Summary of RCA Comments re: Broadband Provisions of the Recovery Act

Full copy of Comments to NTIA/RUS
Full copy of Comments to FCC

Introduction

Job creation and economic development are among the driving forces leading to the passage of the Recovery Act, and RCA is mindful of the fact that decisions that NTIA and RUS will make regarding the administration of their Recovery Act funding programs must keep these objectives clearly in focus.

But we must also be mindful of the fact that “we have not yet met the challenge of bringing broadband service to everyone.” Expanded and accelerated broadband deployment throughout rural America (in which many unserved and underserved areas are located) is critically important, and Recovery Act funding provides an opportunity to ensure that consumers, governments, and businesses, as well as educational, public safety, health care, and other institutions throughout rural America have greater access to broadband services.

The focus of NTIA and RUS on jobs and economic development should not detract from their efforts to utilize funding made available by the Recovery Act in the most efficient and effective manner possible to improve broadband access in rural communities. Further, it is important to note that the goals of job creation and expanded deployment of broadband are not mutually exclusive, since studies have shown a direct correlation between broadband penetration and job creation.

For all these reasons, RCA proposes that priority be given by NTIA and RUS, in the allocation of grants and loans, to projects designed to deploy broadband infrastructure in unserved and underserved areas.

NTIA and RUS should define unserved areas, underserved areas, and broadband service in a way that moves rural areas toward parity with urban areas in having access to affordable broadband service that enables utilization of advanced applications and functionalities. Accurately and reasonably defining unserved and underserved areas based upon the levels of broadband service speeds currently available will facilitate the targeting of funding in a manner most consistent with the goal of universally available broadband.

Broadband service should be defined in a way that distinguishes between wireless and wireline technologies, because this will serve the statutory purpose of ensuring that service providers using different categories of technology platforms all have an opportunity to compete for funding and will enable consumers in unserved and underserved areas to take advantage of the unique capabilities of mobile wireless broadband services.

Finally, in awarding grants and loans pursuant to BTOP and the RUS broadband grant and loan programs, NTIA and RUS should take into account the fact that mobile wireless broadband service providers are in the best position to deploy broadband infrastructure in rural areas quickly and efficiently, and to provide affordable broadband services to the widest population of subscribers in unserved and underserved areas.

Summary

Many rural communities throughout America have been watching from the sidelines as broadband transforms communications across the country. Bringing broadband to rural and remote areas has been a slow and uneven process largely because deploying broadband infrastructure in these areas is a costly enterprise with uncertain returns. As broadband construction and deployment have lagged in rural areas, consumers in unserved and underserved communities have found themselves stuck with no means or inadequate means for accessing the Internet.

The Broadband Technology Opportunities Program and the Rural Utilities Service (“RUS”) broadband grant and loan programs funded by the American Recovery and Reinvestment Act of 2009 (“Recovery Act”) provide an opportunity to reverse this tide by expanding and accelerating broadband deployment throughout rural America. In the short term, these funding programs will create and preserve jobs through the deployment of broadband infrastructure. In the longer term, the availability of advanced telecommunications services in rural areas will spur economic development, and will provide many other services and benefits—such as health care and public safety—that are enhanced by the presence of broadband networks.

The challenge for the National Telecommunications and Information Administration (“NTIA”) and RUS is to make all this happen by designing grant and loan programs that work effectively in getting funding into the hands of service providers that can deploy broadband quickly and efficiently. The Rural Cellular Association believes that mobile wireless broadband service providers can play a key role in the rapid deployment of affordable broadband services in rural communities through the utilization of Recovery Act funding.

Priority in awarding grants and loans should be given to projects that will deploy broad-band infrastructure in unserved and underserved areas. The economic, educational, and other benefits derived from a national broadband network are decreased to the extent that there are “dead zones” throughout the country where consumers have no access, or inadequate access, to advanced telecommunications technologies. Directing Recovery Act funding toward a cure for this problem will not only help to achieve parity for consumers in rural communities but will also benefit the nation as a whole by building a ubiquitous broadband network.

This lack of adequate broadband, or the lack of any broadband at all, should be among the first problems addressed by the grant programs. One solution is to define unserved areas, underserved areas, and broadband service in a way that enables carriers using mobile wireless broadband technologies to receive Recovery Act funding. This is consistent with the intent of the statute to enable as many entities as possible to be eligible for grants. In addition, although mobile wireless broadband currently does not deliver speeds comparable to some wireline technologies, it does provide features and capabilities—mobility being chief among them—that make it an attractive service that is increasingly in demand in rural areas. Mobile wireless broadband technologies can be deployed efficiently and quickly, in contrast to wireline broadband infra-structure, making them well positioned to accomplish the statutory goal of deploying broadband service to a large universe of subscribers in unserved and underserved areas.

Another solution to the lack of broadband, or inadequate broadband service, in rural areas is to give a top priority to the deployment of affordable broadband service as quickly as possible in unserved and underserved areas. If NTIA and RUS instead were to give a higher priority to broadband speed, this would be detrimental to consumers because it would slow deployment (because current technologies that provide greater bandwidth also take longer to put in place) and would make broadband services less affordable (because the construction of infrastructure for these higher speed technologies faces many encumbrances that increase their cost).