I filed reply comments today regarding the California Public Utilities Commission’s (CPUC) review of eligibility requirements for construction subsidies from the California Advanced Services Fund (CASF). The first round of comments were reasonably evenly split between the ayes and the nays. My comments put me in the yes camp too.
To baldly go.
In particular, I took issue with the cable television lobby, the California Cable and Telecommunications Association (CCTA). What they want is to allow existing telecoms companies to be able to get funding for any eligible area under normal rules, but put ridiculous restrictions on local governments, independent ISPs and other non-traditional broadband providers. Ridiculous to the point that it gives lie to their poker-faced claim to support eligibility expansion.
As I put it in my comments to the Commission…
Combined with its assertion of non-opposition to the Commission’s contemplated expansion of eligibility, CCTA’s proposal is baldy disingenuous.
I also chimed in on the value of what’s called a Certificate of Public Convenience and Necessity (CPCN). If you have one (or the mobile telephone equivalent, a WIR) then you’ve been officially blessed as a telephone company by the Commission. It confers certain privileges, for example it greases the skids if you want to attach your lines to someone else’s poles, but it also comes with some pretty stringent oversight from the CPUC.
When it considers opening up CASF grants and loans to other types of service providers, the Commission should also take a look at the CPCN itself.
My recommendations are…
- Insofar as non CPCN/WIR holders are eligible for CASF funding, they should have equal access to underserved and unserved areas alike, and face no greater restrictions in that regard than traditional applicants.
- Publicly owned public utilities should be given the same eligibility as and face no greater constraints than CPCN and WIR holders in applying for CASF funding.
- If the Commission decides not to generally expand CASF eligibility to all non CPCN/WIR holders, it should consider specific eligibility for bona fide publicly owned public utilities.
- The scope of the rulemaking should be expanded to consider the various requirements and classes of CPCN eligibility, either in conjunction with the expansion of CASF eligibility or as an alternative.
Other organizations – seven at last count – have also filed reply comments and more might come in. I’ll update those tomorrow.