Comments to NTIA on Broadband Implementation within the Infrastructure Investment and Jobs Act (IIJA)

By at 4 February, 2022, 2:07 pm

Comments to:

National Telecommunications and Information Administration (NTIA)

Docket No.:  220105–0002

Infrastructure Investment and Jobs Act Implementation


Dear Administrator Davidson:

The small business community is justifiably excited and supportive of elements of the Infrastructure Investment and Jobs Act (IIJA) that are aimed at modernizing and improving infrastructure so that small-to-mid-size businesses (SMBs) can operate more efficiently and competitively. The broadband piece of the infrastructure package is extraordinarily important to businesses lacking access, and for economic development in areas of the nation that are not digitally connected. Access to digital tools and the digital economy will open new markets for inclusive entrepreneurial opportunities and small business growth.

The Small Business & Entrepreneurship Council (SBE Council) is pleased to submit comments on IIJA’s implementation as it relates to broadband deployment. SBE Council is a nonpartisan, nonprofit advocacy, research and education organization dedicated to protecting small business and promoting entrepreneurship. With more than 100,000 members nationwide, SBE Council is engaged at the local, state, federal and international levels where we collaborate with elected officials, policy experts and business leaders on initiatives and proposals to enhance competitiveness and improve the environment for business start-up and growth.  For 28 years we have worked on a range of issues to strengthen the policy ecosystem. Technology and telecommunications policy has remained one of our core issues, as participation in the digital economy – with all of its tools and opportunities – is critical to small business success and growth, and the health of inclusive U.S. entrepreneurship and the economy in general.

The Broadband Equity, Access, and Development (BEAD) and Digital Equity Planning Grant programs represent a critical opportunity to greatly narrow the digital divide and help small businesses and economic development in digitally-barren areas of our nation. Therefore, the taxpayer resources dedicated through IIJA must be allocated with great efficiency and care to ensure digital connectivity is maximized through these programs.

As the National Telecommunication and Information Administration (NTIA) develops a framework for distributing the $48 billion allocated in support of these programs, we urge NTIA to keep small business owners and communities lacking access at the center of your efforts in crafting rules that will govern the distribution of taxpayer dollars associated with these important programs.

The longer it takes for communities and small businesses to get digitally connected, the further behind these local communities and their entrepreneurs will fall in the fast-moving digital economy. That means dollars and awards must be allocated with reasonable speed, to reliable partners, and with limited red tape and unnecessary rules that could undermine successful deployment.

Just as there is the need for speed in broadband connectivity, there is a need for speed in allocating broadband dollars to ensure small businesses and communities lacking access are not left behind as the digital economy surges forward. Transparent, simple and common-sense rules will help foster the expeditious allocation of resources and deployment.

SBE Council urges that NTIA adopt simple, transparent rules and common-sense principles to ensure the effectiveness of these programs, and to avoid waste and abuse of funds. These rules should promote:

● Uniformity across states to ensure consistency,

● Transparency and strong accountability in the use and deployment of funds,

● Partnerships with reliable providers,

● Adherence to the guardrails included in IIJA, including no mandates and creative restrictions – the focus must be on access and adoption,

● USF reform driven by user-friendly features for consumers that are uniform, simple, provide choice, and allow for low-cost offerings as a qualifying plan,

● And simplicity and clarity in the rules in general to ensure deployment and access occur with reasonable speed.

Many small businesses across America are counting on this program to deliver. Given the quality and experience of our nation’s providers – both large and small – backed by an efficient process and transparent framework, along with uniformity and sticking to what Congress advanced and intended through IIJA, SBE Council believes this promise can be met.

Again, many small businesses in rural and non-served areas of the country cannot wait another two, five, or ten years for broadband. As our chief economist Raymond Keating noted in a recent analysis of metro jobs numbers regarding the “unevenness” of job recovery and growth from the pandemic, it is clear that rural America is suffering. Even with the migratory changes of people during the pandemic, Keating writes:

“Rural America continues to face considerable challenges in terms of attracting people and businesses, and generating economic, income and employment growth.”

There is no doubt that broadband is a critical solution to economic development in these areas, and offers a key lifeline for hope and opportunity.

Thank you for the opportunity to comment on this proceeding, and please do not hesitate to contact me for questions or additional information.



Karen Kerrigan, President & CEO


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