Commissioner O'Rielly Letter to RUS Administrator Chad Rupe Re: Second Round of ReConnect Program

As you are aware, I have been closely following all federal broadband funding programs, including the ReConnect Program’s grant and loan disbursements, to ensure that funds are distributed as efficiently as possible and directed foremost to those communities lacking any broadband service, rather than those areas already served by an existing provider. To that end, I have voiced concerns to the Rural Utilities Service (RUS) over the use of scarce ReConnect Program funding to overbuild existing networks, whether built through private investment or via government subsidies.

Among the more troubling aspects of the second round’s framework are (1) the decision to lower the threshold at which an area must be unserved to be eligible for a 100 percent grant from 100 percent unserved to 90 percent unserved; (2) a lack of consistent and transparent practices governing the challenge process; (3) the absence of comprehensive measures to exclude from eligibility areas already subject to enforceable deployment obligations; and (4) the decision to disproportionately favor fiber technology in the application scoring process. I would respectfully request that you consider these concerns, as further outlined below, and consider appropriate programmatic revisions as you move toward awarding further funding or designing future ReConnect Program rounds.