“A ban on the practice could have the adverse effect of disincentivizing broadband buildout to affordable housing units, reducing affordable options to broadband for residents, and further exacerbating the digital divide for affected households.”

National Association of Counties

“Over the past decade, our Members – smaller broadband providers – have invested many billions of dollars to enter new markets, thereby giving consumers, including those residing in MTEs, greater choice. These investments were due in no small part to the Federal Communications Commission’s (“Commission’s”) adoption of a balanced regulatory regime. This included the Commission’s 2010 decision finding that bulk billing arrangements are on balance pro-consumer. We urge the Commission to continue policies that enable competitive entry and expand consumer choice.”

ACA Connects

“The Winterpark II BOD is not in favor of any rules, changes or regulations banning associations from directly negotiating with and promulgating bulk purchase agreements for their respective owners’ internet and television services. Additionally, this HOA is not in favor of any rules, changes or regulations to nullify or otherwise invalidate existing agreements currently in force.”

Naples Winterpark ll Condominium Association, Inc.

“We find the FCC’s reasoning for regulating bulk arrangements both baffling and inaccurate; as our current bulk billing arrangement demonstrates, it maximizes the welfare of our residents. Moreover, should the FCC alter these arrangements, such as permitting any individual resident to opt out of the arrangement, our residents – all seniors – would end up paying much higher prices for broadband and cable. We therefore urge you to reject any effort to ban or regulate bulk billing arrangements, including those that already exist.”

Lazy River Village Inc.

“Municipalities and housing authorities have used bulk billing to deliver broadband at low or no cost to affordable housing tenants who might otherwise lack the financial means to get online, with one prominent example being the city of Charlotte’s AccessCharlotte Program, which is scaling up to provide free internet to over 50 housing communities and the single-family neighborhoods in low-income communities. With the Affordable Connectivity Program on life support, soon over 23 million low-income households across the country could see their monthly internet bills go up, including over 415,000 households here in South Carolina.“

Chaquez T. McCall (Florence, SC) Councilman

“Currently, many HOAs, public housing communities, and university students receive internet at up to a 50% discount by negotiating rates as a group. Ending bulk billing would eliminate these savings and make it significantly more expensive to expand internet service.”

Kambrell Gavin, North Carolina State Representative

“In HOAs and COAs, it is property owners who live in the community and belong to the HOA or COA that take part in the bulk billing negotiation process. They negotiate with providers who compete for their business to secure the best, most consumer-friendly deal possible for everyone living in their community, including themselves. Stripping away their ability to leverage bulk billing will only lead to higher internet prices for everyone in their community, with no apparent benefit for these communities resulting from this at all.”

Chris Russell (Thornton, CO) Councilman

“This proposal threatens both the affordability and accessibility of essential digital services. Continuous connectivity is essential for the well-being and advancement of the communities I represent. In my district alone, about 50% of households are part of HOAs or apartment communities which could benefit from bulk billing and should continue to have that competitive option to provide the lowest rates to their residents.”

U.S. Representative Shelia Cherfilus-McCormick

“The Federal Communications Commission is considering a proposal to ban bulk billing for internet service. This is a common practice in many of our multi-family communities in which the association is able to negotiate service packages for its residents at lower-than-market prices. The FCC maintains that it is trying to expand choice. The true consequence, though, will be higher prices for homeowner associations, senior living communities, condo associations and affordable housing complexes. These entities have long been able to secure deep discounts, easing access to the internet.”

Dean Trantalis, Fort Lauderdale (Florida) Mayor

“I urge the FCC to reconsider this proposal. Americans living on a fixed-income cannot afford this setback, especially as we navigate the end of programs that promote digital equity. Maintaining and enhancing measures supporting affordable housing and ensuring comprehensive broadband access for all is critical. The FCC must align its policies with the ongoing federal initiatives that have begun to address our digital divide successfully. As we continue to advocate for equitable internet access, particularly in affordable housing, it is imperative that we build on the progress made, not dismantle the tools that have proven effective.”

Jason Dawkins, Pennsylvania State Representative

“..the FCC’s proposal is far broader than just weeding out dishonest practices from landlords. Instead, it would eliminate bulk billing as a whole, which would have unintended, disastrous impacts on the underserved communities whose broadband connection depends on bulk billing contracts.”

Jonathan Kinloch, Wayne County (Michigan) Commissioner

“Serious concerns can be raised about the impact this rule would have broadly for consumers, but I’m especially concerned about the unintended impact it’d have on underserved communities by exacerbating the affordability gap. Broadband affordability is the number one barrier keeping Americans offline, and it’s been shown to have an outsized impact on communities of color.”

Kalan Haywood, Wisconsin State Assemblymember

“For residents in affordable housing, bulk billing is vital for overcoming economic barriers to internet access. Without these agreements, local governments and housing providers may face challenges in securing favorable terms with internet service providers, leading to higher costs for residents—impacting underserved communities most severely.”

Sonya Halpern, Georgia State Senator

“In Raleigh, we have a wide array of residents reaping huge savings from these agreements. It includes folks in HOAs and COAs, seniors living on a fixed income in multi-tenant communities who rely upon lower costs to stay financially stable in retirement and college students whose student housing provides them with a stable connection at a lower price on day one of school. By eliminating bulk billing, the FCC could threaten the connectivity of all these residents and put our nation at risk of widening its digital divide.”

Mary-Ann Baldwin, Raleigh (North Carolina) Mayor

“As someone who works to pass policies that protect older Nevadans, it’s impossible to overlook the ways in which this proposal would raise prices for seniors, especially those living in senior living communities, many of whom live on a fixed income. Without the savings that bulk billing agreements provide, many seniors on a fixed income could have their connectivity threatened.”

Sandra Jauregui, Nevada Assemblywoman

“For many of our residents, these arrangements are more than just a way to save on monthly bills — they’re a lifeline, ensuring that every family, regardless of income, can stay connected and informed in an increasingly digital world. I’ve seen firsthand the impact of these arrangements on our community.”

Alix Desulme, North Miami (Florida) Mayor

“We believe the FCC’s prior decision is well-founded as it enables consumers, including seniors, fixed-income individuals, and students to aggregate their purchasing power.” 

U.S. Representatives Darren Soto (D), Rep. Neal Dunn (R), Rep. Buddy Carter (R), Rep. Kat Cammack (R), Rep. Gus Bilirakis (R), Rep. Jared Moskowitz (D), Rep. Bill Posey (R), Rep. Kathy Castor (D), Rep. Diana Harshbarger (R), Rep. Lizzie Fletcher (D) and Rep. Young Kim (R)

“People in underserved communities frequently face challenges in affording homeownership, leading many to opt for renting instead. Tenants rely on the owners and managers of multidwelling units (MDUs) to make essential services like broadband access available. However, due to the economic challenges of serving buildings, especially those with lower-income residents, many MDUs have struggled to attract broadband providers willing to deploy new infrastructure and offer quality service at affordable prices. MDU owners and managers have frequently overcome those challenges through bulk billing arrangements.”

ALLvanza

“If the FCC were to ban bulk billing, all the benefits derived from these arrangements would vanish. Those currently enjoying the advantages of bulk billing would pay more for services. For those unable to afford these higher prices, they would lose a critical tool for their well-being. Additionally, residents in communities with limited-service provider options would face challenges attracting new providers to compete. None of these outcomes serve the best interests of older individuals, their families, or their communities.”

Diverse Elders Coalition

“Bulk billing agreements for internet service have played a crucial role in ensuring that residents in multi-dwelling units (MDUs), particularly those in public and affordable housing who account for 20-25% of the nation’s digital divide, can affordably connect to the online world.”

No Home Left Offline Coalition

“Bulk billing agreements for internet service have played a crucial role in ensuring that residents in multi-dwelling units (MDUs), particularly those in public and affordable housing, can affordably connect to the online world. However, the recent proposal to eliminate bulk billing agreements threatens to disrupt this vital lifeline, potentially diminishing competition and exacerbating disparities in digital access.”

EducationSuperHighway

“Our HOA / COA would lose the benefits of free / comped services like internet, TV and phone for common areas, pools, clubhouses, guard gates and more. This would cost our Community thousands more per year. Without bulk, there are many senior residents that would have to drop either TV or Internet services to live within their fixed income. I implore you to review all the information above and continue to allow the current bulk services we have offered to our residents for many years.”

Huntington Pointe

“With out the bulk service our building would receive less priority and our 122 owners would pay substantially higher individual rates. We hope to keep our Blue Stream bulk rate service for many years to come.”

Aquanique Ocean Club Condominium Association

“I challenge you and your Board of Commissioners to visualize yourselves as a person on a fixed income. Who are these people (the FCC) who have the power to make me to pay significantly more for services that provide critical information for my safety….or force me to give up access to the provider of this information that we negotiated at a fair and affordable rate?”

Capstan 1, Inc.

“As the President of the Board of Ocean Harbor South, I am writing to express our strong support for the continuation and promotion of bulk pricing arrangements for Internet and TV services. Our community has experienced significant benefits from our current bulk pricing agreement with Bluestream, and I would like to highlight the advantages that this arrangement provides over individual account pricing.”

Ocean Harbor South Condominium Association, Inc.

“Key to this ability to negotiate was including all units in the contract and not allowing units to individually opt out of service. Not including all residents in the bulk agreement, and not allowing residents to opt out of the bulk agreement, the HOA would have less or no ability to negotiate lower rates and improved services.”

Copper Oaks Homeowners’s Association

“Today, as president of our association, I am constantly reminded that our community members cannot afford higher costs. Many of them are put in a position to either refill their medication or being able to purchase food. Before making such a decision, truly reflect on how such a ban will affect the majority of our residents. Perhaps, you can pretend that any of our residents can be your parent/grandparent, etc.”

Sunrise Lakes Phase IV, Inc. 3 Condominium Association

“It would be a great disservice to so very many people if you were to remove the bulk internet services. Especially for my family personally and for so many other residents of The Coral Springs Estate Townhome Condominiums.”

Coral Springs Estate Townhome Condominium Association

“Our residents at Mimosa Condominium benefit greatly by our ability to include all residents in the bulk agreement. Pricing is greatly reduced from everyday rates, more than 50% of what they would pay individually. We feel if our association did not have the ability to negotiate bulk agreements for internet and TV service, many of our senior residents would have to drop either TV or internet service for many different reasons.”

Mimosa Condominium Association

“To eliminate “bulk billing,” however, is also a mandate that eliminates a powerful tool communities can use to better serve their members. While bulk agreements are likely not right for all communities, they can be extremely beneficial for others. In your goal to lower costs and address the lack of choice, please don’t eliminate our choice to consider bulk agreements.”

Mirabella at World Gateway Condominium Association, Inc.

“Our HOA conducted an exhaustive review process with potential providers with a view towards maximizing the benefits for our residents. A key component of our negotiations was the ability to offer all our residents participation in the contract, enabling the HOA to negotiate lower rates and improved services. With limited exceptions, residents are not permitted to opt out of the arrangement.”

Kingswood Association 2, Inc.

“Our Master Board, our sub-HOA’s and many other people would not be very happy if the FCC or any one else bans these agreements, against our wishes. They save our residents a substantial amount of money and are beneficial to our residents and communities.”

Panther Trace at Sawgrass Lakes

“The internet is a lifeline for most of our residents to keep in touch with family and friends. If the bulk rate is eliminated, you would be reducing the quality of life for many of these residents. They cannot afford to pay $60-$200/month, depending on the package.”

Jamaica Bay

“Our owners tell us they want 3 things – a great TV/Internet experience, superior customer service, and at a reasonable rate. That’s exactly what bulk buying provides. We ask that you choose to continue to allow bulk buying of TV/Internet.”

Seascape

“It’s a given fact that when you purchase the same item in larger quantities there are savings to be gained.  Why then should HOAs and COAs lose their ability to use their collective bargaining power to negotiate bulk services which are affordable for our senior residents?  Please think long and hard about the financial effect this change would have on millions of seniors. Things are tough enough for senior citizens today.  Please do not take away this important negotiating ability for Port Charlotte Village and all the other HOAs and COAs.”

Port Charlotte Village

“Although we applaud your goal of lowering cost and increasing choice for consumers, we believe banning bulk agreements and allowing residents to opt out of the bulk billing arrangement will have the opposite effect. If implemented, the ban could increase costs for those who can least afford it. It may also be a disincentive to upgrade antiquated infrastructure in aging buildings and communities to modern high-speed fiber.”

Gator Trace Master Property Owners Association

“In summary, bulk agreements have been instrumental in providing our community with a great television and internet experience, superior customer service, and affordable rates. Banning bulk services would not only undermine these benefits but also cause financial hardship for many of our residents. I urge the FCC to reconsider this proposal and continue to support bulk agreements for HOA communities like Ballantrae.”

Ballantrae Community Association

“Let it be known that our 55+ condominium association of 148 units is in favor of keeping in place BULK internet and television contracts for our residents. To maintain our lower cost for the services, it is better for our residents not to be able to opt out so to ensure a better leverage with our provider of services.”

High Point West

“The financial savings provided by the bulk service agreement are especially critical for our community, where many residents are on fixed incomes. Without the bulk service package, a large number of our residents would likely be unable to afford the services they currently enjoy and rely on. This would greatly diminish their quality of life, as internet and television services are essential for staying informed, entertained, and connected with loved ones.”

Country Club Tower of Coral Springs

“Our Condominium Owners Association (COA) has provided cable television and internet services for our residents for many years and been able to leverage and maximize our community’s buying power for these essential services. These services are included through a bulk contract and provides services for all in our community, allowing for the Board of Directors to negotiate the optimal deal, like the many services our residents have come to expect – i.e. landscaping, maintenance and other utilities. It allows the COA’s members to avail themselves of the benefits of lower rates that include service and equipment. Furthermore, it provides predictable rates and fees, with reliable service/performance for both internet and television broadcasting that does not permit any resident to opt out.”

High Point of Delray Beach

“Members of our coalition are deeply concerned that the proposed elimination or restriction of bulk billing agreements for internet service in MDUs will jeopardize both existing and future digital access for vulnerable populations. Without these agreements, public and affordable housing providers may struggle to negotiate favorable terms with internet service providers (ISPs) and managed service providers (MSPs), leading to higher internet costs for residents. At a time when the future of the Affordable Connectivity Program (ACP) remains uncertain, the unintended consequences of the FCC’s proposal would mean some of our nation’s most vulnerable populations are unable to connect to affordable, high-speed internet, further widening the gap in digital literacy and access to online resources.”

National Real Estate and Housing Associations

“There isn’t a provider offering service to retail customers that can tout these kinds of offerings at the discounts our community members are receiving. Banning bulk contracts would diminish group buying power and eliminate wholesale pricing and purchasing, and regarding Playa Vista’s contract, would diminish the benefits that Playa Vista residents are currently receiving.”

Playa Vista Parks and Landscape Corporation

“In addition to the cost savings, the bulk service agreement provides us with the valuable benefit of having a dedicated account representative. This representative is available to assist with any questions or repairs, ensuring that issues are resolved promptly and efficiently. This level of personalized customer service is a significant advantage for our community, where many residents may need additional assistance with technology and service-related concerns.”

Country Club Tower of Coral Springs

“The financial savings provided by the bulk service agreement are especially critical for our community, where many residents are on fixed incomes. Without the bulk service package, a large number of our residents would likely be unable to afford the services they currently enjoy and rely on. This would greatly diminish their quality of life, as internet and television services are essential for staying informed, entertained, and connected with loved ones.”

Country Club Tower of Coral Springs

“Our HOA did a thorough process in making a decision to enter into a bulk contract. We first formed an ad-hoc committee to look into the possibility. The committee surveyed our residents to see if there was interest. 95% were interested. Next, we solicited companies; including Comcast and Frontier (they were not interested). We narrowed it down to two companies and ultimately chose one for our community. We then conducted several town hall meetings with the chosen company to inform our residents of all aspects of the process, the services they were going to receive, the laying of fiber optic cable and its benefits, installation in their homes, and education on how to use the services after installation. Lastly, after all the town hall meetings, we put it to a community vote for final approval. The results were overwhelmingly in favor of entering into a bulk contract for our community at 93%.” 

Oyster Creek Homeowners Association

“We are concerned that this proposal would have a negative impact on residents; including seniors, fixed-income individuals, and students who reside in community associations because it will result in increased costs and lower quality infrastructure. Bulk billing arrangements for broadband access through condominiums and homeowners’ associations have been proven to benefit residents with lower costs, improved infrastructure, and faster internet access.”

Community Association Institute (CAI)

“Pricing, service capabilities, and customer responsiveness that we obtain through our bulk agreement cannot be matched by providers in the retail market. If the FCC proceeds and bans bulk agreements, it would harm our owners and others living in homeowner communities. The FCC should not pursue such an anti-consumer agenda.”

Bonita Beach Club Association

“While I understand that the premise behind the proposed rule to eliminate bulk bulling is that it would increase competition, choice, and competitive pricing; I assure you that the opposite would in fact take place. The residents of Lakes on the Green would immediately go from paying a $74 bulk rate to well over $200 for the same services; Definitely not reducing costs.”

Lakes on the Green Homeowners Association

“As our society’s reliance on technology continues to grow, the disparity between those with and without internet connection disproportionally affects our lowest-income households including people of color, older adults, and persons with disabilities. Public housing authorities are crucial to narrowing the digital divide since they house and serve the lowest-income households in our country. Because of bulk billing arrangements, CLPHA members can subsidize the cost of internet or offer affordable rates to residents living in public housing units.”

Council of Large Public Housing Authorities (CLPHA)

“I am concerned that this proposal would have a negative impact on various residents and communities, including seniors and fixed-income individuals, among others, who reside in condominiums and housing cooperatives, because it will result in increased costs and lower quality infrastructure.”

33 Laguna Woods Village

“HOAs benefit substantially from competition in negotiating these bulk billing arrangements. In Summit Broadband’s experience, there typically will be up to six ISPs competing for a new bulk billing agreement as part of an HOA-run competitive process. HOAs often will appoint a subcommittee of residents to develop a detailed Request for Proposal (“RFP”), solicit responses, select, interview and negotiate with two or three finalists, and negotiate a contract with the finalist—all subject to the final approval by the HOA board. This competitive process gives an HOA the ability to determine which contractual terms to prioritize in a negotiation.”

Summit Broadband

“In 2010, the FCC concluded that bulk billing is an effective model for reducing prices and increasing internet access. Many stakeholders agree that reversing this well-reasoned decision would contravene the public interest. We agree – the FCC should abandon any plans to eliminate bulk billing arrangements in MDUs or to take other actions that would weaken the buying group power of the purchasers of such services.”

Providers of High-Speed Broadband Services Under Bulk Billing Agreements

“Having an established term in these negotiable agreements allows Altice to offer lower rates and so provides benefits to both the service provider and the business customer. Business customers receive certainty and favorable rates for their commitment, and the provider receives the promise of recouping some of its investment, especially when the agreement includes construction requirements.”

Altice USA

“NCTA explained that the benefits of bulk billing arrangements for consumers are significant and that interfering with the ability of building owners to offer these arrangements to their tenants will result in higher broadband and video prices and other harms for consumers, with questionable and limited benefits. Moreover, as with other services and facilities that may be provided in a multi-tenant setting (e.g., gym facilities, landscaping, party room), a tenant that chooses to live in the MTE necessarily opts in to the choices made by the MTE owner as to the services and facilities offered, with no expectation of receiving a credit if the service or facility is not used by the tenant.”

The Internet and Television Association (NCTA)

“In addition to enabling broadband investments, bulk billing arrangements create sales-channel efficiencies that reduce the per-unit cost of providing service, thereby enabling higher-quality broadband at lower prices.”

Coalition of Independent Internet Service Providers

“Indeed, some bulk billing arrangements offer more benefits to consumers than consumers could achieve when contracting with ISPs directly.”

GiGstreem

 “A ban on bulk billing arrangements would run directly counter to the FCC’s intentions to increase competition, as opportunities for bulk contracts encourage competitions among providers to enter new communities, and offer services with more favorable pricing and service terms than would otherwise be available to consumers.”

Blue Stream Fiber

“The Hotwire Representatives further explained that bulk billing arrangements, which lower the cost of broadband service significantly, will become even more important for lower-income consumers living in multi-tenant buildings or multi-premises communities should the ACP end. EducationSuperHighway addressed this point in recent meetings with the Commission, stating ‘It is our position that bulk billing ultimately benefits tenant consumers, increases market competitiveness for broadband coverage, and provides an easier consumer experience. Hotwire urged the Commission to not exacerbate the challenges these consumers would face should the ACP end by subsequently eliminating or otherwise limiting bulk billing arrangements‘.”

Hotwire Communications

“Through bulk billing, providers like OpticalTel are able to offer much lower prices to more customers than would be possible without bulk billing. Bulk billing arrangements are a key tool for closing the digital divide by permitting competitive providers to deploy next-generation fiber facilities to communities in reliance on a business case and minimum revenue targets that are sufficient to cover the costs of deployment and ongoing service.”

Optical Telecommunications

“As broadband deployment experts, we have seen bulk billing provide an incentive to build where deployment may not have otherwise been economical or beneficial. Should the FCC prohibit bulk billing, investments in difficult to build areas may be stymied.”

Utopia Fiber

“The end of bulk billing will result in less competition and higher consumer costs, especially for those least able to afford the dramatic price increases sure to follow. Bulk billing offers savings for communities that disproportionately live in multi-resident buildings, including seniors on fixed incomes, people in public housing, and minority communities in more densely populated urban areas. These are the people who would be harmed most, as they witness sticker shock from their internet service bill stripped of its volume discount.”

Consumer Action for a Strong Economy

“Vulnerable communities, including seniors and low-income individuals, stand to bear the brunt of these changes. For many of them, bulk billing represents a lifeline to affordable broadband access. Disrupting this system could exacerbate existing disparities in internet connectivity, further marginalizing those who can least afford it and exacerbating the digital divide, which would stand against the FCC’s mission these last few years.”

Consumer Choice Center

“Such a ban would not ‘lower costs and address the lack of choice for broadband services’ as the Commission alleges. What it would do is harm Americans living in collective housing arrangements who benefit from the reduced rates that building owners negotiate on their behalf.”

American Consumer Institute

“Second, as a result of this ill‐​defined approach, the aims of anti-‘junk fee’ policies are often explicitly contradictory. The proposed rule on bulk billing implies it is unfair and uncompetitive for landlords owning apartment blocks to bundle up charges, such as for broadband, into a total rent price, for example. The Biden administration says it doesn’t want tenants paying for services they haven’t opted into. Yet much of the rest of the anti-‘junk fees’ agenda encourages the bundling up of fees into a ‘total price.”

CATO Economics

“The FCC’s proposed rule could cause significant harms to consumers without producing meaningful benefits. Bulk billing allows for residents of MTEs to receive higher-quality broadband service at lower prices, and outstanding concerns about subsidy participation do not justify elimination of the practice.”

American Action Forum

“While claims of consumer choice sound good in principle, they overlook the essential benefits these bulk billing arrangements provide, such as affordability and broader access. If implemented, the ban could lead to higher internet costs for those who can least afford them. It also could lead to reduced capital investment to upgrade antiquated infrastructure in older buildings to modern high-speed fiber. In combination, these effects will widen the digital divide the FCC purports to close.”

The Federalist Society

“In 2010, the FCC understood that it would be a ‘disservice to the public interest if, to benefit a few residents, we prohibited bulk billing, because so doing would result in higher [broadband and television] service charges for the vast majority of MDU residents who are content with such arrangements.’  If the agency acts against the overwhelming facts in the record, it could represent regulatory overreach subject to legal challenge. Instead of a blanket ban on bulk billing, a more nuanced approach targeting specific anti-competitive practices would be more effective. This could involve regulations that prevent exploitative practices without eliminating the model that has worked well for so many consumers.”

American Enterprise Institute

“Internet access is more important than ever. It is necessary for many teleworkers to earn a living and children—who are either enrolled in virtual schooling or simply finishing their homework online—to learn. With pandemic learning loss still haunting students, any policy that would remove proven avenues to learning should garner plenty of skepticism. That’s what the FCC’s latest proposal would do: Make internet access more expensive—and possibly out of reach—for many renters, while simultaneously eliminating businesses’ abilities to differentiate themselves from their competitors.”

Marc Hyden, Director of State Government Affairs, R Street Institute, Georgia

“We discussed the Chamber’s viewpoint on Chairwoman Rosenworcel’s proposal to prohibit bulk billing arrangements. We noted that bulk billing arrangements provide significant benefits to consumers, enable greater access to broadband, and that a rulemaking at this point is premature.”

U.S. Chamber Institute for Legal Reform