Who determines if the customer is eligible, you or the government? We would 
never have participated in ACP if we had to make that determination.

On November 10, 2026 9:20:43 AM CST, Adam Moffett <[email protected]> wrote:
>I wonder if lobbyists for cable or LEC providers suggested the phone 
>requirement to make life harder on competitors, or if a bureaucrat came up 
>with the idea on their own.
>
>
>________________________________
>From: AF <[email protected]> on behalf of Ken Hohhof via AF 
><[email protected]>
>Sent: Tuesday, November 10, 2026 10:12 AM
>To: 'AnimalFarm Microwave Users Group' <[email protected]>
>Cc: Ken Hohhof <[email protected]>
>Subject: Re: [AFMUG] We may have to sell VOIP...
>
>
>ETC sounds like the big lift.  Have you done business plans for the scenario 
>where you participate and where you don’t, and determined that participating 
>makes sense?  When ACP was a thing, did you participate in that?  I know we 
>didn’t greatly regret doing so but if they brought it back we would have 
>passed.
>
>
>
>Personally I suspect it makes no sense to offer VoIP just for this program, 
>unless your business would take a big hit by opting out.  If you already offer 
>VoIP, or feel it would have benefits (hint: the money is in hosted PBX for 
>businesses), then the effort might be worth it.
>
>
>
>Very few people regardless of household income level want landline phone any 
>more, they just use a cellphone (and there’s Lifeline).  And if someone really 
>does want VoIP, apparently your state has never heard of OTT VoIP.  I have a 
>couple low income (or just thrifty) customers who have Ooma, because it’s 
>cheaper than us.  I think they have a basic plan that’s $0 monthly you just 
>have to buy the phone, the one my customers have I think is $9.99/mo.  I have 
>another customer who got a cellular based box from Consumer Cellular for less 
>than we charge for residential VoIP.  If you do end up offering VoIP as part 
>of this program, there’s a good chance you will get close to zero customers, 
>unless you’re willing to price it so low that you will probably lose money 
>unless you find other more profitable ways to sell VoIP.
>
>
>
>In addition to ETC, you probably can’t just resell service, I would scrutinize 
>the rules.  And if you are the provider, you will have costs related to things 
>like STIR/SHAKEN that will make it unprofitable at a low customer count.  
>There are also various costs like NANPA and TRS, and rules like 
>know-your-customer to prevent robocalling.  It’s not an insurmountable burden, 
>but not something you’d want to take on for a handful of customers.
>
>
>
>From: AF <[email protected]> On Behalf Of Adam Moffett
>Sent: Tuesday, November 10, 2026 8:04 AM
>To: AnimalFarm Microwave Users Group <[email protected]>
>Subject: Re: [AFMUG] We may have to sell VOIP...
>
>
>
>Do you have to have to sell phone under your own brand?  Phone service comes 
>with obligations to protect CPNI, to provide E911, to keep call history logs, 
>etc.  I don't know about NM, but in NY phones also have sales tax.  None of 
>that comes without labor.  If you can just be a retailer you could sell the 
>phone, get a one time commission and then the rest of it isn't really your 
>problem.
>
>
>
>Could you meet the requirement by retailing a cell phone service? If you're 
>doing VoIP you'll have to configure QoS on your whole network, especially on 
>wireless, but really the whole network end-to-end has to be able to classify, 
>mark, and prioritize the VoIP packets.  It's very easy to miss one thing and 
>have VoIP glitches.  A cell phone service removes the technical burden at the 
>very least.
>
>
>
>Is there anything saying you can't use credit checks to disqualify customers?  
>Many ACP eligible customers are going to fail a credit check, so maybe that's 
>a way to minimize how much of it you have to take on.
>
>
>
>It might be worth a letter to the PRC to say the rule should be amended to 
>remove the phone requirement, or to have an exception for providers below a 
>certain size threshold.
>
>
>
>You could estimate all of your additional costs and determine that subsidizing 
>the ACP customers will add $x/month to everyone else's bill.  You can even put 
>that on the bill as a "New Mexico PRC regulatory recovery fee". Whenever a 
>customer asks about the fee, you can explain exactly what it's for and give 
>them a phone number for the PRC, and a link to a comment form on the PRC's 
>website.  They can express their appreciation for the state government helping 
>others or complain about their bill going up.  Their choice, you're just 
>providing the information.
>
>
>
>Sorry to anyone who thinks I'm being the evil guy offering evil 
>suggestions.....people might like the world to be a certain way, but we have 
>to live in it the way it is right now, and right now a business has to make 
>money or not exist.
>
>
>
>-Adam
>
>
>
>
>
>
>
>
>
>________________________________
>
>From: AF <[email protected]<mailto:[email protected]>> on behalf 
>of Josh Luthman 
><[email protected]<mailto:[email protected]>>
>Sent: Monday, November 9, 2026 8:11 PM
>To: AnimalFarm Microwave Users Group <[email protected]<mailto:[email protected]>>
>Subject: Re: [AFMUG] We may have to sell VOIP...
>
>
>
>Call up an attorney and get your ETC like...last year...
>
>
>
>On Mon, Nov 9, 2026 at 12:38 PM Cameron Crum 
><[email protected]<mailto:[email protected]>> wrote:
>
>Danial White at Atheral https://atheral.com/
>
>
>
>
>
>On Mon, Nov 9, 2026 at 11:27 AM Sam Lambie 
><[email protected]<mailto:[email protected]>> wrote:
>
>We are in NM and the state is about to roll out an ACP like benefit to low 
>income households. Unlike ACP where as long as the provider was selling 
>internet the federal government paid the benefits to an ISP, whereas the state 
>of NM is mandating that in order to provide these LITAP benefits, the provider 
>needs to sell telephone services as well as register with the NM PRC as an 
>ETC. Totally archaic ruling in our opinion and shuts out a lot of small ISP's 
>in NM to be able to pass these benefits to our customers.
>
>Nonetheless, in order to play the game, I am researching who sells VOIP that 
>we can resell etc?
>
>Any suggestions would be greatly welcome.
>
>--
>
>--
>Sam Lambie
>Taosnet Wireless Tech.
>575-758-7598<tel:(575)%20758-7598> Office
>www.Taosnet.com<http://www.newmex.com>
>
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