EXECUTIVE SUMMARY

ACA is uniquely positioned to assist NTIA and RUS in ensuring that broadband stimulus funds are distributed and administered in an efficient and effective manner.  ACA Members have a long history of bringing new and advanced services to rural areas, and are leading the way in deploying broadband to these areas.

In response to the first NOFA, at least 83 ACA members applied for broadband stimulus funding for 127 last-mile and middle-mile projects totaling more than $1.3 billion in grants and loans under the two programs.  More ACA members would have applied but for funding restrictions and cumbersome barriers in the first NOFA.  ACA suggests the following modifications to encourage greater participation from existing providers and to assure that the goals of the programs are met:

• Modify the 10 year no-sale prohibition;
• Eliminate the BIP mandatory loan requirement for Rural/Non-Remote Areas;
• Give rural applicants the option of applying for BTOP grants only;
• Provide flexibility to the BIP first lien rule;
• Reduce the BIP Program preference for past borrowers to 1 point and limit its application to loan and loan/grant comparisons only;
• Provide flexibility in using funds for tax impact purposes;
• Eliminate the penetration criteria from the "underserved" definition and focus only on speeds;
• Modify the Public Notice process by coordinating with the FCC and using FCC Form 477 and using other readily available information to determine where broadband is already available.