Transcript: Community Broadband Bits Episode 375

This is the transcript for episode 375 of the Community Broadband Bits podcast. In this episode, Christopher speaks with Carol Mattey about the Connect America Fund and how the Federal Communications Commission subsidizes broadband expansion. Listen to the episode, or read the transcript below.

 

 

Carol Mattey: What is necessary now is to push the FCC to come up with a comprehensive plan and not let up until it's done.

Lisa Gonzalez: Welcome to episode 375 of the Community Broadband Bits podcast from the Institute for Local Self-Reliance. I'm Lisa Gonzalez. Federal grant funding can make or break plans to deploy community broadband networks. Local governments, cooperatives, and Internet access companies all apply for funding when they find themselves eligible. We've had guests on the show in the past to discuss the Connect America Fund, also known as CAF, and the manner in which the FCC has chosen to determine which applicants receive awards. This week, we have a Connect America Fund expert on the show, consultant Carol Mattey. Why is she an expert in all things CAF? Because she is one of the people who initially developed the program. She's also worked on the national broadband plan. Carol talks about the broad goals of the Connect America Fund, and she reviews the process that has included the first two rounds of subsidy awards. Carol gives us some insight into the politics of CAF and the challenges the FCC has faced in developing the program. Christopher and Carol talk about the pros and cons of the program and what's next. Now here's Christopher with Carol Mattey, principal of Mattey Consulting.

Christopher Mitchell: Welcome to another episode of the Community Broadband Bits podcast. I'm Chris Mitchell with the Institute for Local Self-Reliance up in Minneapolis, Minnesota. Speaking today with Carol Mattey, the principal of Mattey Consulting. Welcome to the show.

Carol Mattey: Hello Chris and everyone who's listening.

Christopher Mitchell: I really appreciate you taking the time. I feel like you're someone who has a lot of knowledge about something that's very important in terms of connecting rural America, and the rest of us have, in many ways, been trying to figure it out. And so, I'm hoping to pick your brain a bit today and share that knowledge with folks and give a broader perspective of the Connect America Fund.

Carol Mattey: Sure. Happy to help.

Christopher Mitchell: Oh, I appreciate that. Let me ask you first — before you were the principal of Mattey Consulting, what were you doing at the Federal Communications Commission?

Carol Mattey: I was the deputy bureau chief in what's known as the wireline competition bureau. And in that role I basically supervised the team that developed the Connect America Fund, and also I worked on all of the other universal service programs that the FCC has. I had gone back to the FCC in 2009 and actually worked on the national broadband plan, the chapter that addressed broadband deployment, and then I stayed on at the FCC to work on implementing those recommendations.

Christopher Mitchell: And can you just give us a sense — what was life like before the Connect America Fund in terms of how did the Universal Service Fund work then?

Carol Mattey: Oh, well, I think it's — I first started working on universal service actually quite some time ago in 2000 and I did a prior tour at the FCC when I was the deputy bureau chief. And you know, I newly came into that role and had been working on local competition and other issues, and I vividly remember when the staff briefed me on what was known as the high cost program. And I remember just like scratching my head thinking this is the most complex, byzantine set of rules I've ever heard of. It was very complicated, a lot of rules that were, you know, what I call the product of a world that no longer exists today in terms of regulatory distinctions and sort of arcane things to do with cost separations and notions of interstate and intrastate and embedded subsidy flows that the FCC, over the course of 20 years after the '96 Act, had been working to basically make the subsidies explicit. You know, back in the day, way back when, it was basically AT&T, Ma Bell, had most of the country, and there were small telcos in the areas that Ma Bell didn't want to serve. A lot of this was just embedded into rates and intercarrier payments, and the idea of the Universal Service Fund is to make that funding go out the door in a more, you know, transparent way so that people would see what subsidies are being provided to the telcos.

Christopher Mitchell: I think that's a really interesting way of framing it because for a lot of us, we just think of it as modernization as having to do with, "Okay, now we're going to subsidize broadband rather than subsidizing telephone calls."

Carol Mattey: Right, right.

Christopher Mitchell: And so—

Carol Mattey: There's some legal reasons, and you know, I won't bore you with all the details, but part of the complication here is that the '96 Act speaks of universal service as an evolving level of telecommunications service. And, you know, while the FCC has sort of flip flopped over the years as to whether broadband is a telcom service or an information service, at the time we were doing these reforms, broadband was an information service. And so, you know, the FCC had to sort of thread the needle in terms of how it could support broadband networks, and to do so it had to tie it to the provision of voice service.

Christopher Mitchell: Right, and I think that's a very good point. And in our discussion of Connect America Fund, I don't think we're going to discuss that connection, although it is important and it remains there today. But I think we can let people know they can listen to perhaps a future podcast or just a different one.

Carol Mattey: Sure, sure. And I don't want to get into details of that. I want to, you know, I want to talk about the Connect America Fund.

Christopher Mitchell: Right, so let's talk about the Connect America Fund. So, when you were designing it you mentioned you wanted to make the subsidies more transparent, but more broadly, what were the goals of the Connect America Fund as you were drafting it?

Carol Mattey: Well, you know, big picture, it was to transform this existing program, which was just this mishmash of multiple different funding streams with no requirement to use the funding to deploy broadband. The idea was to transform it into a program that would explicitly make a broadband as the goal. And the goal was obviously to make broadband as universal as voice service is today, but we had a couple of additional specific goals. I mean, we wanted to create accountability for the companies that receive the funds with clear enforceable performance obligations, and we wanted to target the funds to the areas that the private sector isn't willing to serve without a subsidy, meaning no funding for areas with un-subsidized competitors. And we were hoping to transition to a more incentive-based approach with funding available for new technologies and non-incumbents that want to serve rural areas, and last but not least, we were trying to ensure that the funding was provided in an efficient way with no wasteful expenditures. Now, thinking on a lot of those issues evolved over time, but big picture, those were the goals that were motivating us.

Christopher Mitchell: And was there an additional goal ⁠— which I can't explain why I thought it was, but I think there was. And that has to do with the cost of the universal fund has been going up for so long. One of my impressions was that you were seeking a way that the federal government could ultimately lower the amount it would be paying over time by investing in technologies that would no longer require subsidies in the future.

Carol Mattey: There was language, certainly, in the broadband plan and in some of the FCC orders about potentially reducing the amount of subsidies that would be required, but you know, when the FCC originally created the Connect America Fund, it took the approach of saying, "Well, we're currently spending about $4.5 billion a year, and we're going to set the budget at $4.5 billion." But certainly the notion was that through competition and the introduction of new technologies, it would be possible to over time lower the cost of making universal service possible.

Christopher Mitchell: Now, I'm going to try and sum up rounds one and two, and then you're going to laugh and explain to everyone how ignorant I am of it. So we're kind of near the tail end of round two of the Connect America Fund. I think it's fair to say we're about to have major auctions for the ⁠— well, the third round, which has been renamed. But in rounds one and two effectively I think most of the money was reserved to go to first the companies that were already providing service in an area. As you mentioned, these are areas in which there's no competitor. And so, most of the money basically went to those areas, and if the provider, say AT&T or a small independent company, wanted the money, then they would receive it and there was certain obligations. If they didn't, then it went into a pool that was auctioned to entities that wanted to bid on it. Is that more or less how we've dealt with it thus far?

Carol Mattey: With one adjustment to what you said. Basically the FCC in 2011 created two tracks. One track is what you just described, but that track basically applied to the areas that were served by the largest companies, so specifically, AT&T and Windstream and Frontier and Consolidated and Verizon — and I might be forgetting one or two — and CenturyLink and Hawaii Telecom. So what you just described was, like, to offer the money and give the companies and opportunity to accept it, and if they turned down the money, the money would go up for auction. So that's what we think of as phase two of the Connect America Fund. There was a completely separate track for the small telcos, the small independents, and you know, the telco cooperatives. The FCC did a variety of things that impacted those companies, but basically, from a big picture perspective, there was a decision to keep them on the system that they already had been on with some nips and tucks along the way. And then subsequently, a number of years later in 2016, the FCC decided to offer more money to that group of companies in exchange for building more broadband. But the FCC has not, you know, imposed a regime where those smaller telcos' pot of money would be up for auction, by and large.

Christopher Mitchell: Okay. And I was actually just checking in with some of the Minnesota companies, and I think a lot of those are now what's called the ACAM approach, right?

Carol Mattey: Exactly. Yup, yup, yup. That's exactly right.

Christopher Mitchell: And I think they're required to build to 25/3 [Mbps] with the money, although nearly all of them seem to be building with fiber, so they're well exceeding the expectations.

Carol Mattey: Right, and that's a good thing. I mean, I think one of the things to keep in mind. When the FCC has set these minimums, the FCC's view was not that the company would just do the minimum and no more. You know, throughout this process, the FCC has ⁠— there's language in FCC orders saying we encourage companies receiving the money to build future-proof networks, and you know, we want them to do more. It's just they're not mandated to do more, and in fact, as you say, you know, a number of the companies that accepted ACAM are doing Fiber-to-the-Home. You know, from the FCC's perspective, that's a good thing.

Christopher Mitchell: I agree. And in some ways I have to say, like, I feel like the FCC has conducted an experiment in which the expectations of my organization, the Institute for Local Self-Reliance, have been pretty born out, which is that I feel that the largest companies have basically done the minimum amount to get the money, whereas I think the smaller independent companies and certainly specifically the cooperatives that we've seen have figured out how to stretch that money to do the most with it. Which is where you and I, I think, first met face to face at the Montana Telecom Association, you know, where I was saying that I thought the FCC had made a huge mistake in even allowing a companies like AT&T and CenturyLink to have access to this money. And so, you know, I'm curious now as we're looking back, do you think it makes sense to have started there?

Carol Mattey: Well, I think you have to understand the political context. Giving the right of first refusal to the large incumbent providers fundamentally was a political decision, and you know, back in 2011 the idea that you would just do a flash cut and eliminate the funding for the largest telcos completely and go straight to auction, it just wasn't going to happen. I mean, there was language in the broadband plan that suggested that that would be a good idea, but you know, the political reality was that that just wasn't possible when we actually worked on implementing it. And so, you know, while a lot of people have criticized the FCC, the way to think about it is that phase two program was in essence a six year transition. It's like the FCC said, "We're going to give you money for a specified amount of time and we're going to require you to do something, and then after that time period, then we're going to open it up to auction." And that was the mindset.

Christopher Mitchell: Well, I think, to argue against myself in a position that I quite like in terms of finding ways of not subsidizing AT&T as rapidly as possible and similar companies — I have to think that if I was the one making the decision and I decided to go in terms of just doing that flash cut, these are areas in which some of these large telephone companies have been looking to get out of anyway, and it could have given them an excuse to basically walk away from landline service even, potentially. That would've been devastating in these areas where people really count on that.

Carol Mattey: Yeah, I mean, they certainly have argued ⁠— you know, because there were some areas of the country where the FCC did cut off their fundin,g and they argued that that was unlawful. And in fact, they even took the FCC to court on that, and the FCC, you know, ultimately prevailed in that decision because the judge recognized that this was part of a long range multi-step plan to change the overall paradigm on how the subsidies were provided and the FCC got deference on that. But I mean, you're right. I mean, part of the problem is if you flash cut to something, there can be dislocations and you don't know how it's gonna turn out. Another thing to think about is, you know, it took the FCC literally from 2011 until 2018 to figure out how to do an auction. And if the FCC had just said, we're gonna cut off the money and go straight to auction, I am sure the auction would have happened sooner, but the point is the FCC had to go through a lot of processes even to figure out how to do an auction. I mean, this was the first major auction for universal service subsidies that, you know, has occurred in the United States, and there were a lot of arguments back and forth even about how you do that in the first place.

Christopher Mitchell: I want to come back to that in a second, but before we talk about the auction, what else did CAF get right and where do you think we might've made different decisions based on looking back now?

Carol Mattey: Well, I certainly think CAF got it right in terms of targeting the money to areas where there aren't un-subsidized competitors, and it got it right for setting, you know, clear deployment obligations. And I think, you know, CAF got it right and did a good job of encouraging companies to transition to a system with more certainty — you know, that's the ACAM program and the phase two auction. The notion that if you provide companies with certainty as to what their revenue flows will be for a 10 year period, that gives them the ability to do long range planning, borrow money if necessary to invest in the infrastructure you need. So I think, you know, all of those were good things. The auction itself, you know, I think the FCC did a good job of spurring competitive interest. And you know, there were a variety of different bidders in that phase two auction, and I think that was a success. But you know, in hindsight I can say the biggest mistake in my view was to be too timid in setting the performance standards for the companies receiving the money. You know, when the FCC first set up the Connect America Fund, it said that the standard for recipients of funding was to provide 4/1 [Mbps] and then it upped it to 10/1 [Mbps] before it handed out the money to the large carriers. And, you know, looking back now, I wish that the FCC had been a little bolder. You know, I think it was ⁠— part of the problem is the FCC has been too timid and too fearful of just sort of thinking about how you should be more forward looking on where the country's going to be down the road.

Christopher Mitchell: Yeah, just for a second — the political reality I assume must be challenging in the FCC because when you were making these decisions, at that time, the senators weren't railing on you for setting your sights too low. I wonder if you had a sense that there might be political backlash if you'd set your sights much higher, or is the concerns of senators who write letters less of an issue when you're figuring these things out in the bureaus? I don't really have a sense of that.

Carol Mattey: Well, I actually have no memory whatsoever of congress weighing in on what the definition of broadband should be. You know, that just wasn't really. . . You know, Congress wasn't really active on those issues back then, to my recollection. I mean, certainly in the last few years we've seen a lot more focus in Congress on the broadband maps and the fact that, you know, their constituents don't have service. But back in 2011, I don't really. . . You know, it's kinda funny. I don't really remember, you know, who was pushing for 4/1 [Mbps]. I mean, it was just like, you know, 4/1 [Mbps] was the recommendation in the broadband plan and honestly it just got adopted in the Connect America Fund without a lot of further thought to be honest.

Christopher Mitchell: Yes. Actually, someone was just in an email chain discussing that the national broadband plan basically called for a lot of the people — everyone living in cities effectively to have 100 megabit download and maybe 20 megabit upload or something like that and that rural areas would still have 4/1 [Mbps]. And so, 10/1 [Mbps] is even better than it was foreseen, but we, let's hope, can do a lot better than that. So, let's talk briefly about the auction specifically because I think that despite the fact that I would have liked to have seen some of the weights different to lead to more gigabit investment, I do think that the auctions, and specifically the transparency around the auctions, is one of the most laudatory ⁠— or one of the things that I would most praise this FCC under Chairman Pai for getting right.

Carol Mattey: I think the process of the auction worked very, very well. You know, I had been working on the auction rules up until the time I left the FCC in early 2017. And then obviously, you know, the administration changed and Chairman Pai made it a priority to get this done. And I have to, you know, say hats off to him for getting it done and for moving forward on these issues, and from all I can tell from a process standpoint, everything went beautifully.

Christopher Mitchell: And so I just recently saw some criticism that the reverse auctions hadn't been proven work from someone I hold in high regard in Maine, and I would say that that's not been my perspective. I think the auctions showed that not only is it a good way to distribute the money among many flawed ways of distributing money like this, but that I'm very comfortable arguing about the minutia around it but generally keeping this approach to do the $20 billion that'll go out in the next round.

Carol Mattey: Yeah. I mean, obviously there's a difference between was the auction a success and will it yield a success in terms of performance? I mean, we clearly know that the auction spurred a lot of competitive interest and new providers that have indicated they want to serve these areas and certainly with speeds far above the minimum that the FCC set for the auction. Now obviously, we're going to have to wait and see. Like anything in life, you know, it isn't over 'til it's over, and you've got to see how it all plays out. And so, you know, there could be situations where some of the winning bidders don't perform, but that's no different than anything else in life. I mean, even if it is the case that in some specific instances a particular provider, you know, fails to perform or meet the obligations that it is agreed to in the auction, that doesn't mean the auction was a failure because I'm expecting, by and large, most of those winning bidders will actually deliver what they said they were going to do.

Christopher Mitchell: Yes. I think that that's what I would expect. Also, one of the criticisms that I've had — I'm curious how you would respond to it — is that in the years that you were working on this, we knew that there was, for instance, the cooperatives of North Dakota and a number of other independents, particularly I would say in Illinois but in the Midwest generally — we saw a lot of them really doing the hard work of figuring out how to invest. And I felt like they got passed over a bit when it came to this money because they had already done their job, which to me seems like a missed opportunity because if anything we would want to, I would think, figure out how to reward companies that had proven they knew how to invest in rural America, and it seemed like that wasn't something that was really possible until we got to the auction phases. And I'm just curious ⁠— I think you're working with a number of these sort of companies now, and I'm just curious how you respond to that.

Carol Mattey: Well, I think part of it is you have to go back to the fact that the FCC created an overall budget. And you know, as I said earlier in this podcast, the FCC decided back in 2011 it was gonna set a budget of $4.5 billion total, and it recognized that, you know, the geographic areas where the price cap carriers operate, there was by and large a woeful lack of investment there and it was trying to dedicate more money to those areas. And I want to emphasize, we're talking about the areas, not the companies. I mean, the mindset was the consumers in those areas don't have service and we need to figure out a way to channel more dollars to those geographic areas, but because of that finite budget, it's a zero sum game. If you're providing more money to one part of the country, by definition that means there's less available on the other side. You know, the FCC went through various machinations of the policies that it would implement for the smaller carriers, like those cooperatives that you mentioned. Ultimately, you know, it's gotten back on course and has done some reforms and so forth, and I think now those companies have the certainty they need to move forward. You know, so it was a bit of a difficult time, but I think big picture now the rules of the road have been set for both sides of the house, so to speak — both the areas where the large incumbents operate as well as the areas where the smaller incumbents operate.

Christopher Mitchell: Really my question was just I guess rehashing this other issue of, I sure wish in my ideal world it would have been a situation in which the FCC would have effectively said, "Hey, you know, co-op in southeastern South Dakota, you did a great job in your area. We're going to give you money for the CenturyLink area." But as you noted, that's politically unaware and dangerous.

Carol Mattey: It's exactly ⁠— that is exactly what this RDOF auction is all about. I mean, the idea is that CenturyLink is no longer going to be automatically entitled to this money after 2020 and that cooperative that's next door is going to have the opportunity to bid to greatly expand their service area into that neighboring territory. So, you know, yes, it took a long time coming. It's taken years to get to this point, but that is precisely ⁠— I mean, it just goes back to the flash cut. The FCC didn't want to do it immediately, and now the RDOF is the opportunity for all of those companies out there that want to expand their service territory into neighboring areas where consumers are not served and have the opportunity to get the subsidies that up until now have gone to the incumbent.

Christopher Mitchell: Great segue into how I wanted to finish off our discussion. The RDOF is the Rural Digital Opportunities Fund, which I like to remind people, you know, anybody who's in charge of anything at the federal government or even the state government or sometimes local governments, they like to rename things so they can get more credit for them. It's really CAF III, right?

Carol Mattey: Yeah, I'm well aware of that. Honestly, I was a little miffed when they renamed it, but then I realized I did the exact same thing because we renamed the high cost program and called it the Connect America Fund. So I get it. I understand why they did that.

Christopher Mitchell: So one of the questions that I really wanted to ask you was ⁠— I mean I'm working on comments right now about how this fund should work. We're talking about money that's going to be dispersed from 2020 through 2030, and to me, the FCC proposal that the minimum speed delivered is 25/3 [Mbps] with the money, I believe, it looks a lot like this same thing with 10/1 [Mbps] in which you think that one lesson you've learned is that the FCC should have been more aggressive. To me, I would think that first of all, a lot of these entities that are bidding on it are going to surpass that. I have no doubt, but nonetheless, the fact that anyone could be getting a check in 10 years for delivering that level of speed to me seems worrisome.

Carol Mattey: Well, I actually share your worry. I mean, I'm concerned myself that 10 years down the road, you know, 25/3 [Mbps] is going to seem as inadequate as 4/1 [Mbps] seems does today or even 10/1 [Mbps]. And the problem is that the FCC keeps setting the minimum speed based on today's definition of broadband. And what it really needs to do is be projecting what our definition of broadband is going to be at the end of the term, or at least at the end of the deployment cycle, which means forecasting out where are we going to be six or seven years from now. And that that's kind of a fundamental problem that I think ⁠— you know, that sort of thinking has not prevailed thus far. And, you know, I'll be interested to see all the comments on that issue when folks file comments this week.

Christopher Mitchell: Are you interested in tipping your hand on any other changes that you'll be recommending in comments?

Carol Mattey: Well, I think another issue — honestly, I'm very concerned about front-loading all of the budget into what the FCC is calling phase one of the RDOF because, as we talked about a little earlier, you know, there's a problem with the broadband mapping. And basically, the FCC is proposing to put 80 percent of the RDOF budget into the first RDOF auction and target it to areas based on the Form 477 data, which say the areas are unserved, and then defer to a second auction areas that may be partially served. And it just seems to me it doesn't make sense to put all of your money up front if you haven't yet properly sized the scope of the problem. I mean, there's no question that there are plenty of unserved people in census blocks that are showing up today on the FCC's map as served because under the FCC rules, a company, even if it only serves or makes available service to a tiny corner of a census block, you know, the FCC counts that whole block as served. And that's a real problem, and I'm just worried that, you know, at least as proposed by the FCC, they may be putting too much money up front and not leaving enough money to take care of the full job that needs to be done.

Christopher Mitchell: Do you know when the rest of the money would be allocated?

Carol Mattey: Well, the FCC's vague about it and it says, you know, there'll be a phase two auction once we have improved data, but it doesn't say when that's gonna happen. And one thing I've learned over time is everything takes longer than you expect it to, and obviously looking ahead, 2020's in election year and you know, with the potential of a change in leadership at the FCC, who knows if and when that second auction would occur. And one of the issues is sort of, how do you design this program so that there's more than one opportunity for companies to compete to get the funding to serve the areas that need to be served?

Christopher Mitchell: Yeah. And I think, I mean, I would imagine this is a pretty significant issue because you can imagine that a company ⁠— a co-op, a local company, whoever ⁠— would be able to bid differently if for instance, there are 10 contiguous blocks rather than two blocks that are surrounded by areas that today are not eligible but may be eligible when we have better mapping.

Carol Mattey: Right, exactly. That is exactly the point. You know, companies don't build networks according to census blocks. You build a network to go from point a to point b, and if you've got a situation where, you know, four or 10 or however many census blocks in the middle are not eligible for funding, even though in fact there are unserved people there, that's a real problem and that could end up having the exact opposite consequence in terms of not getting the result we want. And I think that, you know ⁠— now I want to be clear, I'm not saying the FCC should wait until it has perfect data to do any auction because then I'm afraid, you know, we'll be waiting three years before we have the next funding opportunity, and that doesn't make sense either. But I am saying I think that a program of several opportunities to compete for this funding would make sense, and I think the budget needs to be reallocated in a more even way so that, you know, you're making some money available in this first auction, an additional amount of money available in the second auction. And another point is, I think it's premature just to say we're going to have two auctions and then we're done. I mean, in my view, we're not done until we actually have universal service, and if it turned out in the second auction that there are places in the country that don't get winning bids, the FCC needs to be prepared to do it another time or look at other solutions. You can't just say we're done and then throw up our hands and say [to] some areas of the country, "You're out of luck. Nobody wanted to bid."

Christopher Mitchell: Yes, I am in full agreement on those points. Is there anything else that you wanted to mention in terms of the Connect America Fund before I kick you off the show?

Carol Mattey: Ah. Well I think one of the things to keep in mind is over the years I'd speak at conferences and other things, and you know, at various times people would criticize the FCC. And I think — you know, I want to say to your listeners, the FCC's intentions truly have been in the right place. These issues are complicated, they're hard, and they're very political, and the FCC has been moving in the right direction. I mean, obviously we all wish it could've happened faster, and it just doesn't work that way and that's just a function of government. But the FCC is pointed in the right direction, and I think, you know, what is necessary now is to push the FCC to come up with a comprehensive plan and not let up until it's done.

Christopher Mitchell: All right. Well, I really appreciate you taking the time to come on, especially as I've been pretty public in criticizing this program in ways that I think you would agree — I mean, I know that you would agree, but I would also say, at times it's easy to sit on a bar stool and to say how the world should be. But when you actually wrestle with things, it always turns out to be much more difficult than you think.

Carol Mattey: Yeah. Amen. I agree with that. So thank you for having me on your show. I appreciate it.

Lisa Gonzalez: That was Christopher with Carol Mattey, principal of Mattey Consulting discussing the Connect America Fund. We have transcripts for this and other podcasts available at muninetworks.org/broadbandbits. Email us at podcast@muninetworks.org with your ideas for the show. Follow Chris on Twitter. His handle is @communitynets. Follow muninetworks.org stories on Twitter. The handle is @muninetworks. Subscribe to this podcast and the other podcasts from ILSR, Building Local Power and the Local Energy Rules podcast. You can access them anywhere you get your podcasts. You can catch the latest important research from all of our initiatives if you subscribe to our monthly newsletter at ilsr.org. While you're there, please take a moment to donate. Your support in any amount helps keep us going. Thank you to Arne Huseby for the song Warm Duck Shuffle, licensed through Creative Commons, and thank you for listening to episode 375 of the Community Broadband Bits podcast.

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