February 4, 2022

The Honorable Alan Davidson
Assistant Secretary of Commerce for Communications and Information National Telecommunications and Information Agency
United States Department of Commerce 1401 Constitution Avenue, NW Washington, DC 20230

Re: Infrastructure Investment and Jobs Act Implementation, Docket No. NTIA–2021–0002 Dear Assistant Secretary Davidson:

The American Farm Bureau Federation (AFBF) is the nation’s largest general farm organization representing farmers and ranchers in all 50 states and Puerto Rico. AFBF appreciates the opportunity to submit comments to inform the development and implementation of broadband programs authorized as part of the Infrastructure Investment and Jobs Act or the Bipartisan Infrastructure Law (BIL).

Expanding access to rural broadband has long been a priority for AFBF, and our organization was pleased to support the BIL, which provided a historic investment in broadband programming. Farmers and ranchers depend on broadband for the viability of their operations, just as they do highways, railways and waterways to ship food, fuel and fiber across the country and around the world. Many of the latest yield-maximizing farming techniques require wireless broadband connections for data collection and analysis performed both on the farm and in remote data centers.

Rural communities need access to health care, government services, and educational and business opportunities. For these communities, access can only be realized through broadband services and sophisticated technologies that require high-speed connections. Current and future generations of rural Americans will be left behind their fellow citizens if they are denied affordable broadband service that enables them to tap into health care, education and government services and new business opportunities.

The Request for Comment published in the Federal Register listed several questions for stakeholders on various topics related to the development and implementation of new broadband programs. AFBF is providing responses to questions for which the organization has policy and are most relevant to our advocacy efforts.

Question 1. What are the most important steps NTIA can take to ensure that the Bipartisan Infrastructure Law’s broadband programs meet their goals with respect to access, adoption, affordability, digital equity, and digital inclusion?

The BIL provides a historic opportunity to expand broadband service to the millions of rural residents that do not currently have access. Farm Bureau policy supports expanding broadband access in rural areas through any source as well as the prioritization of resources for unserved and underserved areas. It is critical that the agency administers funding in a technology-neutral manner to enable providers flexibility to serve as many people as possible by utilizing the best technology for a given unserved and underserved area. This will ensure funding is being used in an efficient manner and that more communities are reached.

AFBF policy supports mapping of broadband services to be more accurate, comprehensive and granular, including requiring providers who have been awarded funding to report accurate service area maps with governing bodies. With limited funding and an overabundance of need, more granular and accurate maps are critical to successfully target and distribute federal broadband programs. Our organization was a strong proponent of the passage of the Broadband Deployment Accuracy and Technological Availability (DATA) Act of 2020 which required the Federal Communications Commission (FCC) to collect more granular service availability data from broadband providers. We encourage the agency to work with the FCC in the development of accurate broadband maps to ensure federal resources within the BIL are targeted appropriately.

Question 2. Obtaining stakeholder input is critical to the success of this effort. How best can NTIA ensure that all voices and perspectives are heard and brought to bear on questions relating to the Bipartisan Infrastructure Law’s broadband programs? Are there steps NTIA can and should take beyond those described above?

AFBF agrees that stakeholder input is critical to the deployment of the new broadband programs authorized under the BIL. AFBF appreciates the outreach opportunities that have been afforded thus far through virtual listening sessions and the Request for Comment. As the agency contemplates additional stakeholder outreach opportunities, AFBF encourages the agency to ensure states and territories develop thorough outreach strategies to allow for additional feedback as plans are developed.

Question 3. Transparency and public accountability are critical to the success of the Bipartisan Infrastructure Law’s broadband programs. What types of data should NTIA require funding recipients to collect and maintain to facilitate assessment of the Bipartisan Infrastructure Law programs’ impact, evaluate targets, promote accountability, and/or coordinate with other federal and state programs? Are there existing data collection processes or templates that could be used as a model? How should this information be reported and analyzed, and what standards, if any, should NTIA, grant recipients, and/or sub-grantees apply in determining whether funds are being used lawfully and effectively?

AFBF policy supports transparency of government spending at all levels and recommends states and territories be required to develop transparency plans as part of state and territory proposals. Grant recipients and/or sub-grantees should be required to establish deployment goals to ensure recipients are held accountable and utilize federal funds in an efficient manner. The number of unserved and underserved locations connected through broadband programs should serve as a metric for those entities that receive awards.

Question 7. NTIA views the participation of a variety of provider types as important to achieving the overall goals of the Bipartisan Infrastructure Law broadband programs. How can NTIA ensure that all potential subrecipients, including small and medium providers, cooperatives, non-profits, municipalities, electric utilities, and larger for-profit companies alike have meaningful and robust opportunities to partner and compete for funding under the programs?

As mentioned above, it is critical that the agency administers funding in a technology-neutral manner to enable providers flexibility to serve as many people as possible by utilizing the best technology for a given unserved and underserved area. States should also adhere to this as applicants are considered. Additionally, AFBF supports increased cooperation among providers to improve access to broadband in rural areas through coordination and sharing of either current assets or the installation of necessary infrastructure to allow for efficient deployment. Programming from the BIL should encourage strong cooperation among providers through the sharing of assets.

Question 15. In its effort to ensure that BEAD-funded networks can scale to meet Americans’ evolving needs, and to ensure the public achieves the greatest benefit from the federal investment, NTIA seeks to understand reasonably foreseeable use cases for America’s broadband infrastructure over the next five, ten, and twenty years. What sort of speeds, throughput, latencies, or other metrics will be required to fully connect all Americans to meaningful use over the next five, ten, and twenty years? How can the BEAD program meet our nation’s broadband network connectivity needs in the future and what other benefits can Americans expect from this program and the networks it will help fund in other industries and across the economy? How can existing infrastructure be leveraged to facilitate and amplify these benefits? What are the best sources of evidence for these questions and for predicted future uses of broadband?

AFBF policy supports networks meeting and exceeding the FCC’s definition of broadband. However, understanding the technology needs of modern agriculture, our grassroots leaders recently adopted policy supporting a goal of standardizing the minimum acceptable speed for all federally funded broadband projects to 100Mbps/100Mbps.

Access to broadband is essential for farmers and ranchers to utilize the latest precision agricultural equipment, follow commodity markets, communicate with their customers, gain access to new markets around the world, and increasingly, for regulatory compliance.

Farmers and ranchers embrace technology that allows their farming businesses to be more efficient, economical, and environmentally sensitive. Today’s farmers and ranchers are using precision agricultural techniques to make decisions that impact the amount of fertilizer a farmer needs to purchase and apply to the field, the amount of water needed to sustain the crop, and the amount and type of herbicides or pesticides the farmer may need to apply. These are only a few examples of the ways farmers use broadband connectivity to achieve optimal yield, lower environmental impact and maximize profits.

Precision agricultural equipment requires a wireless broadband connection for data collection and analysis performed both on the farm and in remote data centers. As more precision equipment becomes available, farmers and ranchers cannot take full advantage of that equipment if they do not have access to wireless broadband in the field or on the ranch. A 2021 study, “The Future of American Farming: Broadband Solutions for the Farm Office, Field, and Community,” released by the Benton Institute for Broadband Society and sponsored by the United Soybean Board, found that to meet the growing demand among farmers for both upstream and downstream speeds, networks must be capable of 100/100 Mbps service. Upload speeds are often more important to farmers and ranchers as they need to upload data at faster speeds than they need for downloading it.

As the agency contemplates future broadband needs, AFBF recommends the agency coordinate closely with the United States Department of Agriculture Rural Utilities Service as well as the FCC Precision Ag Connectivity Task Force to support the interests of rural communities and agriculture.

Question 20. When formulating state broadband plans, what state agencies or stakeholder groups should be considered in the development of those plans?

Farmers, ranchers, and rural residents of unserved and underserved areas should be consulted in the development of state broadband plans. In addition, organizations that advocate for and serve the agriculture industry and rural communities should be involved in the development of these plans. It is imperative that those with firsthand knowledge of connectivity challenges in rural communities, in particular those active in farming and ranching, are included in discussions moving forward. AFBF is comprised of Farm Bureau organizations in all 50 states and Puerto Rico, all of which have strong grassroots leadership and membership within their counties.

Broadband is essential to modern agriculture, the farmers and ranchers who grow our food and the quality of life for rural Americans. Farm Bureau is encouraged by the possibilities the BIL presents for expanding broadband access across the country and looks forward to working with the agency as implementation moves forward. Thank you for the opportunity to provide comments.

Sincerely,

Sam Kieffer

Vice President, Public Affairs
American Farm Bureau Federation