Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of )

The Commission's default rules are designed to impress upon recipients the importance of being prepared to meet all Commission requirements and be prepared to fulfill deployment obligations."6 In other words, the default rules exist to hold bidders' feet to the fire and incentivize them to build the networks for which they received subsidies – subsidies which were denied to losing bidders. [...] The Amnesty Letter suggests that the unserved might be better off if Broadband Equity, Access, and Deployment (BEAD) Program subsidies instead were used to connect their locations.7 But as the Amnesty Letter concedes, the BEAD Program is months away from allocating funding.8 By contrast, Universal Service Fund money allocated through the RDOF and CAF II mechanisms already have been disbursed. [...] 7 See, e.g., Amnesty Letter at 1-2 (stating that the BEAD Program "will provide US states and territories the resources to deploy broadband in unserved and underserved communities" and that "[s]ignificantly lowering the penalties for default will incentivize awardees to relinquish their areas sooner rather than later, making the areas eligible for BEAD funding"). [...] at 1 ("The principal issue herein is the preservation of the integrity of the RDOF Auction as well as the protection of the integrity and viability of any future Commission reverse auctions."). [...] Penalties for default are essential to the integrity of this funding model, as they create the necessary incentives for winning bidders to do what they promise to do – and the necessary disincentives to discourage gamesmanship that harm not just rivals, but also Americans on the wrong side of digital divides who are harmed when broadband network construction does not occur.