Amount of Funding, ILEC Priority, Are Subject of Rural Broadband Experiment Reply Comments

Of the 1,000 expressions of interest filed, more than 200 came from utilities and their partners, the Utilities Telecom Council said (http://bit.ly/Rmb3DY). “This overwhelming response clearly answers the question whether there are others besides incumbent price cap carriers and rural LECs that are interested in providing rural broadband,” it said. UTC urged the commission to budget more than the $50 million-$100 million contemplated in the Further NPRM. Otherwise, it said, “the Commission will have wasted the opportunity to achieve real change.” With their extensive infrastructure already in place, utilities are “uniquely positioned” to promote rural broadband, the council said. The commission shouldn’t give incumbents a right of first refusal, or exclude partially served areas from the experiments, it said. The commission should also seek local input, “taking the selection process to the people in these rural communities,” it said.

Incumbents argued they should get a right-of-first-refusal. Rural, rate-of-return LECs have demonstrated their “sustained commitment to serving high-cost rural areas of the nation,” said NTCA, the National Exchange Carrier Association, the Eastern Rural Telecom Association and the Western Telecommunications Association (http://bit.ly/Rmowf4). “The Commission should leverage this experience and the demonstrated commitment of RLECs, as well as their existing networks in nearby locations, to deploy sustainable broadband to hard-to-reach, unserved and underserved rural locations as quickly and effectively as possible,” the groups said. They asked for “a window” for rural LECs to get fast-track approval of proposed experiments within their incumbent study areas. Generally, though, the commission shouldn’t let the broadband experiments “become a distraction from the larger task” of creating a broadband-focused CAF mechanism to accelerate broadband deployment on a much larger basis, they said. The experiments “may yield interesting results that could inform future policy decisions,” but the FCC should make “tailored, targeted updates” to existing USF mechanisms its “top priority.”

Incumbent LECs “lack the Commission’s vision,” the American Cable Association said (http://bit.ly/RmsCns). In urging the commission to “rein in its ambitions for these experiments,” ILECs are missing a key agency goal of experiments, ACA said, namely “to determine whether it can bring higher-performance broadband to rural customers and do so by using less support.” To encourage participation, the commission should streamline the eligible telecom carrier designation process, ACA said. Right now it’s a “major barrier to participation” for ACA’s members. State public utility commissions may oppose ETC designation streamlining, ACA said, but “given that the Commission intends to vet the financial and operational capabilities of any applicant and impose strict performance requirements, the number of issues remaining where state review would have some value are very limited.”

The rural broadband experiment program deserves “robust” funding, the Wireless ISP Association (WISPA) said (http://bit.ly/1qYM5Vr). WISPA advocated “technology neutral eligibility and project selection rules,” using cost-effectiveness as the most important selection criteria for fixed wireless applications. It’s important not to adopt program rules that will “promote unfair and unwarranted favoritism toward projects employing one particular technology,” it said. WISPA also backed more than $100 million to support the experiments, arguing putting more money toward experiments will “increase the likelihood that successful solutions will be identified.” The program shouldn’t fund experiments in areas that are already well-served, WISPA said, or favor applicants that propose “ultra-high-speed” broadband services. “Applications who desire funding for rural gigabit network deployment can participate in the USDA’s Rural Gigabit Network Pilot Program as authorized by the 2014 Farm Bill,” WISPA said.

The Rural Independent Competitive Alliance pushed for all unallocated funds to be available for the experiments, rather than just $50 million-$100 million. “An arbitrary limit on a percentage of the available funds before the Commission has even seen concrete proposals would not serve the public interest,” RICA said (http://bit.ly/1gCDR41). Several parties agreed with RICA that the model the commission will use to allocate support to price cap carriers is “not valid” for rate-of-return carriers, the association said. Cost effectiveness shouldn’t be the primary criterion for evaluating proposals “because nothing would be learned about serving more high cost areas,” RICA said. “A perverse incentive to design to the lowest ‘first cost’ would prevent achievement of the stated objectives of robustness and scalability.”

The Fiber to the Home Council suggested the commission evaluate proposals “as if they were business plans.” Cost-effectiveness and the “overall reasonableness of the business case,” along with how well the experiment could deploy robust and scalable networks, should make up the bulk of the criteria for the agency to use when judging applications, FTTH Council said (http://bit.ly/RmMFlF). A budget of $50 million-$100 million is enough to support 20-30 experiments “representing a variety of business models in areas with a real diversity of geographic and demographic characteristics,” it said.