On May 6, two of our firm’s clients filed a Petition for Clarification or Declaratory Ruling (view here) seeking guidance from the FCC on the definition of locations under the Alternative Connect America Cost Model (A-CAM) for residences that also serve as businesses. Specifically, the Petition notes that a Frequently Asked Questions (FAQ) document released by USAC (https://www.usac.org/_res/documents/hc/pdf/tools/HC-HUBB-FAQ.pdf) on the treatment of home-based businesses runs counter and actually contradicts FCC Orders on guidance on A-CAM locations. According to the FAQ, in order to count a home-based business as an eligible “location,” “there must be separate facilities (drop/line) and separate equipment (e.g., modem) and the business must separately subscribe (get its own bill) to at least the minimum speed required. These requirements, however, do not exist in the FCC rules and if USAC imposes this separate requirement on A-CAM carriers, it could have a significant impact on many carriers’ ability to meet their location obligations.