Local Perspectives on Broadband Funding
Inside the South Bend Connectivity Coalition’s public comments
This is a historic moment for digital access and equity. Unprecedented levels of funding from the Infrastructure Investment and Jobs Act are coming to ensure every American has access to high speed internet and all that comes with it.
Over $45 billion will be spent across two categories: the Broadband Equity, Access and Deployment Program ($42.45 billion) to build out high speed connectivity; and Digital Equity Act programs ($2.75 billion) to ensure that communities have the devices, skills, and access needed to maximize that connectivity. With internet access becoming increasingly essential in today’s world, this funding has transformative potential to bridge the digital divide and empower residents in communities across the country.
Most of this $45 billion will be granted to state broadband offices, which are tasked with creating plans and policies to distribute their allocated funding. To get all Hoosiers online, the Indiana Broadband Office (IBO) will be distributing $868 million in BEAD funding, as well as additional allocations for digital equity act funding, through subgrants statewide. As part of this funding process, IBO has produced two volumes of Connecting Indiana — guidelines for how it will distribute BEAD funding — and the state’s first digital equity plan to guide future Digital Equity Act funding. For each of these documents, IBO requested public comment from communities like ours. These comments could provide feedback on a wide variety of topics, including: IBO’s definition of high speed internet, who is eligible for funding, how the state is mapping broadband access, what counts as a low cost internet plan, and what strategies for digital equity the state is prioritizing.
For both volumes of BEAD guidelines and the Indiana Digital Equity Plan, we shared our feedback in public comments from the South Bend Connectivity Coalition, a partnership of local organizations working to bridge the digital divide.
In our comments, we emphasized the following:
- Ensure funding can reach municipal, nonprofit, and community-owned networks.
In South Bend, we have seen firsthand the value of public and private organizations working in tandem to provide connectivity:
- ChoiceLight, a 501c(3) nonprofit, provides open access dark fiber in our area. Working with private internet service providers (ISPs), ChoiceLight brings gigabit connectivity to over 300 business and anchor institution subscribers.
- In 2022, the South Bend Community School Corporation (SBCSC) launched a CBRS private LTE network in partnership with Hayes Towers and Crown Castle to provide free in-home internet access to over 150 low-income families.
- Since 2016, the City’s South Bend Open Wi-Fi network has provided free access to the public. Open Wi-Fi is now available at over 140 community sites citywide.
For both BEAD and Digital Equity Act funding, we see public networks and entities as critical to getting all of our residents online. Nonprofits and government entities can provide broadband initiatives with financial flexibility, deep community relationships, inclusive and effective procurement practices, and unique assets like public facilities. To ensure BEAD and Digital Equity Act projects are successful, sustainable, and innovative, we have asked IBO to ensure public entities will be eligible for funding to maximize these strengths.
2. Support open access infrastructure.
Open access networks are a valuable way to limit the costs of broadband, both for providers and end users. With these types of networks, the owner leases infrastructure on an open basis to ISPs who can use it to offer service to end users. This approach to broadband deployment allows multiple providers to come into an area with a single installation, contributing to long term competition while limiting construction costs.
In South Bend, ChoiceLight’s dark fiber network has demonstrated the value of open access infrastructure. When ChoiceLight builds out infrastructure to a new anchor institution or business, that organization can light their own fiber or choose from one of 15 partner service providers. With a one-time build, that organization gains multiple gigabit service options, promoting competition while keeping costs low for providers. In our comments, we encouraged IBO to specify how it will prioritize and incentivize the use of open access networks as it awards BEAD funding.
3. Increase the affordability of low-cost service options.
Since 2021, the Affordable Connectivity Program has bridged the broadband affordability gap for millions of Americans, including nearly 700,000 households in Indiana and over 8,600 households in South Bend. With future funding of the ACP uncertain, service plans with subsidized pricing for low-income families will be essential to ensuring that this progress is not erased.
To this end, the federal government is requiring that recipients of state BEAD funding must provide low-cost service options for households at or below 200% of the federal poverty line (the qualification for the Affordable Connectivity Program). States, however, are responsible for creating the guidelines for what an acceptable low-cost plan will look like.
For Indiana, IBO proposed that the maximum monthly charge for a low-cost plan would be 2% of the maximum ACP-eligible income.
For a household of one in 2023, this would have looked like:
Maximum eligible income: $29,160/year, $2,430/month
2% of $2,430 = $48.60/month
While this methodology would keep costs within the 2% guideline for households at the maximum eligible income, many ACP recipients have incomes significantly below the 200% federal poverty threshold, especially older residents and those with fixed incomes. In St. Joseph County, 49% of all ACP participants have qualified through Lifeline, which has a 135% federal poverty eligibility threshold. If low-cost plans are tethered to 2% of the maximum ACP-eligible income, many of the families who have benefited from ACP will not be able to keep their broadband spending within the FCC’s guidelines.
Therefore, we have asked IBO to tether its methodology to the maximum Lifeline-eligible income (135% of the federal poverty level). In 2023, this would have translated to a low-cost plan threshold of $30.58/month. While this cost would still not be affordable for many low-income families if ACP ends, this guideline represents a step in the right direction for maintaining broadband affordability while balancing considerations for ISPs with smaller or more expensive deployments.
4. Invest in research partnerships.
South Bend is fortunate to have the Notre Dame Wireless Institute, a global leader in wireless research, in our backyard. Partnerships with Wireless Institute faculty and students have shaped local connectivity initiatives while providing valuable on-the-ground findings to fuel wireless innovation. Since 2022 alone:
- Thought leadership from the Wireless Institute on shared spectrum and private wireless was integral to SBCSC’s private LTE deployment. Ongoing research of the network is contributing to improved performance for student use.
- The Wireless Institute and the City worked together to measure mobile data speeds citywide by leveraging City solid waste vehicles.
- The Wireless Institute and the City launched an innovative partnership to measure residential broadband performance using remote testing.
Based on these successes in South Bend, we have requested that IBO make grant funds for research partnerships and applications available in BEAD and Digital Equity Act funding, especially in the areas of spectrum innovation and broadband performance measurement.
5. Highlight community philanthropic partnerships as a strategy to catalyze digital equity initiatives.
In the Indiana Digital Equity Plan, IBO emphasizes the importance of digital equity ecosystems in getting members of a community online. As evidenced by our Connectivity Coalition, South Bend is committed to this ecosystem approach to digital equity. With funding from the Digital Equity Act, we hope to invest in and further cultivate South Bend’s digital equity ecosystem to support new programs and initiatives.
One strategy that cities like Baltimore, Cleveland, Kansas City, and Miami have used to build capacity in their digital equity ecosystems involves leveraging local philanthropy as sustainable partners in digital equity funding. Working with community foundations, these cities have created digital equity funds that regularly invest in nonprofit organizations to launch and expand connectivity initiatives.
South Bend and our area have many private and place-based foundations that have played a role in digital equity pilots and programming. In our comments, we requested that IBO identify the value of philanthropic partners in building local digital equity capacity in the Indiana Digital Equity Plan. Moreover, we asked that the State permit a portion of Digital Equity Act funds to seed dedicated digital equity funds housed at community philanthropic partners.
Looking Ahead
We are eager to continue these conversations with state and local leaders as we represent the needs of South Bend residents. We will be paying close attention to coming grant opportunities and are excited to work as committed partners with IBO to get all members of our community online.
To read the full comments from the South Bend Connectivity Coalition, please click the links below!
Coalition Comments — Indiana BEAD Volume I
