RDOF OPPORTUNITIES
The Rural Digital Opportunity Fund is the FCC’s next step in bridging the digital divide.
Every RDOF winning bidder (or its assignee) must file a long-form application (FCC Form 683) with the FCC. As part of this process, the long-form applicant must obtain an eligible telecommunications carrier (ETC) designation from the relevant states or FCC, submit detailed technology and system design descriptions, including a network diagram certified by a professional engineer, and provide a Project Funding Description detailing how it plans to fund its proposed buildout.
If the long-form applicant satisfies the application requirements, the FCC issues a “Ready to Authorize” public notice and the long-form applicant will have 10 business days to submit an irrevocable, stand-by Letter of Credit (LOC) from a qualified bank covering at least the first year of support for each state where it will receive support, as well as a Bankruptcy Opinion of Counsel (OOC) letter from outside legal counsel. (Please see below for more information about how to draft acceptable LOC and OOC documents)
Once all required information has been submitted and the application is complete, the FCC will issue a public notice announcing authorization of support for the winning bid and directing USAC to begin disbursing payments. USAC will then assign a study area code to the applicant for each state where it is authorized to receive support and begin issuing monthly payments shortly after the public notice has been released.
While RDOF support will be disbursed over a period of 10 years, carriers must complete deployment by the end of the eighth year to all locations in areas eligible for support and must meet interim deployment milestones along the way. A reassessment in year six of the program will revise location counts and deployment obligations (and adjust support in certain circumstances).
RDOF participants must file and certify deployment data annually in the HUBB (High Cost Universal Broadband) portal reporting all locations built out in the prior year, and should be prepared to provide documentation to the High Cost compliance team to substantiate build-out. The compliance team will conduct verification reviews of both interim and final milestones to confirm deployment to a sample of locations reported to the HUBB.
