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Comments to NTIA Regarding Implementation of the Infrastructure Investment and Jobs Act

February 4, 2022

ITIF filed comments with the National Telecommunications and Information Administration (NTIA) in the matter of Infrastructure Investment and Jobs Act Implementation (Docket No. 220105-0002), regarding the $48 billion to be administered by NTIA through the Broadband Equity, Access and Deployment (BEAD) Program; the Middle Mile Program; and the Digital Equity Planning Program.

The legislation provides an abundance of funds to promote broadband access and adoption, which should be enough to eliminate the geographic digital divide, but only if spent wisely and constructively. If the funding is spent to ensure wider coverage of broadband to unserved areas, we believe the nation can once and for all eliminate the geographic digital divide (with low-earth-orbit satellite broadband serving the rest). If instead funds are spent to promote competition through overbuilding, as some advocates desire, this “once” (not once in a lifetime) opportunity will have been squandered. As such, the stakes are incredibly high and NTIA cannot afford to get this wrong. Doing so will consign millions of households to being on the other side of the digital divide, while doing fundamental harm to the trust in government to solve key pressing problems.

To facilitate effective use of funds, NTIA should ensure a thoughtful initial allocation of administrative resources and responsibilities by creating incentives for capable deployment that prioritizes unserved areas and uses diverse technologies. ITIF’s comments make for broad points:

  1. Funding should be targeted to unserved areas.
  2. Funding should be technology-neutral.
  3. NTIA should create an allocation process that incentivizes efficiency and accountability.
  4. NTIA should look to experienced providers with adequate capital and economies of scale.
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