Sarah Oh Lam

In these comments we explain why Title II classification is unnecessary and potentially harmful.  Specifically, we make the following points: 

Some policymakers are calling for money to subsidize middle-mile networks. Because it is so difficult to precisely define “middle mile,” and therefore identify and measure its outcomes beyond simply being built, it’s hard for politicians and recipients of the money to resist their spending spree of federal funds regardless of whether it’s needed. More middle-mile funding can generate new construction and a ribbon-cutting ceremony, but nobody will ever know if it generated more broadband. 

[Sarah Oh Lam is a senior fellow at the Technology Policy Institute]

Several core recommendations emerge from this history of broadband policymaking:

The Federal Communications Commission asks a series of questions about the current set of programs supported though the Universal Service Fund, particularly in light of the broadband initiatives funded through the American Rescue Plan Act of 2021 (ARPA) and the Infrastructure Investment and Jobs Act (IIJA). Commenters have focused heavily on how to fund universal service programs given the problems with the current contribution mechanism and ways to modify existing support programs. We have reviewed these comments and respectfully submit reply comments.

The Technology Policy Institute recommends that the National Telecommunications and Information Administration (NTIA):