[1st-mile-nm] Comments per FCC Rural Digital Opportunity Fund

[Mimbres Communications]

On Fri, Jan 31, 2020 at 12:38 PM Robert Jacobson <
robert.jacobson at atelier-tomorrow.com> wrote:

> My immediate response to the FCC's “Rural Digital Opportunity Fund”
> announcement yesterday?
>
> Just more pandering….
>

Yes -- but roughly what we expected, given the current makeup of the
Commission.



> Via CAF-2, the preceding FCC fund, two of the vendors serving a community
> in which I'm working — CenturyLink and Viasat — have each taken hundreds of
> millions of funding, yet for two years running haven't made good on their
> existing pledges of seriously extending broadband service.
>

An unfortunately familiar story in rural NM.



> Is there a reason that ths next round of funding won’t be more feathering
> of the ISPs’ nests?
>

Change that to "entrenched incumbent ISPs" and I'll agree with you.



> the FCC, by limiting distribution of the “new" funds only to communities
> with "no broadband service whatsoever,” means only one local customer with
> broadband, defined by the USDA as 10 mbps down and 1 mbps up, and by the
> FCC in this announcement as 25 mBps down,3 mbps up — neither of which 99%
> of the global internet community would consider “broadband” — will
> disqualify a community from receiving a grant.
>

IMO the biggest issue here is the rush to allocate money before the
November elections with no regard for efficiency or effectiveness.

Two FCC proceedings (WC Docket 19-195, *Establishing the Digital
Opportunity Data Collection* and WC Docket 11-10 *Modernizing the FCC Form
477 Data Program*) and a related NTIA RFC (Docket 180427421–8421–01, *Improving
the Quality and Accuracy of Broadband Availability Data*) have been working
their way through the system.  These would change both the way locations
are enumerated and whether they are considered serviceable, which will in
turn affect FCC, USDA, and a significant portion of state subsidy
programs.  A number of us filed comments requesting that RDOF money be
disbursed after the initial phases of that work were completed.  FCC
elected to move ahead (and move big) using the existing (hugely flawed)
Form 477 data.



> In short, this appears to be much adieu about nothing, just another FCC
> bone tossed to existing ISPs
>

RDOF mostly follows the lead of previous subsidy programs, which (via a
range of rules and requirements) effectively foreclose participation by the
majority of small, independent providers.  This is by design.  Look at the
players.
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