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ACA: Weighting Of CAF Bids Must Be Based Upon The Statute, A Methodology And Data

‘Reasonable Comparability’ And An ‘Evolving Level Of Service’ Should Guide Agency’s Final Decision

PITTSBURGH, August 8, 2016 -  In reply comments, the American Cable Association said the Federal Communications Commission's effort to develop a weighting system for the Connect America Fund Phase II competitive bidding program must have a sound statutory foundation and any weighting factors need to emanate from that basis, be based upon a methodology, and be quantified based on market data.

"The FCC should weight bids based on the statutory requirement that consumers in eligible areas receive reasonably comparable service to urban consumer preferences for broadband Internet access services over the 10-year timeframe of the program and that, to maximize participation, the deployment cost of bids in different performance tiers be normalized.  Both of these factors can be determined using a methodology based on market data and are quantifiable," ACA President and CEO Matthew M. Polka said.

Unfortunately, many parties submitted comments proposing a weighting system that strayed from the statute's ‘reasonable comparability' requirement.  Instead, these commenters tended to emphasize the need to maximize the number of locations served within the budget, but, as ACA believes, not only does this approach downplay the statute, but it discourages many parties from participating in the auction, thereby limiting the cost-effective distribution of support.  ACA said that many parties proposed weights without any effort to link them to the statute, a methodology, or actual data.  The FCC cannot adopt such weights because they are arbitrary and will skew the competitive bidding process.

ACA also stressed that the weighting methodology should normalize costs among assumed technologies for each performance tier to maximize participation and to reflect consumer broadband preferences.  ACA proposed that to maximize participation and reflect consumer preferences, weighting should account for the significant differences in costs for deploying different network technologies in different geographies among the performance tiers.

About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing nearly 750 smaller and medium-sized, independent cable companies who provide broadband services for nearly 7 million cable subscribers primarily located in rural and smaller suburban markets across America.  Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business.  For more information, visit http://www.americancable.org/

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