December 4, 2019
VIA ELECTRONIC DELIVERY
Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
Rural Digital Opportunity Fund, WC Docket No. 19-126;
Connect America Fund, WC Docket No. 10-90
Dear Ms. Dortch:
On December 3, 2019, Melissa Slawson, General Counsel and V.P. of Government Affairs and Education for California Internet, L.P. dba GeoLinks (“GeoLinks”), and Elizabeth Bowles, President and CEO for Aristotle Unified Communications, LLC (“Aristotle”) met with Nicholas Degani, Senior Counsel for Chairman Pai.
During this meeting, GeoLinks and Aristotle provided details about the companies’ recent Connect America Fund Phase II Auction (“CAF”) awards. The companies provided information regarding their personal experiences with the CAF Letter of Credit requirement, the high costs associated with securing Letters of Credit, the financial constraints Letters of Credit can impose on smaller companies, and their concerns regarding the Commission’s proposal to require a Letter of Credit requirement for the forthcoming Rural Digital Opportunity Fund Auction (“RDOF”). Specifically, the companies explained how imposing a Letter of Credit requirement under RDOF will result in grant dollars that could be used for broadband network infrastructure instead being used for bank fees and other costs associated with obtaining and maintaining Letters of Credit.
The companies also offered information regarding adopting a performance bond requirement in lieu of a Letter of Credit requirement. The companies explained that performance bonds carry significantly lower costs than Letters of Credit while still serving to protect the Commission’s investment into the RDOF.
Pursuant to Section 1.1206(b) of the Commission’s rules, I am filing this letter electronically in the above referenced dockets. Please contact me directly with any questions.
/s/ Melissa Slawson
General Counsel and V.P. of Government Affairs and Education
cc: Nicholas Degani