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:

On behalf of Pennsylvania Farm Bureau (PFB), the state’s largest general farm organization, I am writing to submit comments related to Docket Number NTIA–2021–0002. We appreciate the opportunity to submit comments to help the development and implementation of broadband programs authorized as part of the Infrastructure Investment and Jobs Act or the Bipartisan Infrastructure Law (BIL).

As an organization, increasing broadband access has long been a priority issue, and Farm Bureau was happy to support the BIL, which provided a historic investment in broadband programming. The bill provides a key opportunity to expand broadband access to the millions of rural residents who lack access. Administering funding – as well as expanding access to broadband – should be done in a technology-neutral manner, to make sure providers have flexibility to serve as many people as possible by using the best technology for a given unserved and underserved area.

Additionally, we encourage the NTIA – as well as any state or federal entity formulating broadband plans – to consult with farmers, agricultural business owners and rural residents, and as any organizations serving the agricultural industry and rural communities to ensure those with first-hand knowledge of the connectivity challenges in rural communities are heard.

There are plenty of citizens who are being left behind, particularly in rural areas. In Pennsylvania, roughly 18 percent of rural citizens lack access to internet service, or only have low-speed options. Research performed by the Center for Rural Pennsylvania in 2018 found that median broadband speeds across most areas of the state did not meet the FCC’s criteria to qualify as broadband. In fact, research showed that there were no counties in Pennsylvania where at least 50 percent of the populace received broadband connectivity. This is a significant problem when you consider how essential broadband is for life today.

Broadband is a critical tool for modern agriculture. Farmers and agricultural business owners rely on broadband access to manage and operate successful businesses. For instance, farmers are using precision agriculture techniques to make decisions that impact the amount of fertilizer they need to purchase and apply to their fields, the amount of water needed to sustain crops, and the amount and type of herbicides or pesticides needed. Additionally, access to broadband is essential for farmers to be more efficient, follow commodity markets, communicate with their customers, gain access to new markets around the world and, increasingly, to ensure regulatory compliance.

Additionally, broadband is an increasingly critical component which contributes to the quality of life in rural communities. As we found during the pandemic, rural families who lacked internet – or a reliable broadband connection – were unable to fully take advantage of remote schooling, working from home, telehealth, or simply the same entertainment choices as those who had broadband. This is not acceptable. Broadband is no longer a luxury, but a necessity .Over the last few years, the COVID pandemic only highlighted the challenges for the population who have no internet, or only low-speed access. Increased investment in developing a modern broadband infrastructure, accountability for those accepting government funds for broadband improvement and buildout, and ensuring buildout reaches citizens in the “last mile” is critical. We cannot let rural citizens be left on the wrong side of the digital divide.

Pennsylvania Farm Bureau supports the comments submitted by the American Farm Bureau Federation (AFBF) to this docket and asks that this support be noted as part of the comment record. AFBF’s comment letter specifically provides answers to all questions posed by the National Telecommunications and Information Agency (NTIA) where Farm Bureau has applicable policy and are most relevant to Farm Bureau’s advocacy efforts. In addition to our statement of support regarding AFBF’s comment letter, I’ve highlighted several key points of Farm Bureau policy below which can be applied in general response to questions posed by the NTIA. Farm Bureau policy supports:

• Requiring companies that win broadband spectrum bids to quickly build out infrastructure or face significant fines for failing to do so. Any fines should be earmarked for broadband infrastructure in underserved rural areas;
• Multiple sources and increased levels of funding for developing and expanding broadband and cellular network access to rural areas;
• Standardizing the minimum acceptable speed for all federally-funded broadband projects to a speed not less than 100 Mbps/100Mbps;
• Increasing high speed internet access in rural areas through any source, including wireless, by using a combination of tax incentives, grants and/or regulations. Networks should meet and exceed the FCC’s definition for broadband;
• Increased cooperation among Internet providers to improve access to broadband in rural areas through coordination/sharing of either current assets or the installation of necessary infrastructure;
• Identification of underserved areas in regards to broadband availability and the prioritization of those areas in terms of resource allocation;
• Accurate mapping of broadband services to be more comprehensive and granular, including requiring providers who have been awarded funding to report accurate service area maps with governing bodies;
• The federal government opening federal property to improve rural mobile and broadband coverage;

Thank you for the opportunity to provide comment today. We look forward to working with the NTIA on broadband in the future.

Sincerely,

Rick Ebert President