Fix the RDOF now

Recently, the Federal Communications Commission received a letter from members of Congress urging it to use the Rural Digital Opportunity Fund long-form application process to ensure that winning bidders are capable of meeting their obligations. To honor Congressional intent, safeguard the public’s money and deliver necessary services to rural America, I suggest the FCC should:

1. Require financial projections that include the number of fiber miles to be constructed each year.
2. Require documentary evidence that backs up the projections of construction costs.
3. Require that the applicant has designed, built and/or managed fiber construction in the past year or two years that is within 50% of the pace of construction for the projected first three years. The pace of the first three years' construction must meet the RDOF 40% service milestone.
4. As an alternative to number 3, the applicant could provide a complete network design for the first three years' construction, by which the Commission would be able to measure future construction progress.
5. Require a commitment from fiber manufacturers and construction firms for the first year of construction with documentary evidence that the material costs and unit labor costs are consistent with the financial protections.
6. At the end of the first year after receiving funds, and the second year after receiving funds, require that the actual construction is consistent with the pace of the financial projections.