Current Efforts to Promote Program Alignment

Coordinating the Impact of Federal Broadband Funding

In the spring of 2022, NTIA undertook a systematic effort to better understand other agencies’ award processes and to align on a desired high-level approach to better coordinate the impact of federal broadband funding with Treasury, USDA, and the FCC. In July 2022, NTIA shared the preliminary results of that analysis and proposed the following process:

1. Any awarding agency should first conduct analysis to determine whether potential areas of duplication exist, or in the case of a pass-through award, should direct its recipients to conduct the analysis.
2. If the awarding agency identifies a potentially duplicative project, it should then notify the relevant agencies with sufficient notice before award decisions have been made.
3. The awarding agency should meet with the other relevant agency or agencies to discuss areas of duplication and, to the extent possible, resolve the potential duplication.
4. Resolution should be confirmed and documented prior to issuing the award.

Over the next several months, NTIA worked with USDA, Treasury, and the FCC to identify common tools for overlap analysis prior to making an award. Although each agency retains the final decision and authority to issue awards based on its own program requirements and statutory obligations, all four agencies have agreed to the principles included above. As the new process was being developed, NTIA consulted the best data available at the time prior to issuing awards in its TBCP, BIP, CMC and the Middle Mile Grant Programs. NTIA’s proactive efforts helped direct program dollars to where they are needed most, meet statutory implementation timelines established by Congress, and connect unserved Americans as quickly as possible.

This effort will become easier as federal agencies add more programs and more complete data to the Broadband Funding Map, allowing the map to show a more complete picture of where federal funding for the deployment of broadband infrastructure has been committed. The Broadband Funding Map, however, will not preclude the need for an agency-driven process for avoiding duplication of funding, nor will it be the sole tool agencies use for overlap analysis. This is particularly important in the near term because the map does not currently show a complete picture of federal broadband deployment funding. Agencies need time to collect the right data from recipients, especially because some program reporting requirements were defined before the data specifications for the map were completed. In addition, while broadband funding agencies and grant recipients are able to obtain a license to the Fabric that allows it to be used for the submission of data to the Broadband Funding Map, it will take time for broadband funding awards that were issued prior to the advent of the Broadband Funding Map to link funding data to the location-specific Fabric.

Furthermore, the Broadband Funding Map will not show projects to which an agency plans to obligate federal dollars. Providing such information on a public-facing map could create legal exposure for the Federal government. Therefore, additional steps (e.g. an MOU) are required to safely share confidential information across agencies prior to award in order to coordinate federal broadband funding, especially while agencies are implementing programs in parallel 

Finally, the unique structure of the BEAD Program necessitates yet additional coordination on timing. Whereas previous federal broadband programs were limited in geographic scope, Congress required states and territories in the BEAD Program to award funding in a manner that will prioritize coverage of broadband service to all unserved locations .²⁶  As states and territories execute on this directive, creating a stable environment is critical for program’s success. The potential for unexpected federal awards at certain phases of BEAD implementation could create uncertainty and complexity that may reduce participation from internet service providers, chill outside investment, and delay the achievement of Internet for All. For these reasons, NTIA is working with other federal agencies to ensure a stable environment in the lead up to and during a state or territory’s subgrantee selection process.

Data Sharing and Transparency

In the complex broadband funding landscape described by GAO, stakeholders may reasonably struggle to understand what funding opportunities are available and what rules govern them. Given that complexity, NTIA, in partnership with multiple agencies, is striving to publish transparent and data-driven resources that communicate the availability of broadband funding opportunities, where funding has been committed, and where funding may still be needed. The federal broadband programs administered by NTIA and more than a dozen other agencies are described on NTIA’s BroadbandUSA site, which provides information about programs’ authorizing legislation, eligible recipients and purposes, speed/technical requirements, and more.

The FCC has made progress developing the Broadband Funding Map. This map, which the FCC initially released in May 2023, will (where possible) show Congress and the American public where the federal government is investing in broadband infrastructure at a location level. NTIA is assisting the FCC to promote awareness of the obligation placed on broadband infrastructure-funding agencies to provide their information to the FCC. NTIA also recognizes that the inclusion of state-level broadband funding is important to prevent duplication and has encouraged the FCC to explore ways to incentivize states to provide their data to the map.

NTIA has also made progress in streamlining the data collection process for the report on federal broadband funding required by the ABA, an effort that should ease the reporting burden for agencies and improve data accuracy. In October 2022, after working with NTIA, OMB issued a Controller Alert that instructs agencies to use specific keywords when reporting federal financial assistance to USA Spending.²⁷ These key words will allow NTIA to use the search feature at USASpending.gov more effectively to explore feasibility of automating some aspects of the data collection process for the ABA report. NTIA also intends to leverage the broadband infrastructure data provided to the FCC’s BFM for purposes of ABA reporting.

In addition to coordinating with the FCC, NTIA has been building on its longstanding partnership with the Census Bureau²⁸ to create data products and tools to better understand broadband and digital equity challenges. In May 2021, the Census Bureau released the Digital Equity Act Population Viewer, an interactive collection of maps that includes the first-ever estimates of the “covered populations” defined by the Digital Equity Act of 2021, while highlighting various demographics and broadband Internet availability and adoption by state.²⁹  The maps were designed to help policymakers plan and implement Digital Equity Act programs, including by providing the legally required inputs for the statute’s state funding formula.³⁰  In February 2023, the Census Bureau and NTIA published the ACCESS BROADBAND Dashboard, a resource designed for policymakers and the public to assess how changes in broadband availability and adoption could influence local economies. The interactive dashboard allows users to compare maps displaying broadband access statistics to maps of select economic indicators, such as employment statistics, small business establishments, wages and income, poverty, population change and migration, educational attainment, and real gross domestic product. NTIA and the Census Bureau plan to update the dashboard annually so users can assess the economic context of areas where broadband availability and adoption efforts are underway. Each release will include the interactive dashboard and supplemental data files so users can access the underlying map data.

NTIA and the Census Bureau continue to explore other ways to improve the state of knowledge in this space, including use of sophisticated modeling techniques to produce estimates of key metrics for small geographies and populations. In June 2023, the two agencies released new covered population estimates for small geographies, including census tracts and counties. These estimates, which are available from the updated Digital Equity Act Population Viewer, enable users to understand where covered populations are concentrated within each state, helping to inform digital equity plans and programming. NTIA will continue to pursue small area estimation and other novel methods to increase the breadth of available data to inform broadband and digital equity policies and programs.

Program and Policy Alignment

Since early 2022, the White House’s National Economic Council has regularly convened the four lead agencies responsible for the vast majority of broadband funding (FCC, USDA, Commerce, and Treasury) through a working group co-chaired with NTIA’s Assistant Secretary of Commerce for Communications and Information. This Broadband Coordination Group includes senior staff from each agency and meets regularly to promote alignment between programs, discuss policy issues, and raise recommendations to agency and White House principals as needed.

Going forward, a key aspect of program alignment will be delivering consistent reporting standards for funding recipients, both for infrastructure and digital inclusion activities. NTIA supported the development of uniform data collection standards for the Broadband Funding Map to ensure that all agencies with funding for broadband infrastructure projects institute reporting protocols that generate accurate, timely information about funding footprints. NTIA participated in an early Broadband Funding Map feedback session with the FCC in August 2022 and subsequently offered written feedback with questions and suggestions for improvements. In February 2023, NTIA distributed the FCC’s draft data specifications for the Broadband Funding Map to all members of the Federal Funding Workstream,³¹  and in March 2023, NTIA facilitated a demonstration of the Broadband Funding Map for all agencies that report funding for broadband infrastructure projects for NTIA’s ABA report. Finally, NTIA gave a presentation on Broadband Funding Map reporting obligations to more than a dozen agencies in March 2023, providing federal partners with insight about what information would need to be collected from grant recipients and offering strategies to support implementation of standard reporting requirements in subsequent grant programs.

While the agencies continue to drive alignment, fully integrating applications for all federal broadband grant programs is not possible, given the wide range of purposes, timelines, and intended recipients for congressionally-created programs, as well as differences in underlying statutes. In some cases, however, agencies can agree to adopt common application policies across programs. For example, NTIA has included a Tribal consent condition in its programs, whereby applicants seeking federal funding to deploy broadband on Tribal lands must include in their application a Resolution of Consent from the Tribal Government upon whose Tribal Lands the infrastructure will be deployed. USDA included a similar clause in the Community Connect Funding Opportunity Announcement requiring a “certification from the appropriate tribal official” if service is being proposed on Tribal lands and will not consider for funding any applicant that fails to provide certification, as well as with the recent Round 5 ReConnect Notice of Funding Opportunity.³² 

Benefits of Complementary Programs

The GAO report paints a picture of fragmented, overlapping programs. While NTIA is working to alleviate the negative effects of fragmentation, GAO itself has noted that fragmentation can sometimes have benefits, such as the creation of defined roles and responsibilities.³³ NTIA has the expertise required to administer the BEAD Program through the states in part because of the expertise the agency developed by providing technical assistance to states for over a decade through the State Broadband Initiative, the BroadbandUSA program, and the relationships the agency has developed through the State Broadband Leaders Network.³⁴  Programs may serve different purposes and, therefore, require different expertise and relationships to implement.

With coordination and transparency, complementary federal deployment programs can be a means for different types of stakeholders to leverage multiple sources of funding to ensure that all areas achieve connectivity. In its technical assistance, NTIA has encouraged states to view the broadband deployment programs of the FCC, USDA, Treasury, and NTIA as “waves” of funding, with each successive program filling in gaps left by the preceding one. Programs are authorized and designed with different objectives, which may incentivize different applicants to enter the ecosystem. For example, the Rural Digital Opportunity Fund (RDOF) allowed technologies like low-Earth orbiting satellite and some fixed wireless technologies, to compete in the auction process. However, some of these applicants were unable to prove technological feasibility in the long-form application round, and their initial winning bids were not authorized.³⁵ Now those areas may be eligible for funding through USDA’s ReConnect program or state-run programs funded by CPF. Eventually, any remaining unconnected areas will be eligible for funding through a state’s BEAD subgrantee selection process. Migration, evolving technology, and a changing provider landscape mean that each year, new opportunities and obligations arise to connect more people to the Internet. Waves of funding help ensure locations that were missed, overlooked, or uncompetitive in previous grant programs still have the chance to be served by subsequent programs.

Administrative and Legislative Solutions to Reduce Overlap, Fragmentation, and Duplication