Comment

To whom it may concern:

The American Connection Project Policy Coalition (ACPPC), comprised of over 175 businesses and organizations spanning across the entire country and economy, applauds the efforts of the National Telecommunications and Information Administration (NTIA) to solicit feedback and guidance as we approach broadband program design and implementation. The ACPPC has long advocated for a robust investment in broadband infrastructure, accurate mapping, and stronger state and federal coordination on broadband deployment. Our coalition applauded the passage of the Infrastructure Investment and Jobs Act (IIJA), and we look forward to continued collaboration with the agency to ensure that this historic investment is implemented efficiently and closes the digital divide in communities across the country. The comments below reflect the general principles of our coalition, and it is our hope that the agency strongly considers incorporating these principles into its implementation strategy.

Communication, engagement, transparency, and accountability are critical to the successful implementation and deployment of the IIJA. If we are to successfully execute on delivering high-speed internet to all Americans, these areas of focus are critical as NTIA collaborates with state officials and broadband offices. ACPPC supports the federal government requiring communication, engagement, and transparency plans to be developed as part of the state proposals. Further, governors, state officials, and respective broadband offices should be involved in any conversations regarding broadband program development and implementation, as these leaders have both a strong and nuanced understanding of their state’s broadband needs and the challenges within their borders. Additionally, we encourage NTIA to engage with state broadband coordinators to consider downstream implications new federal programs could have on existing state programs, preventing any inadvertent conflict with existing efforts, programs, and funding.

Secondly, broadband maps should be developed as quickly as possible, while also maintaining accuracy. Our coalition defines the term “accuracy” through the collection of metrics related to the quality and extent of service, such as download speed, upload speed, and latency. The identification and analysis of these metrics then enable us to determine the greatest areas of need, thereby prioritizing both unserved and underserved communities, as well as anchor institutions. Where they exist and are accurate, we encourage NTIA to work with the Federal Communications Commission (FCC) to leverage already existing state-developed broadband maps as the FCC finalizes the map that NTIA is required to use for its programs. Further, a viable challenge process and a sensible crowdsourcing program should also be included, and ACPPC coalition members stand ready to partner with the FCC to promote and share the new crowdsourcing program.

Affordability and digital inclusion should remain at the forefront of the implementation discussion. ACPPC members support state and federal funding that provides much-needed assistance to low- income communities and consumers to make broadband service more affordable, while also promoting broadband adoption. With this goal in mind, we encourage NTIA to work with the FCC to continue to improve access to the newly established Affordable Connectivity Program while also ensuring the program is efficiently managed.

Furthermore, the ACPPC encourages NTIA to consider the following key principles as it develops its implementation strategy:

  • We encourage the NTIA to support state and federal funding that prioritizes deployment and sustainability of scalable networks. These networks should deliver quality high-speed broadband services capable of meeting todays and tomorrow’s communications needs across America as required by the law, while also encouraging such networks to be built in a timely manner.
  • The NTIA should also prioritize unserved locations, and then underserved areas as well as community-serving anchor institutions with limited speeds. Specifically, funding should be prioritized in communities with the greatest number of disparities and challenges such as unserved, high-poverty areas and unserved tribal communities.
  • The coalition encourages the NTIA, FCC, and USDA to allow new funding made available through the IIJA to work in concert with existing state funding. Many states have a long history of utilizing state funds to deploy broadband networks. These funds should serve as a complementary source of funding to the more-robust federal funding made available through the IIJA. For example, states should be allowed to use existing state funds already available to them towards the required ‘matching’ funds needed for the new NTIA BEAD program.
  • We encourage NTIA and the Administration to ensure consistent application of waiver processes across state grantees and projects. This includes streamlining the applications through the use of IT product category waivers.
  • Cybersecurity is an important national security issue. The coalition encourages the Administration to incorporate baseline guidance for grantees and states to mitigate and prevent cyber risks to our communication networks and consumers.

The American Connection Project Policy Coalition appreciates the opportunity to comment as the agency begins the implementation process of the Infrastructure Investment and Jobs Act. Our coalition stands ready to partner with the NTIA, other federal agencies, and state governments to collaborate to ensure the implementation of this historic investment reaches the households, businesses, and communities that are not connected today. If you have any questions or need additional information, please do not hesitate to reach out to Matthew Wohlman at mwohlman@landolakes.com or Autumn Veazey Price at alveazey@landolakes.com.

Respectfully,

American Connection Project Policy Coalition Partners

Filed Date:

February 3, 2022

Filed By:

The American Connection Project Policy Coalition

Recipient:

National Telecommunications and Information Administration

Subject:

Telecommunications, Docket ID No.: FSA-2021-0002

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