Comments of The Public Interest Spectrum Coalition on BTOP Grant Criteria

The NTIA has been presented with an extraordinary opportunity to improve access to, encourage competition among and increase the speed, affordability and openness of broadband services. Recognizing the transformative effect that broadband services can have in communities and the potential for such services to promote economic activity, civic discourse and innovation, Congress crafted a set of broadband initiatives that would promote the use of broadband while ensuring, though a set of public interest conditions, that taxpayers would receive a long-term return on their investment. PISC urges the NTIA to ensure that these conditions are met and enforced and to utilize the funds allocated by the Stimulus Act to make a meaningful impact in the lives of Americans in unserved and underserved areas. As such, PISC proposes the following:

• That the role of states in the grant and loan selection process be limited, so as to preserve transparency and reduce delay in the grant allocation process.

• That the grant selection criteria echo the guiding principles of the BTOP program, by prioritizing projects that hold the greatest potential to meaningfully affect the impact of broadband in unserved and underserved communities, projects that promote the deployment of infrastructure that will remain viable in the long-term and projects proposed by entities that serve the public interest.

• That the NTIA establish a $25 million "small entities" fund to provide small entities with grants and loans for programs that are consistent with the goals of BTOP and should reach out to these entities so as to encourage their participation.

• That investments in broadband mapping promote a more sophisticated and nuanced understanding of the state, current deployment and potential of broadband services in the United States, by collecting and displaying data regarding the speed, price and availability of wired and wireless broadband services, as well as information about the availability and use of public spectrum and broadband infrastructure and the success and impact of the BTOP broadband initiatives.

• That the NTIA enforce conditions that require grantees to operate networks that are open, interconnected and nondiscriminatory, so as to ensure the long-term viability of taxpayer-funded networks.

• That the NTIA or the FCC consider invoking a rulemaking to pre-empt nonphysical impediments (State laws, acceptable use policies, contracts, local agreements, etc.) that may preclude entities from applying for grants and loans in order to provide a service consistent with the purposes of BTOP. By following the above suggestions, the NTIA can ensure that taxpayer money is wisely spent, that the public interest is well served and that broadband connectivity has a meaningful, positive impact in the lives of Americans.

To read the full comments, please dowload the attached PDF below.