A coalition of 21 Connect America Fund Phase II (CAF-II) winners from Auction 903 has filed petitions with the FCC to retroactively apply the letter of credit (LOC) requirements adopted for the upcoming Rural Digital Opportunity Fund (RDOF) to CAF-II winners. For RDOF, the FCC adopted LOC requirements that are less financially burdensome to support recipients than the LOC requirements adopted for CAF-II whereby the LOC value will in no case exceed three years’ worth of support. The coalition specifically asks the FCC to (1) initiate a rulemaking proceeding to modify the CAF-II LOC rules to resemble the RDOF LOC rules, and (2) waive the existing CAF-II LOC rules so that modified rules can apply instead. The FCC seeks comment on these petitions by April 13, 2020 and reply comment by April 28, 2020.
