February 23, 2026
The Honorable Jerry Moran
Chair
Subcommittee on Commerce, Justice, Science, and Related Agencies
U.S. Senate Appropriations Committee
Washington, DC 20510
The Honorable Chris Van Hollen
Ranking Member
Subcommittee on Commerce, Justice, Science, and Related Agencies
U.S. Senate Appropriations Committee
Washington, DC 20510
Re: Written Submission for the Record – “A Review of Broadband Deployment Funding at the Department of Commerce”
Dear Chair Moran and Ranking Member Van Hollen,
On behalf of National Taxpayers Union Foundation (NTUF), I respectfully submit this letter for the record in connection with the Subcommittee’s hearing entitled “A Review of Broadband Deployment Funding at the Department of Commerce.”
Following enactment of the Infrastructure Investment and Jobs Act and the launch of the Broadband Equity, Access, and Deployment (BEAD) program, the effectiveness of federal broadband investment increasingly depends less on aggregate funding levels than on execution capacity—specifically regulatory sequencing, permitting, cost control, and coordination across overlapping programs. As recent federal investments have expanded available capital, delivery outcomes are now shaped primarily by administrative, regulatory, and implementation constraints rather than by funding scarcity alone.
More specifically, in this environment, program effectiveness depends on how efficiently appropriated funds are translated into obligated projects, how quickly those projects move through permitting and regulatory processes, and how well implementation timelines are aligned across federal, state, and local actors. As a result, delayed obligations, extended construction timelines, and cost escalation now pose greater risks to program effectiveness than underfunding—directly affecting the value derived from existing appropriations and Congress’s ability to assess results within annual budget cycles.
As Congress reviews BEAD funding, greater attention to the following issues would strengthen oversight and delivery outcomes:
First, execution capacity increasingly represents the binding constraint on broadband deployment outcomes.
As federal investment has scaled rapidly, delivery discipline has become increasingly central to delivery performance. Where administrative and regulatory capacity lags available funding, unobligated balances can accumulate, timelines extend, and per-location costs rise. Strengthening execution capacity—rather than increasing funding levels—now offers the greatest opportunity to improve delivery outcomes and fiscal efficiency.
Second, permitting and regulatory sequencing remain significant sources of delivery risk.
Broadband deployment requires compliance with federal, state, and local permitting requirements, environmental reviews, and rights-of-way approvals that serve important public purposes. However, these processes frequently operate sequentially rather than in parallel and often without effective coordination across permitting authorities. As a result, procedural sequencing can delay projects in ways that are not inherent to construction, introducing avoidable uncertainty in delivery timelines and costs.
From an appropriations perspective, such delays complicate obligation schedules, increase exposure to cost escalation, and make it more difficult to evaluate program performance against expected timelines. Greater predictability in permitting—through clearer sequencing, earlier coordination, and alignment across relevant authorities—would improve the likelihood that appropriated funds are converted into operational infrastructure on schedule.
Third, federal funding should reinforce, rather than displace, private investment.
Broadband infrastructure remains highly capital-intensive and continues to rely on substantial private-sector investment. Public funding that is poorly sequenced or overly prescriptive risks displacing private build-out rather than accelerating it. Clear rules, predictable regulatory treatment, and stable tax policy are therefore integral to sustaining private capital alongside federal investment. In this context, tax provisions such as full expensing for capital investment can function as deployment enablers by lowering the after-tax cost of infrastructure investment without increasing direct federal outlays or programmatic spending.
Fourth, coordination and cost transparency are central to effective oversight.
The current broadband funding environment spans multiple federal agencies—including the Department of Commerce, the Federal Communications Commission, the Department of Agriculture, and the Department of the Treasury—as well as state broadband offices. This dispersion of responsibility across federal and state actors increases the risk of duplication, inconsistent standards, and fragmented delivery in the absence of effective coordination and transparency.
Absent effective coordination mechanisms, overlapping programs risk financing parallel deployments, applying inconsistent eligibility criteria, and imposing duplicative administrative requirements—each of which can contribute to higher per-location costs and delays in service delivery. More systematic reporting on deployment timelines, coordination with other federally funded projects, and aggregate cost trends across programs would strengthen congressional oversight and reduce fiscal risk.
Ultimately, the effectiveness of federal broadband investment depends less on the scale of appropriations than on the speed, cost, and durability of deployment. Execution capacity, permitting friction, coordination, and private-sector leverage now play a decisive role in determining whether broadband funding achieves its intended outcomes. Congressional attention to these factors can materially improve delivery performance without requiring additional federal spending.
Respectfully submitted,
Ryan Nabil
Director of Technology Policy and Senior Fellow
National Taxpayers Union Foundation
122 C St NW, Suite 700
Washington, DC 2000