Broadband Deployment Advisory Committee: Streamlining Federal Siting

Through its deliberations, the Streamlining Federal Siting Working Group Working Group found that the fundamental concerns regarding the streamlining of federal siting are 1) predictability and complexity of the application process and accompanying requirements and 2) the application review time. The Working Group offers ten recommentations:

1. Challenge: Varying and unpredictable fees and rates.

Solution: Standardize and publish fee schedules and utilize revenue in a way that promotes expediting federal siting processes.

2. Challenge: Lengthy application review times.

Solution: Require all federal landholding or managing agencies to prioritize broadband permitting. Implement a 60-day shot clock for application review with a deemed approved remedy and a 10-day shot clock for notification of additional materials request.

3. Challenge: Unharmonized application forms and unpredictable processes across agencies.

Solution: Require all federal landholding or managing agencies to use one standardized application form. Harmonize permitting processes across agencies to extent feasible and ensure the process is uniformly applied across regional and state offices. Recognize and accept existing completed studies in previously disturbed areas.

4. Challenge: Cumbersome historic and environmental review processes including environmental studies and Geographic Information System studies.

Solution: Harmonize environmental assessments across federal landholding or managing agencies, further streamline National Environmental Protection Act and National Historic Preservation Act exclusions, and eliminate duplicative environmental studies. Make current environmental and historic review streamlining mechanisms mandatory for all agencies.

5. Challenge: Lease and renewal terms that do not incentivize investment.

Solution: All leases and easements should have 30 or more-year terms with expectancy of renewal to better incentivize investment.

6. Challenge: Unclear points of contact for local, state, and federal leads for agencies.

Solution: Every project should have a single, clear point of contact for application review and follow-up.

7. Challenge: Difficulty getting updates on status of applications and lack of transparency in agency-deployment application process history.

Solution: There should be a single, easily accessible online-tracking mechanism at each federal agency for the permitting process. All agencies should regularly report on permit status, the number of permitting applications they have processed, and on coverage gaps.

8. Challenge: Lack of re-evaluation of processes and fees as technologies evolve.

Solution: The common application form should accommodate changes to existing installations and applicable leases and easements. Agencies should accommodate and incorporate new broadband infrastructure technologies into their review processes.

9. Challenge: Department of Defense Siting Process is costly and time-consuming.

Solution: Department of Defense (DoD) agencies should incorporate streamlining efforts utilized and recommended for other federal agencies and examine their military base broadband deployment permitting practices. DoD agencies should streamline their spectrum clearance processes.

10. Challenge: Siting barriers caused by federal funding clauses.

Solution: All federal land grant provisions directly or indirectly precluding broadband deployment should be eliminated.