JSI’s comments provide recommendations on the FCC’s intentions to conduct targeted funding experiments in both price cap and rate-of-return areas to bring advanced services to rural areas of the nation using next generation networks that are high-speed, scalable, IP-based and robust.
- First, JSI recommends that the FCC establish a budget for the experiments of $200 million based on the significant amount of letters received (over 1,000) and large demand for support that would encourage network investment. Committing $200 million would go far to satisfy the demand, select a wide range of experiments, and allow the Commission to retain at least $30 million unallocated in its reserve.
- Second, JSI argues that the Commission’s precondition that the only areas eligible for funding should be those areas lacking broadband is too narrow and restrictive. The experiments should address how to future-proof wireline networks with fiber facilities in the delivery of broadband that is high-speed, scalable and robust.
- Third, JSI addresses the issue of ETC designation and explains that the FCC’s proposed approach creates an unresolvable problem for state commissions.
- Fourth, JSI recommends that RLEC applications be evaluated and qualifying applicants be awarded prior to applications from other providers, subject to a challenge process.
- Finally, JSI comments on the selection criteria for the experiments, and makes several recommendations for evaluating applications based on robust, scalable networks.