Op-ed Feb 03, 2022
Applauding efforts of the National Telecommunications and Information Administration on broadband program design and implementation
The American Connection Project Policy Coalition (ACPPC), comprised of over 175 businesses and organizations spanning across the entire country and economy
By: The American Connection Project Policy Coalition
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:
Respectfully,
American Connection Project Policy Coalition Partners:
Adaptrum
Association of Equipment Manufacturers
Agricultural Retailers Association
Agricultural Council of California
Alabama A&M University
AgriGrowth
Alltech
Alcorn State University
American Farm Bureau Federation
American Agri-Women
American Seed Trade Association
American Feed Industry Association
American Sustainable Business Council
American Soybean Association
American Tower Corporation
American Telehealth Association
Association of Public & Land-Grant Universities
Animal Health Institute
BASF
AveleCare
Baylor Scott & White
Bayer
Big Brothers Big Sisters of America
Best Buy
Boehringer Ingelheim Animal Health
Blue Cross Blue Shield Association
California Farm Bureau Federation
Bremer Financial Corporation
CapZone Group
Capital One
Center on Rural Innovation
Cargill
Ciena
CentraCare
Cisco
CHS Inc
Clearfield
ClearBlade
CoBank
Cleveland Clinic
Connected Nation
Com Net, Inc.
Cooperative Network
Compeer Financial
CUNA Mutual
Consumer Brands Association
DeLaval
Corteva Agriscience
Ditch Witch
Dairyland Power Cooperative
Ecolab
Dell Technologies
eXtension Foundation
Ducks Unlimited
Farm Journal
EYEJ: Empowering Youth, Exploring Justice
Finley Engineering
Federation of Southern Cooperatives
FMI The Food Industry Association
FMC Corporation
Germania Insurance
GEOVERSE
Google Fiber
Gillette Children’s Specialty Healthcare
Gundersen Health System
Granite Telecommunications
Heartland Forward
HealthPartners
Hershey Company
Helium
hims & hers
Hewlett Packard Enterprise
IdeaTek
IBM
Iowa Institute for Cooperatives
International Dairy Foods Association
Kansas Cooperative Council
Iowa State University
Land O’Lakes, Inc.
Khan Academy, Inc.
LightBox
Landus Cooperative
Mayo Clinic
Lumen
Merck Animal Health
Medical Alley Association
Minnesota Business Partnership
Microsoft
Minnesota Farmers Union
Minnesota Crop Production Retailers
Minnesota Milk Producers Association
Minnesota Hospital Association
Minnesota Technology Association
Minnesota Rural Broadband Coalition
Minnesota Vikings Foundation
Missouri School Boards' Association
MOX Networks
National Association of State Departments of Agriculture
National 4-H Council
National Association of Counties
National Corn Growers Association
National Council of Farmer Cooperatives
National Farmers Union
National FFA Organization
National Grain and Feed Association
National Milk Producers Federation
National Pest Management Association
National Rural Electric Cooperative Association
National Rural Education Association
NCBA CLUSA
Nebraska Cooperative Council
Nebraska Cooperative Internet Service Providers
NEED
Nestlé Purina
New Horizons Minnesota
NDSU Agricultural Affairs
North State Together
NTCA-The Rural Broadband Association
NUCA
Ocean Spray Cranberries Inc.
Oklahoma Agriculture Cooperative Council
Ōmcare Inc.
Oregon Farm Bureau
Organic Valley
PCs for People
Paige Wireless
Partners for Education
Pheasants Forever & Quail Forever
Power & Communications Contractors Association
Provalus
Pulse (City of Loveland)
Riceland Foods, Inc.
Randstad USA
Rural Community Assistance Partnership
Rural Cloud Initiative
S2G Ventures
Rural LISC
Scholastic
Schools, Health & Libraries Broadband Coalition
SCOULAR
SD Association of Cooperatives
Silicon Harlem
State Agriculture and Rural Leaders
Syngenta
Talkspace
Telsasoft
Teltech Communications
TELUS Agriculture
Texas Agricultural Cooperative Council
The Fertilizer Institute
Tillamook
Topcon
Toro
Tractor Supply Company
Trilogy Networks
Trimble
UltraSight
United States of Care
University of Illinois Urbana-Champaign
University of Minnesota
Valmont Industries
WTA-Advocates for Rural Broadband
VistaBeam
Weyerhaeuser
Westchester County Association Inc.
Zoetis
Submitted via www.regulations.gov; Attention Docket ID No.: FSA-2021-0002
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.
Respectfully,
American Connection Project Policy Coalition Partners:
Adaptrum
Association of Equipment Manufacturers
Agricultural Retailers Association
Agricultural Council of California
Alabama A&M University
AgriGrowth
Alltech
Alcorn State University
American Farm Bureau Federation
American Agri-Women
American Seed Trade Association
American Feed Industry Association
American Sustainable Business Council
American Soybean Association
American Tower Corporation
American Telehealth Association
Association of Public & Land-Grant Universities
Animal Health Institute
BASF
AveleCare
Baylor Scott & White
Bayer
Big Brothers Big Sisters of America
Best Buy
Boehringer Ingelheim Animal Health
Blue Cross Blue Shield Association
California Farm Bureau Federation
Bremer Financial Corporation
CapZone Group
Capital One
Center on Rural Innovation
Cargill
Ciena
CentraCare
Cisco
CHS Inc
Clearfield
ClearBlade
CoBank
Cleveland Clinic
Connected Nation
Com Net, Inc.
Cooperative Network
Compeer Financial
CUNA Mutual
Consumer Brands Association
DeLaval
Corteva Agriscience
Ditch Witch
Dairyland Power Cooperative
Ecolab
Dell Technologies
eXtension Foundation
Ducks Unlimited
Farm Journal
EYEJ: Empowering Youth, Exploring Justice
Finley Engineering
Federation of Southern Cooperatives
FMI The Food Industry Association
FMC Corporation
Germania Insurance
GEOVERSE
Google Fiber
Gillette Children’s Specialty Healthcare
Gundersen Health System
Granite Telecommunications
Heartland Forward
HealthPartners
Hershey Company
Helium
hims & hers
Hewlett Packard Enterprise
IdeaTek
IBM
Iowa Institute for Cooperatives
International Dairy Foods Association
Kansas Cooperative Council
Iowa State University
Land O’Lakes, Inc.
Khan Academy, Inc.
LightBox
Landus Cooperative
Mayo Clinic
Lumen
Merck Animal Health
Medical Alley Association
Minnesota Business Partnership
Microsoft
Minnesota Farmers Union
Minnesota Crop Production Retailers
Minnesota Milk Producers Association
Minnesota Hospital Association
Minnesota Technology Association
Minnesota Rural Broadband Coalition
Minnesota Vikings Foundation
Missouri School Boards' Association
MOX Networks
National Association of State Departments of Agriculture
National 4-H Council
National Association of Counties
National Corn Growers Association
National Council of Farmer Cooperatives
National Farmers Union
National FFA Organization
National Grain and Feed Association
National Milk Producers Federation
National Pest Management Association
National Rural Electric Cooperative Association
National Rural Education Association
NCBA CLUSA
Nebraska Cooperative Council
Nebraska Cooperative Internet Service Providers
NEED
Nestlé Purina
New Horizons Minnesota
NDSU Agricultural Affairs
North State Together
NTCA-The Rural Broadband Association
NUCA
Ocean Spray Cranberries Inc.
Oklahoma Agriculture Cooperative Council
Ōmcare Inc.
Oregon Farm Bureau
Organic Valley
PCs for People
Paige Wireless
Partners for Education
Pheasants Forever & Quail Forever
Power & Communications Contractors Association
Provalus
Pulse (City of Loveland)
Riceland Foods, Inc.
Randstad USA
Rural Community Assistance Partnership
Rural Cloud Initiative
S2G Ventures
Rural LISC
Scholastic
Schools, Health & Libraries Broadband Coalition
SCOULAR
SD Association of Cooperatives
Silicon Harlem
State Agriculture and Rural Leaders
Syngenta
Talkspace
Telsasoft
Teltech Communications
TELUS Agriculture
Texas Agricultural Cooperative Council
The Fertilizer Institute
Tillamook
Topcon
Toro
Tractor Supply Company
Trilogy Networks
Trimble
UltraSight
United States of Care
University of Illinois Urbana-Champaign
University of Minnesota
Valmont Industries
WTA-Advocates for Rural Broadband
VistaBeam
Weyerhaeuser
Westchester County Association Inc.
Zoetis
Submitted via www.regulations.gov; Attention Docket ID No.: FSA-2021-0002