A team of organizations interested in promoting better broadband to everyone (led by the Institute for Local Self Reliance) has submitted comments to the FCC regarding the competitive bidding procedures for the Connect America Fund.

Here is an outline of their comments:

Summary – We believe rural America will be best served by additional safeguards to ensure Connect America Funds return the greatest investment to local residents and businesses.

Concerns:

Carriers of Last Resort Guarantee – It is imperative that bidders are able to serve every premise within the relevant blocks, with the possible exception of premises that are not connected to the electric power grid.

Satellite Service & Other Technologies – We continue to have strong concerns about the Commission subsidizing high-latency satellite services that have never achieved any market success.

Distribution of funds – We agree with the proposal of the Pennsylvania Public Utility Commission and the Pennsylvania Department of Community and Economic Development regarding a check box for entities that have received support from states for broadband investment: “The Commission should direct an applicant submitting a pre-auction short-form application to include in its application whether it has received any additional resources through the state for broadband deployment. The addition of a simple ‘check box’ for this query in the short-form application proposed by the Commission is all that is necessary.”

Financial Health of Applicants – We agree with the Commission and others that the financial health of potential bidders is important but are concerned that the Commission has not developed an accurate measurement for such health that does not discriminate against smaller providers.

Small Providers & Anti-Collusion rules – We agree with the Rural Coalition comments regarding the importance of smaller providers participating in this auction in order for it to succeed and indeed in order to ensure rural communities are well connected, “Thus, it is essential that the Commission at every turn consider ways to simplify the Auction design in a manner that will enable small businesses to participate meaningfully without undermining the process by which support can be distributed at efficient levels.”14 We are concerned that the Commission has historically shaped rules to fit with the largest carriers, many of whom are much more focused on investing in urban areas than rural regions.

Organizations sending the comments include: Institute for Local Self-Reliance (ILSR), Public Knowledge (PK), Appalshop, Center for Rural Strategies, Access Humboldt, National Digital Inclusion Alliance, Virginia Rural Health Association (VRHA), Southern California Tribal Chairmen’s Association (SCTCA), Broadband Alliance of Mendocino County, California Center for Rural Policy, Access Sonoma Broadband (ASB) and The Utility Reform Networks (TURN).