CEI Joins Coalition Letter Regarding Wasteful RDOF Subsidies, Hamilton Place Strategies

Dear Ms. Dortch:

The Commission adopted its Rural Digital Opportunity Fund (“RDOF”) order last year despite concerns that it would subsidize the construction and operation of broadband facilities in some areas that already have at least 25/3 Mbps service.1 Concerns about the accuracy of the Commission’s broadband maps are widespread and bipartisan.2 Newly released information

from the Competitive Carriers Association (“CCA”) has called into question thousands of locations where RDOF funding is set to be awarded to subsidize areas that are served today. The FCC has the authority to require awardees to update their long-form applications with accurate broadband access data, and with the promise of billions of dollars of federal subsidies, it is appropriate for the Commission to take the step of requiring applicants to update their FCC filings.

CCA recently compared RDOF auction results to publicly available data about broadband access. By overlapping speed test data on RDOF areas, CCA found that nearly 286,000 locations with almost 403,000 people that are poised to receive scarce broadband subsidies already have robust connectivity. Indeed, CCA found that current awards are set to deploy between $144 million and $1 billion to subsidize broadband deployment to areas that are well- served today. These errors are especially troubling because RDOF Phase I awards were supposed to go to those most in need—areas “wholly unserved” by broadband. If a single household within an area was found to have broadband service, that area was intended to be considered for support later, in RDOF Phase II.

Unfortunately, RDOF’s first round is poised to send scarce federal dollars to some of the most connected, dense, and wealthy communities in the country rather than targeting only “wholly unserved” areas. CCA found that subsidies are targeted for:

  • Apple’s headquarters in Cupertino, California
  • The Massachusetts Institute of Technology’s campus in Cambridge, Massachusetts
  • Fisherman’s Wharf, the popular urban center and tourist destination in San Francisco
  • Chicago’s Inner Loop business district
  • Large international airports, like DFW International in Dallas-Ft. Worth and SFO International in San Francisco

We understand that the Commission was attempting to fulfill two mandates—fixing its maps and bridging the digital divide—with a sense of urgency. And we all agree that it is imperative to continue building high-speed networks quickly for those who so need it to participate in modern life—for remote learning, work-from-home, telehealth, and to connect with their communities. But the errors that have been surfaced thus far are not trivial or in the ordinary course of administering a large program. According to one CCA estimate, the FCC’s mapping errors threaten to waste up to $1 billion. That sum is almost three times the FCC’s annual budget.

It is incumbent on the Commission to devote resources to review questionable applications before dollars go out the door, and CCA provides a useful playbook for doing so. Publicly available data led CCA and could lead the Commission to scrutinize awarded areas that crowdsourcing shows have robust broadband access. CCA also used Census data on population density and household income, which the Commission has recognized are highly correlated with broadband access. The FCC has the authority to require awardees to update their Commission filings with accurate broadband access data, and with the promise of billions of dollars of federal subsidies, it is appropriate that awardees assist the Commission in that effort.  The undersigned groups have a strong interest in bridging the digital divide and ensuring that ratepayers’ dollars are well spent. We stand ready to assist.

The FCC has called RDOF its “single biggest step to close the digital divide.” The FCC must act now to make RDOF live up to that lofty goal.


Jeffrey Mazzella


Center for Individual Freedom

Betsy Huber


National Grange

Douglas Holtz-Eakin


American Action Forum

(affiliation for identification purposes only)

Jennifer Huddleston

Director of Technology and Innovation Policy

American Action Forum

(affiliation for identification purposes only)

Ryan Nabil

Research Fellow

Center for Technology and Innovation

Competitive Enterprise Institute

Ernesto Falcon

Senior Legislative Counsel

Electronic Frontier Foundation

Matthew F. Wood

Vice President of Policy and General Counsel

Free Press

Jeffrey Westling

Technology & Innovation Policy Fellow

R Street Institute

Brandon Arnold

Executive Vice President

National Taxpayers Union

Greg Guice

Director of Government Affairs

Public Knowledge