Client Alerts  - Telecommunications Jan 11, 2024

Affordable Housing Connectivity Program (AHCP) Section One Applications Open

ConnectALL will begin to review Section One of AHCP applications after February 16, 2024.

In an effort to close the digital divide for low-income housing residents in New York State, Empire State Development’s ConnectALL Office (CAO) has developed the Affordable Housing Connectivity Program (AHCP). Through the AHCP, the CAO is working to upgrade in-unit broadband infrastructure for low-income affordable housing residents who currently have unreliable, unaffordable or nonexistent internet service in their apartments, at no cost to property owners.1 Eligible uses of AHCP funds include fiber or other broadband connections to property premises and in-building equipment and wiring retrofits.2 The CAO intends for the AHCP to serve at least 100,000 households. The funds allocated to the program total $100 million from the U.S. Department of the Treasury’s Capital Projects Fund under the American Rescue Plan Act.

The AHCP is now open for Section One applications. Eligible applicants for the AHCP include broadband infrastructure owners, broadband infrastructure builders, internet service providers (ISPs) and managed service providers. Participation in the AHCP is a two-step process. If an applicant wishes to participate in the AHCP, it must apply for both Section One and Section Two. In Section One, companies will submit applications providing information including the applicant’s organizational capacity, broadband service quality, geographic areas of interest, and minimum and maximum number of units the applicant can serve. After approval of its Section One application, an applicant will be informed of available property portfolios. Then, in Section Two, an applicant will provide property-specific deployment proposals and business plans for each property it is interested in serving. In a Section Two application, an applicant must provide service inside each residential unit. The CAO will score both Section One and Section Two applications and base awards on a combination of those scores. Eligible applicants must use New York State’s Consolidated Funding Application (CFA) platform to create profiles and submit applications: The CAO will begin reviewing Section One applications after February 16, 2024. Eligible applicants should submit their Section One applications before February 16, 2024, if they want to have the opportunity to view and apply to all property portfolios in their geographic areas of interest. The CAO expects to release initial property portfolios in March 2024. It is important to note that some basic form of building access agreement between the ISP and owner/manager will probably need to be agreed to as part of this deployment.

The CAO will prioritize projects capable of delivering 1/1 Gbps and those that involve a pathway to public ownership or control of the wireless assets by the CAO or other public entities. The CAO is also prioritizing metropolitan areas, however, eligible properties outside of metropolitan areas may be included in property portfolios. A few notable requirements for AHCP projects are that AHCP projects must facilitate open access networks and that projects already receiving funding from other federal or state sources (such as the Broadband, Equity, Access, and Deployment program) are not eligible for AHCP funding for the same activity.4 The CAO’s targeted completion date for all AHCP projects is December 31, 2026.

Additional Assistance

For further assistance, please contact a member of our Telecommunications Practice Team or the Phillips Lytle attorney with whom you have a relationship.

1   See ConnectALL Affordable Housing Connectivity Program, (last visited Jan. 9, 2024).

2   Some notable requirements for AHCP proposal include participation in the federal Affordable Connectivity Program (ACP), reliably delivering service that is or is scalable to a minimum of 100/100 Mbps, and committing to five years of service. Additional requirements for applicants and proposals may be reviewed in the Grant Program Guidelines: ConnectALL, Grant Program Guidelines New York State’s Affordable Housing Connectivity Program (AHCP) (Apr. 2023), The ACP is a federal program that offers monthly subsidies to help low-income households pay for home internet. Unless more money is added to the program, it will likely expire at some point during 2024. See Joe Supan, The ACP Helps Millions Afford Internet. It Could Be Gone by Next Year, CNET (Dec. 4, 2023, 2:26 PM),

3   See ConnectALL Grant Program Guidelines: New York State’s Affordable Housing Connectivity Program (AHCP), (Apr. 2023) (April 2023).

4   See ConnectALL, Affordable Housing Connectivity Program Request for Applications, at 6. (updated Dec. 21, 2023),

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