The American Cable Association ("ACA") urges NTIA and RUS to do the following in distributing and administering broadband stimulus funds under the BTOP:

• Apportion funds to both "unserved" and "underserved" areas, and not prioritize the allocation of grants and loans to one of these areas over the other;
• Determine that eligible applicants include any entity that has provided reliable cable, phone, or broadband Internet service in the United States or its territories within the last three years;
• Define "unserved" and "underserved" areas as being a Census Tract in which at least 50% of the households do not have access to reliable broadband of 1.5 Mbps downstream and 128 Kbps upstream transmissions, and 5.0 Mbps and 500Kbps, respectively;
• Do not place non-discrimination obligations on grants awarded which are more stringent than those outlined by the FCC in its 2005 Broadband Policy Statement;
• Impose any non-discrimination and network interconnection obligations only on the infrastructure being funded with grant funds;
• In "underserved" areas, give priority to proposals that seek to invest in bringing high capacity "middle mile" infrastructure to an area over "last mile" infrastructure;
• In "unserved" areas, give equal weight to grant proposals that seek to invest in bringing both high capacity "middle mile" and "last mile" infrastructure to an area;
• Mandate that all applicants have available 20% of funds for a project, except that a smaller entity may be awarded a grant that is more than 80% of a project's cost based on certain criteria to assure adequate operational, technical, and financial experience;
• Streamline the application and grant process, and ensure that the applicant has the resources and expertise to operate the facilities for which funding is sought;
• Place grant application forms, instructions, pending applications, and award notices online;
• Avoid awarding redundant grants for overlapping service areas; and
• For smaller entities-existing video, broadband, or phone providers with 5,000 broadband subscribers or less-seeking grants below a threshold of $5 million, adopt and provide those applicants with a short-form application.