November 30, 2009 - NTCA Recommends Changes to Second Broadband NOFA
Suggests NTIA/RUS Postpone Next Round to Provide Time to Fix Flaws
Arlington, Va., November 30, 2009 - In response to a request from the Rural Utilities Service (RUS) and the National Telecommunications Information Agency (NTIA) regarding revisions to the broadband NOFA, the National Telecommunications Cooperative Association (NTCA) urged the postponement of the second NOFA to March 2010, to provide the agencies more time to investigate and rectify the known flaws associated with the first NOFA and ensure it meets in the agencies' objectives.
In the comments NTCA cited specific concerns with the first NOFA, particularly regarding the scoring system for the RUS's Broadband Initiatives Program (BIP), and proposed modifications to the second NOFA, including:
- Modify the point system relating to the proportion of rural residents served in unserved areas. The criterion awarding points for each 10,000 unserved households should be dropped and points should be reallocated to Rural Area Targeting, based on the percent of the rural area that is unserved.
- Reconsider the definition of "Remote Rural Areas" and establish the remote threshold at 25 miles, which would prevent the scoring of a proposal to service an area 40 miles from the nearest town the same as a proposal to serve an area just five miles from a town. Applicants seeking to serve an area within a 25 mile radius of a town could also receive points by demonstrating that the areas is "remote" due to terrain, density, demographics or other factors.
- Revise the awarding of equal points for 20 Mbps wireline and 2 Mbps wireless projects to 10 points for 20 Mbps projects five points for 2 Mbps projects, since 20 Mbps is vastly superior to 2 Mbps from a capability perspective.
- Revise the system providing equal weighting to last mile and middle mile projects to make middle mile projects eligible for five points and last mile projects eligible for 10 points.
- As a surrogate for the sustainability criterion in the award scoring system, points should be awarded for presence and longevity in the targeted rural areas, with five points awarded to proposals from companies with continuous service to a targeted area for more than 25 years.
NTCA also recommended that NTIA and RUS improve access to census block/ group/ tract data from funding applications to improve the efficiency of the process for reviewing and filing objectives to funding requests. The association also supports any steps the agencies can take to simplify the application process and subsequent reporting and auditing requirements, without compromising oversight or fraud prevention.
The National Telecommunications Cooperative Association is the premier association representing more than 560 locally owned and controlled telecommunications cooperatives and commercial companies throughout rural and small-town America. NTCA provides its members with legislative, regulatory and industry representation; meetings; publications and educational programs; and an array of employee benefit programs. Visit us at www.ntca.org.