should allow for a new level of transparency such that areas where CAF II providers do not commit to build out can be reclassified as eligible. CETF has made expedited review part of a preferred scenario but only if the CAF II applicant has shared all its CAF II build plans in the interests of transparency. CETF suggests that expedited review may be an opportunity to provide an incentive for transparency about what will be built to make CASFeligible any areas that the incumbent CAF II provider is not going to upgrade. Race disagrees with allowing CAF II providers expedited review for supplemental CASF grants to expand CAF IIrelated projects. Race contends that every CASF applicant should go through the same submission and challenge process, unless it is determined to be a priority area after a proper convening of the Regional Consortia, stakeholders, providers and local governments. AT&T believes that if the Commission wants to incent CAF providers to build beyond their CAF II commitments to the FCC, the best way to do that is to make participation in the CASF program as attractive as possible, including by adopting the proposals made by AT&T, such as 100 percent funding of amounts requested for projects, a streamlined application process based on a single definitive list of eligible census blocks, reduced reporting requirements (especially when the per household funding amounts requested are below Staff’s proposed thresholds), and monthly payments during projects. This framework allows all providers—whether they participate in CAF II or not—to make rational business decisions on whether to apply for CASF. CAF II providers should be subject to the same application process as all other applicants.
should allow for a new level of transparency such that areas where CAF II providers do not commit to build out can be reclassified as eligible. CETF has made expedited review part of a preferred scenario but only if the CAF II applicant has shared all its CAF II build plans in the interests of transparency. CETF suggests that expedited review may be an opportunity to provide an incentive for transparency about what will be built to make CASFeligible any areas that the incumbent CAF II provider is not going to upgrade. Race disagrees with allowing CAF II providers expedited review for supplemental CASF grants to expand CAF IIrelated projects. Race contends that every CASF applicant should go through the same submission and challenge process, unless it is determined to be a priority area after a proper convening of the Regional Consortia, stakeholders, providers and local governments. AT&T believes that if the Commission wants to incent CAF providers to build beyond their CAF II commitments to the FCC, the best way to do that is to make participation in the CASF program as attractive as possible, including by adopting the proposals made by AT&T, such as 100 percent funding of amounts requested for projects, a streamlined application process based on a single definitive list of eligible census blocks, reduced reporting requirements (especially when the per household funding amounts requested are below Staff’s proposed thresholds), and monthly payments during projects. This framework allows all providers—whether they participate in CAF II or not—to make rational business decisions on whether to apply for CASF. CAF II providers should be subject to the same application process as all other applicants.