For the purpose of determining eligibility for broadband technology grants under the American Recovery and Reinvestment Act (ARRA), several cable, telephony and rural telecommunications groups voiced consensus in recommending that the FCC define as “unserved” any area that lacks transmission speeds of at least 768 kbps. In keeping with ARRA provisions that pertain to the Broadband Technology Opportunities Program (BTOP), the FCC must consult with the National Telecommunications & Information Administration (NTIA) on the definitions of “unserved” and “underserved” areas, the definition of “broadband,” and on non-discrimination and network interconnection obligations that must be written into BTOP grant contracts administered by the NTIA. Several parties, including the National Cable & Telecommunications Association (NCTA), the U.S. Telecom Association, the Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO), and the Rural Cellular Association (RCA), responded to an FCC request for comments on that issue. The commentors generally agreed on the same benchmark transmission speed (768 kbps) for the purpose of defining an area as unserved. While arguing that an “underserved” area be defined as one that lacks at least one ISP with minimum transmission speeds of 3 Mbps downstream and 768 kbps upstream, the NCTA added that, in unserved areas, funding priority should be given to areas “where no provider offers Internet access service at transmission speeds of more than 200 kbps in at least one direction.” The U.S. Telecom Association, meanwhile, suggested all unserved areas lacking minimum transmission speeds of 768 kbps should be given funding priority, with areas lacking speeds in excess of 1.5 Mbps to be given the next highest priority. Voicing support for the multi-tier definition of broadband service adopted by the FCC last year, OPASTCO recommended that (1) the benchmark transmission speed for underserved areas be set at a ceiling of 12 Mbps and (2) nondiscrimination obligations be limited to those set forth in the FCC’s 2005 policy statement on net neutrality. Citing ARRA conference report language that urges the NTIA to “take into consideration the technical differences between wireless and wireline networks,” RCA reminded the FCC that “the statutory objective of technological neutrality requires that the terms ‘unserved area,’ ‘underserved area,’ and ‘broadband service’ be defined in a manner that does not preclude mobile wireless carriers from receiving BTOP funding.”