is called "high-speed" in their filing below; I urge the merger negotiators to make sure anything less than the Broadband Plan minimum of 4 megabits is not considered high speed. It would also be good to extend the program to some of those who get subsidized rather than free lunches, which applies to those up to 185% of the poverty level. (The official "poverty level" is notoriously low.)
I'm sending this to other large carriers with the question "If Comcast can do this, why can't you." Here's the filing, first reported by the ever invaluable Dave Kaut of Stifel Nicholas.
Broadband Deployment and Adoption. From the outset, Applicants have underscored their desire to “accelerate the arrival of the multiplatform, ‘anytime, anywhere’ future of video programming that Americans want.”4 Our Public Interest Statement is replete with discussions about ways in which the combined entity plans to use the opportunities presented by broadband Internet to expand consumer access to news, information, and entertainment.
Deployment. The growth in the availability and adoption of broadband Internet is one of the two most amazing developments in communications in the past decade (the other being the closely related phenomenon of the explosion in content, applications, and services that are available to those who use broadband Internet services). Comcast takes great pride in having made broadband Internet available to over 99 percent of the homes passed by its cable systems, and in continuing to improve that service (in January, we reported that DOCSIS 3.0 was available to more than 75% of Comcast’s footprint; less than a year later, that figure has now risen to about 83%). To increase access to the anytime, anywhere future this transaction will deliver, Comcast will take additional steps to expand access to its broadband services, both via additional construction and via new courtesy connections to community organizations. These steps will further advance the Commission’s goals, detailed in the National Broadband Plan, of
Public Interest Statement, at 1.Ms. Marlene Dortch December 23, 2010 Page 4 of 8
encouraging further investment in deploying network facilities and ensuring that every American has access to broadband facilities.5 Specifically,
• Comcast will expand its existing network by at least 1,500 miles per year for the next three years (2011, 2012, and 2013), making broadband Internet available to an estimated 400,000 additional homes;
• Comcast will also upgrade for Internet service at least six additional rural communities in 2011; and
• Comcast will provide an additional 600 courtesy video and high-speed Internet account locations (for schools, libraries, and other community institutions, targeted to underserved areas in which broadband penetration is low and there is a high concentration of low-income residents) over the next three years, at a rate of 200 additional locations per year. This continuing commitment will include Comcast bearing 100% of the construction costs to bring Internet connections to the locations.
Adoption. Broadband adoption, like broadband deployment, continues to grow, but, as was reported in the National Broadband Plan earlier this year, more than 80 million Americans still do not subscribe to broadband Internet service at home.6 American households do not subscribe to broadband Internet for a variety of reasons: some do not see the relevance of broadband to their lives; some lack basic digital skills; and some find the service too expensive.7 Plus, a significant number of homes lack the equipment that makes a broadband Internet connection useful.
Comcast has a plan to substantially increase broadband adoption in low-income homes throughout Comcast’s service area. In households in Comcast’s service areas with annual incomes below $20,000, broadband adoption rates are at approximately 40 percent. More than a quarter of those homes include students who are eligible for free lunches under the National School Lunch Program (“NSLP”), a commonly accepted indicator of need. (Qualifying homes have annual incomes of less than 130 percent of the poverty level.)
To increase access to the anytime, anywhere future that this transaction will deliver, we believe that a comprehensive plan that addresses three key barriers to adoption identified in the National Broadband Plan – reducing the cost of broadband access for low-income homes, the lack of a computing device in the home, and the absence of digital literacy – will give us the opportunity to boost the number of low-income homes using broadband in Comcast service areas.
Under this Comcast Broadband Opportunity Program (“CBOP”), each eligible participating family will:
5 2010) (“National Broadband Plan”).
National Broadband Plan, at 167. Id. at 168.
FCC, Connecting America: The National Broadband Plan, Report to Congress, Sec. 4.1, Chap. 6 (Mar. 16,
Ms. Marlene Dortch December 23, 2010 Page 5 of 8
1. Receive the Economy version of our High-Speed Internet Service for $9.95 a month – a rate for which the household will qualify so long as it meets the “eligibility criteria” below;
2. Pay no installation or modem charges or fees (although we may use our self-install program);
3. Be eligible for one piece of pre-configured, quality computer equipment (which may include rebuilt PCs, netbooks, or other devices) for less than $150 (the equipment will be sold to the customer by a third-party vendor-partner of Comcast’s, with Comcast providing any subsidy required to bring the equipment cost below $150).
4. Have access to web-based, print, and classroom-based training programs, provided in partnership with One Economy and other current and future Comcast community partners in our digital literacy efforts, including Boys and Girls Clubs, and Urban League and National Council of La Raza affiliate organizations. Comcast will create and fund these programs (although we may seek Foundation and other funds to defray these costs).
The program will be established within nine months after close of the transaction, and will run for a total of 36 months (through three school years) after the program is established (although households that qualify during the three-year program will remain eligible for the program for the discounted HSD prices so long as they have a student in the household who qualifies), but in any event we will maintain the program through three full school years. We will implement the program in coordination with state education departments and local school districts, which will be responsible for certifying household eligibility for CBOP. “Eligibility criteria” include: (i) there is at least one child in the household eligible for a free lunch under the NSLP; (ii) the household is not the subject of current Comcast collections activity; and (iii) the household has not subscribed to a Comcast Internet service within 90 days of installation.
Participation will be solicited through participating school districts’ NSLP enrollment processes. Comcast will rely on this well established certification process to qualify participants in CBOP. We will request that school districts include information about the CBOP Program with the first communication to families in advance of the school year and in each NSLP communication as feasible and appropriate. The goal is to ensure families who qualify for the free NSLP are aware of the program at the beginning of the school year and have the opportunity to register in conjunction with the NSLP process. We will provide appropriate collateral materials and request they be included in all NSLP mailings, as appropriate.
Every reasonable effort will be made to educate school professionals who work closest with NSLP-eligible families about the CBOP program. This outreach will include the various education-related associations, including PTAs and associations representing guidance counselors and social workers, in order to reach those who are most likely to work closely with students and families who qualify for the free NSLP.
Prospective participants will be directed to a Comcast phone number dedicated to this program to verify eligibility. Qualifying callers will be transferred to a centralized order-entry
Ms. Marlene Dortch December 23, 2010 Page 6 of 8
center. When service installation is complete, the participating household will receive a voucher and instructions on how to obtain the subsidized computer equipment.
Comcast will engage in efforts, in coordination with community partners, to publicize the availability of the program, targeted to areas with high concentration of low-income residents and especially through vehicles that are targeted to eligible households. Among other things, we will promote the CBOP program through public service announcements, as well as through segments of Comcast Newsmakers featuring guests who will describe the CBOP program and how to take advantage of it. We will distribute the program information to our partners who work with low-income communities – on a national and local level, e.g., One Economy, National Urban League, La Raza, etc. Comcast will also coordinate with state and local educational administrative entities to enable notification of certified NSLP families of CBOP.
Several computer training and support options will be offered. At the time of installation, each participating household will received basic instructional materials and a phone number for a dedicated support desk. The computer equipment will be pre-configured with a “wizard” to facilitate e-mail set-ups and the setting of parental controls. Shortcuts to “getting started” tutorials will appear on the desktop. Each piece of equipment will ship with Norton security pre- installed. Comcast and its partner organizations will offer “training days” at NSLP- participating schools in Comcast’s service areas, as well as at instruction facilities operated by our community partners.