This morning, the National Telecommunications and Information Administration (NTIA) issued guidance setting out four alternatives to the Broadband Equity, Access, and Deployment (BEAD) program’s requirement that broadband providers seeking funding obtain an irrevocable letter of credit of 25% of the award amount, issued by a Weiss bank with a B- rating or above. Flexible alternatives to the NTIA’s letter of credit requirement were urged by nearly every sector of the broadband market, and was raised most publicly by this letter from nearly 300 signatories representing small, minority and female owned and publicly owned broadband networks. These signatories, including the American Association for Public Broadband, argued that NTIA’s original letter of credit requirement, coupled with the 25% match requirement, was an insurmountable hurdle for these providers, who are best positioned to close the digital divide.

The following statement should be attributed to Gigi Sohn, Executive Director of the American Association for Public Broadband.

We spoke and NTIA listened. AAPB applauds the NTIA for its guidance on alternatives to the BEAD letter of credit requirement. The guidance provides greater flexibility for smaller, minority and female owned and public broadband providers and allows them to participate in a program that is critical to ensuring that every US household has robust and affordable broadband.

AAPB appreciates NTIA’s assurance that it will “continue to monitor the implementation of this requirement and may provide additional guidance as needed.” Publicly owned broadband networks – and many of the private ISPs they partner with – face unique challenges that warrant more flexibility. NTIA acknowledges as much in its Notice of Funding Opportunity, when it says that it will offer additional guidance regarding “acceptable comparable evidence in support of financial capabilities” for “prospective subgrantees that have the ability to issue public bonds (i.e., municipalities). “

We thank NTIA and the Commerce Department and its leadership for their responsiveness to our call, their sense of urgency and their openness to future guidance. They are a model for good governance and good policy.

The American Association for Public Broadband works to promote and defend publicly owned broadband networks and seeks to ensure that they have fair access to state and federal funding. Gigi Sohn can be reached at and 202-253-0876.

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