Comment on FR Doc # 2012-27631

1) The main purpose of the grant (i.e. the construction of broadband facilites in areas where no broadband exists today) is too limiting with regard to local government applicants being able to successfully access the program's funding. 2) The secondary benefit (providing for a community center that provides free broadband services to all critical community facilities in the proposed funded service area for a two year period) is ambiguous with respect to defining or explaining how the community center will provide free broadband services to the critical community facilities. 3) Do the proposed rules provide for the ability of local government applicants to extend services to unserved areas of the locality from a local government constructed midlle mile network. This consideration is not well delineated. 4) There are a limited number of critical community facilites in rural localities that have constructed initial middel mile networks, which do not presently serve the entire jurisdiction but did connect community anchor institutions (i.e. CCFs) as a component of the middle mile project. Thie requirment for CCFs could be a prohibiting factor for local governments seeking to expand their networks to unserved areas. 5) Including entities other than rural local governments as eligible applicants has a great potential to preclude local governments being successful grant applicants. 6) The application requirements are extensive and potentially prohibit the ability of rural local governments to be successful grant applicants due to the complexity of the applcation requirements,which necessitates continuous and expensive planning by rural localties which have limited staff and financial resources to do so.