I. Introduction.

The American Cable Association submits these comments in response to the Commission’s Public Notice seeking suggestions regarding the substantive recommendations to be included in the Commission’s Report to Congress describing a comprehensive rural broadband strategy.

ACA members are uniquely positioned to help the government ensure access to advanced telecommunications and information services to all Americans, particularly in the rural areas where they already serve, and ACA welcomes the opportunity to assist the Commission in formulating a rural broadband strategy.

To that end, and in an effort to develop a comprehensive national broadband plan, ACA urges the Commission to recommend a rural broadband strategy that includes Federal grant and loan programs that allow operators serving small markets and rural areas to apply for and receive money for last-mile and middle-mile projects. The FCC should further recommend that these programs have an application process that (i) is streamlined for applicants who are small and medium-sized operators or those requesting relatively minimal funding; (ii) is open and transparent; and (iii) gives weight to existing entities that have financial, managerial, operational, and technical experience running broadband networks in smaller markets and rural areas.