Commissioner O'Rielly Letter to RUS re: Broadband e-Connectivity Pilot Program

The Rural Utilities Service has sought comment on identifying rural areas eligible for funding, and specifically, how to evaluate whether an area already has "sufficient access" to broadband, and how to very broadband availability data in a proposed service area. In response to this Notice of Inquiry, I respectfully offer some guidance based on my experience from working on the Federal Communications Commission's efforts to connect rural and remote parts of the country. 

• Focus on truly unserved populations in defining "sufficient access". Subsidizing buildout in areas where one or multiple providers already offers service is an ineffective use of limited resources and moreover undermine parties' incentives to invest in broadband buildout in the future. "Sufficient access" should be determined from a technology-neutral point of view, and there should be no restrictions that would favor or disfavor a certain type of service offering. 
• Prevent funding recipients from cherry-picking locations. 
• Exclude areas funded by other agencies. To avoid duplication among federal efforts and protect the FCC's Connect America Fund investment, it is imperative that the RUS work with the FCC to identify those areas already receiving Universal Service Fund dollars and exclude those areas from pilot program funding.