JSI submitted reply comments in response to the Wireline Competition Bureau’s February 4, 2015 Public Notice seeking comment more generally on bank eligibility requirements for the Connect America Fund (CAF) Phase II competitive bidding process.

One of the more concerning and daunting elements of the CAF Phase II competitive bidding process for small providers, as proposed, is the irrevocable Letter of Credit (LOC) requirements if they are similar to those in the Rural Broadband Experiments (RBE). JSI is well-situated to provide input on the CAF Phase II competitive bidding requirements; it assisted rural communications providers with the RBEs, some of which have been provisionally-selected entities that have completed a lengthy and resource-intensive process of obtaining LOC commitment letters and await the next step of finalizing and submitting their LOCs to the Federal Communications Commission (FCC). As such, JSI hereby provides the following reply comments on bank eligibility and LOC issues with the CAF Phase II competitive bidding process as well as lends support for previously-filed comments by USTelecom, CoBank and NTCA – The Rural Broadband Association.