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Public Comment: Many commenters discussed the disadvantages of such an approach. <br />Some commenters, including several local government recipients, argued that limiting <br />investments to locations without access to reliable wireline 25/3 Mbps337 was too restrictive <br />because some urban jurisdictions are already mostly or entirely covered by a network with at <br />least 25/3 Mbps speeds yet lack widespread broadband adoption for various reasons. <br />Commenters suggested that recipients would benefit from greater flexibility to provide necessary <br />investments in broadband access in areas that are nominally covered by speeds of at least 25/3 <br />Mbps, such as to provide affordable broadband access in low-income areas or to address service <br />quality and reliability issues. Further, commenters argued that Treasury's requirement that new <br />projects meet minimum reliable speeds of 100 Mbps symmetrical was inconsistent with the <br />requirement that broadband infrastructure projects focus on those with access to significantly <br />lower speeds, and further noted that several states have already expanded the focus of their <br />broadband programs beyond those without reliable access to speeds of 25/3 Mbps. Commenters <br />argued that if the limitation to unserved and underserved households and businesses were <br />maintained, the definition of unserved and underserved households and businesses should be <br />revised to include households and businesses currently served by higher standards. Commenters <br />proposed a number of alternative cutoff speeds, including 25/25 Mbps, 50/10 Mbps, and 100 <br />Mbps symmetrical. Others expressed support for providing flexibility for recipients to make their <br />own determination on eligible areas for investment. These commenters referenced studies <br />indicating that 25/3 Mbps is inadequate for today's modern household or business needs. <br />337 In the remainder of this Supplementary Information, "25/3 Mbps" refers to broadband infrastructure that is <br />designed to reliably meet or exceed at least 25 Mbps download speeds and 3 Mbps upload speeds. "100 Mbps" <br />symmetrical refers to broadband infrastructure that is designed to reliably meet or exceed at least 100 Mbps <br />download speeds and 100 Mbps upload speeds. <br />300 <br />