Comments to OMB Regarding Guidance for Grants and Agreements: Build America, Buy America Act
Introduction and Summary
The Infrastructure Investment and Jobs Act (IIJA) contains unprecedented funding that presents the best chance we will ever have to deploy broadband to virtually all Americans and close the digital divide. The IIJA also contains the Build America Buy America Act (BABA), which requires iron & steel, construction materials, and manufactured products use in IIJA infrastructure funding programs to be made in the United States. ITIF welcomes the opportunity to comment on the Office of Management and Budget’s guidance which should hold together the goals of rapid and fiscally responsible infrastructure deployment as well as supporting U.S. industrial revitalization. Before making specific comments it is worth noting that few think tanks in the United States have been more committed to U.S. manufacturing renewal and the policies needed to acheive it than ITIF.
This balance is especially precarious for broadband infrastructure since the United States lacks a welldeveloped industrial base capable of meeting broadband deployment requirements and deadlines under the IIJA’s Broadband Equity, Access, and Deployment (BEAD) program. An onerous reading of Buy-America requirements risks dramatically increasing the cost of broadband deployment or delaying that deployment, potentially for years. The White House has promised that IIJA programs will represent “bold, concerted action to expand internet access and digital equity in Tribal communities.” In addition, President Biden has spoken of the need to get to “shovel ready” projects quickly and show results for the American people in reasonable time frame.
These goals are achievable alongside the goal of rejuvenated domestic manufacturing as long as the federal government maintains a balanced approach that does not sacrifice broadband deployment to overly strict buy-America provisions.
Therefore, the Office of Management and Budget (OMB) should carefully craft its guidance and allow waivers as necessary to ensure Americans can rapidly and cost-effectively get the benefits of broadband connectivity while allowing for longer term investments in onshoring of high-tech manufacturing to come to fruition over a reasonable time horizon.