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Great article. The FCC failed to update the cost model with current costs in order to stay within the predetermined E-ACAM budget. Without addressing the inflationary costs, the model absolutely underestimated the cost to deploy 100/20M to all locations. Also, some individual locations can cost $100,000 or more to serve which makes a model unreliable. The FCC did not allow companies to remove those Extremely High-Cost locations, which limited participation as well. Some locations ILEC's were required to serve are currently served by an electric cooperative (EC) with FTTH. However, the EC does not provide voice service and therefore the FCC ignores their FTTH service. Therefore, the locations were shown on the FCC's map as unserved, even though they had FTTH and the ILEC had an obligation to provide 100/20 to those locations with EC FTTH. This would be the same for a WISP that provides 100/20 but no voice service.

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