(The Benton Institute for Broadband & Society delivered the following letter to the
 National Telecommunications and Information Administration for the agency's BEAD Savings Listening Session)

Assistant Secretary of Commerce for Communications and Information Arielle Roth
National Telecommunications and Information Administration
1401 Constitution Ave., NW
Washington, DC 20230
[Delivered via e-mail broadbandgrants@ntia.gov]

February 13, 2026 

Assistant Secretary Roth,

In the Infrastructure Investment and Jobs Act (IIJA), Congress found that broadband is “essential to full participation in modern life” and that broadband’s benefits “should be broadly enjoyed by all.” That is the context in which the Broadband Equity Access and Deployment (BEAD) Program was created: Congress sought to address every facet of the digital divide and ensure that all people could actually benefit from this essential service—not simply have a network pass by their home. 

We appreciated Secretary Lutnick's recent testimony before the Senate Appropriations Committee in which he not only touted states’ ability to understand and address their unique needs, he also promised to make BEAD funds available “in alignment with the statute.” This is encouraging because the statute clearly allows states to use their BEAD funds to promote broadband affordability and adoption and gives them substantial deference in program design. 

Specifically, NTIA must allow states and territories to use BEAD funds to make subgrants to:

1. Deploy broadband networks to unserved and underserved areas;
2. Connect community anchor institutions;
3. Conduct data collection, broadband mapping, and planning;
4. Install internet and Wi-Fi infrastructure or provide reduced-cost broadband within multifamily residential buildings; and
5. Increase broadband adoption, including programs to provide affordable internet-capable devices. 

In addition, Congress authorized Assistant Secretary of Commerce for Communications and Information Arielle Roth to determine additional uses of these funds to facilitate BEAD’s goals. The Benton Institute for Broadband & Society is grateful that NTIA is conducting these listening sessions to refresh the record and ensure that Assistant Secretary Roth’s determination of additional uses reflects stakeholders’ latest thinking.

NTIA Must Follow the Law and Allow States to Address Broadband Affordability and Adoption

BEAD will not be successful unless it addresses the primary causes of the digital divide: broadband affordability and adoption. 

Study after study after study finds that the high cost of internet service is the primary reason Americans can’t get online. This is evident in the 40-percentage-point gap in broadband adoption rates between low- and high-income households, as shown in a 2025 Pew Charitable Trust survey. Only 54 percent of households earning under $30,000 per year subscribe to broadband, compared with 71 percent of rural households. BEAD cannot deliver “universal broadband” if NTIA prevents it from addressing this central cause of the digital divide. 

Fortunately, the statute enables states to address broadband affordability with BEAD support. The IIJA allows states to provide reduced-cost service in multi-dwelling residences. However, not everyone who struggles with affordability lives in such residences, so NTIA should use its statutory authority to allow states to address affordability wherever it is a barrier. 

Beyond affordability, Congress allows states to use BEAD funds to promote broadband adoption. The IIJA defines broadband adoption as the process by which an individual obtains high-quality internet service, digital skills, personal devices, and secure and convenient networks. 

We share Assistant Secretary Roth's concerns about online harms and support certain protections for online safety and well-being. We know from decades of experience that promoting safe broadband adoption, particularly among offline communities, requires person-to-person interactions best conducted by trained, trusted digital navigators. Non-deployment funding should support such efforts, including funding staff, training, devices, hotspots, outreach, and program administration. Not only are digital navigator programs essential to ensure all people can benefit from broadband, these programs also protect against the increasingly common and harmful online scams.

Finally, BEAD guidance should retain state flexibility and innovation. Congress intentionally designed BEAD as a state-led program because states understand their communities best. Rural, suburban, urban, and Tribal contexts vary significantly, and rigid federal prescriptions will undermine BEAD’s effectiveness. NTIA must remain faithful to the statute while empowering states to tailor their non-deployment investments to their unique needs.

Congress Designed BEAD to be Comprehensive

Congress created BEAD to enable states to address all facets of the digital divide—access, affordability, and adoption. This is abundantly clear from the statute itself. Congress explicitly authorized states to fund broadband deployment, affordability, and adoption. Congress was unambiguous that all of BEAD’s $42 billion should flow to the states, going so far as to reallocate unused funds among states rather than return them to the U.S. Treasury. And Congress’s objective when writing BEAD was that Americans should benefit from, not simply access, broadband, ensuring that American taxpayers got the full return on their investment.  

The Benton Institute urges NTIA to follow the statute and release states’ full BEAD allocations for use as Congress intended. 

Thank you.

/s/ Drew Garner
Director of Policy Engagement
Benton Institute for Broadband & Society

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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