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FBA Filing to FCC on Emergency Connectivity Fund

The Fiber Broadband Association (“FBA”) hereby submits comments in response to the Public Notice issued by the Wireline Competition Bureau (“Bureau”) of the Federal Communications Commission (“Commission”) regarding the implementation of the Emergency Connectivity Fund (“ECF”) established as part of the recently enacted America Rescue Plan Act of 2021 (“American Rescue Plan”) to help schools and libraries provide devices and connectivity to students, school staff, and library patrons during the pandemic. Among the issues raised in the Public Notice, the Bureau seeks comment on whether the Commission should impose a minimum service standard (“MSS”) for services to be considered eligible advanced telecommunications and information services to receive ECF support. FBA offers comments on this one issue. As discussed herein, to meet the needs of students, school staff, and library patrons, the Commission should set an MSS of 100 Mbps download and 100 Mbps upload (“100 Mbps symmetrical”) for ECF-supported services.