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Kittitas County Courthouse · 205 West 5th Avenue, STE 108 · Ellensburg, WA 98926 (509) 962-7508 ·FAX (509) 962-7679 Open Access Networks Open-access, non-discriminatory networks offer the best model for achieving competitive pricing and services for previously unserved and underserved communities across Washington State. All internet service providers have an opportunity to compete and offer services over a non-discriminatory system, and customers have choices when it comes to selecting the best internet service for their household. We have seen the repeated success of open-access networks expanding broadband access in counties, cities and Tribes across the state and wish to ensure Kittitas County consumers have access to a competitive marketplace when choosing a broadband service. For this reason, we support WSBO requiring an open-access network in its threshold criteria. Unfortunately, closed systems will not accomplish Washington’s state broadband goals, nor will a monopoly bring to market competitive pricing and services for the communities most in need of broadband. Matching Contributions WSBO’s current policy regarding matching contributions and considerations of financial need successfully ensures that applicants with limited budgets may participate in the Acceleration Grant Program. Therefore, we support retaining WSBO’s 10% matching contribution requirement and policy to waive this requirement in cases of demonstrable financial need. This ensures fairness and equity, while prioritizing projects with matching contributions that will effectively extend grant dollars further in pursuit serving the broadest area possible. Digital Equity Considerations and Low-Income Support While we do not believe WSBO should introduce new scoring criteria midway between grant rounds, we do support WSBO considering digital equity factors in applicants’ projects. All public funding for broadband in Washington State should help facilitate digital equity and inclusion and require low-income pricing options. Digital equity prioritization should be based on readily available statistics, such as the number of students receiving free or reduced school lunches within a community. Low-income pricing options should be a required threshold criterion, as in the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program of the American Rescue Plan, which requires internet service providers to participate in the FCC Affordable Connectivity Program or a similar affordability program for low-income consumers. Challenge Process We support a challenge process that requires challengers to meet or exceed the required broadband speeds of 100/Mbps or higher to ensure communities will truly be served. Challengers should also be required to demonstrate current provision or active construction in the project area, to include a construction completion date on or before the grant requirements. We also request that WSBO enforce its policy around unsubstantiated claims as written in the 2021-2014 Infrastructure Program Guidelines published on November 9, 2021. As you know, the policy prevents any challengers whose claims were deemed unsubstantiated from challenging future projects for the next two funding rounds by WSBO. Last Mile Definition We support the last mile definition given in RCW 43.330.530(5).