HomeMy WebLinkAboutSigned WSBO LetterKittitas County, Washington
BOARD OF COUNTY COMMISSIONERS
District One
Cory Wright
October 4,2022
Mr. Mark Vasconi
Director, Washington State Broadband Office
Washington State Department of Commerce
l01l Plum St SE
Olympia, WA 98504
VIA ELECTRONIC MAIL
mark. vasconi@commerce.wa. gov
District Two
LauraOsiadacz
District Three
Breft Wachsmith
RE: Kittitas County Comments on Fall2022 Round 2 Accelerator Grants Notice of
Funding Opportunity (NOFO)
Dear Mr. Vasconi
Thank you for the opportunity to respond to WSBO's Seotember 15-2022,Call for Comments.
addressing considerations in the scoring criteria for the Fall2022 NoFo.
Kittitas County did not apply for any funding in the first round of Accelerator Grant awards as
a study was underway at that time to fully assess countywide unserved and underserved areas.
However, the county does intend to apply in the second round. Additionally, Kittitas County
received $3.8 million of Public Works Board grant funding to build two projects serving current
unserved areas and has been working with private providers to partner on the design and build
of these networks along with potential future projects.
Given the delay of release from April to now November 2022 and discussion of potential rule
changes in the upcoming NOFO, private partners have understandably been reticent to commit
to any agreements without a clear understanding of the final rules. Our timeline to secure a
partnership for current PWB funding, as well as future builds to potentially be funded by
Accelerator and other grants, was set back significantly as supply chain issues and inflationary
costs accrued throughout the industry. While we are confident that an agreement is rapidly
closing with our potential partner, changing rules between the first and second round of critical
broadband grant funding has brought uncertainty and, with it, additional costs that will result in
contraction of potential projects and ultimate reduction of broadband service to unserved homes
and anchor institutions.
As a future applicant of the Acceleration Grant funding, we support the following criteria of
future grant monies administered by WSBO:
Kittitas County Courthouse . 205 West 5h Avenue, STE 108 . Ellensburg , W A 9g926
(s09) 962-7 s08 .F AX (s09) 962_7 679
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 l0%o 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 ofthe
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).
Kittitas County Courthouse . 205 West 5fr Avenue, STE 108 . Ellensburg , W A 98926
(s09)962-7s08 FAx (s09) 962_7679
Checklist Considerations
We would support a checklist of considerations for grant applications only if this remained
voluntary and had no bearing on an applicant's score. Some of the checklist examples given in
the Call for Comments (pole attachment costs, a survey of poles along the proposed project,
make ready considerations, etc.) could pose significant cost to public entities. Given that many
parts ofthe state are served by private utility providers, access to this proprietary data is not
guaranteed and would have to be confirmed at significant cost and/or personnel hours as was
the case in preparation of past Kittitas County project parameters. In addition, this data has a
shelf life, and it may be rendered useless before the grant project receives WSBO funding.
on behalf of Kittitas County, thank you for again for the opportunity to comment.
S
District One Two
Brett
District Three
Kittitas County Courthouse 205 West snAvenue, STE 108 . Ellensburg,WA 99926
(s09)962_7s08 .FAX (509) 962_7679