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Creating and preserving good jobs, while jumpstarting the economy and promoting long-term U.S. competitiveness, should be the top priorities of the National Telecommunications and Information Administration and Rural Utilities Service broadband initiatives, the Communications Workers of America said in comments filed with the Commerce and Agriculture Departments.

CWA is convinced that the NTIA's Broadband Technologies Opportunity Program (BTOP) and the Rural Utilities Service broadband grant and loan program must focus on investment in broadband projects that create and preserve quality jobs. With 13.2 million unemployed Americans, the first consideration in grant allocations must be putting Americans back to work.

The $7.2 billion broadband initiative included in the American Recovery and Reinvestment Act also is an important step to closing our nation's three gaps in broadband: lack of access to any broadband network by an estimated 10-12 million households, slow speeds compared to our global competitors, and adoption barriers due to the cost or technological barriers to computer ownership and Internet access. Closing these gaps is the driving force of CWA's "Speed Matters" campaign.

The grants are intended to improve broadband deployment in unserved and underserved areas, increase broadband adoption, improve access to broadband by public safety agencies and especially important, stimulate the economy and create quality jobs, CWA said.  

CWA made several key recommendations in its filing:

• Focus network deployment grants on unserved areas -- defined as an area without at least one non-satellite facilities-based provider of non-dial-up Internet service -- and networks serving community anchor institutions, like libraries, schools, rural health centers and similar community centers.
• Some grants should be made to scalable high-speed projects in underserved areas -- defined as areas without networks capable of 3 mbps down, 1 mbps up.
• To increase broadband adoption in underserved, low-income communities, grants should provide for digital literacy promotion, subsidies for computer ownership and broadband access delivered by community based organizations and public agencies.   
• Focus grants on projects that will preserve and create good jobs.
• To ensure enforcement of Buy America provisions and prevailing wage requirements, require that grant recipients report the number of jobs created and the wages/compensation of those jobs.
• Ensure that projects can be started quickly and are sustainable, and that recipients have a track record of success and that grant-funded projects are scalable.
• Establish minimum speed requirements of 3 mbps down and 1 mbps up for network deployment,  then rank grant proposals based on speed, number of new households and locations connected, number of jobs created, number of low-income households served.
• Preserve an open Internet by requiring grant recipients to abide by the Federal Communications Commission's Open Internet principles and current Internet traffic exchange and peering norms.