Tuesday, October 13, 2020

Final FCC Petition Filing. LULAC, Hispanic Federation, and National Latino Farmers and Ranchers Trade Association


October 12, 2020
Hon. Ajit Pai, Chairman
Hon. Jessica Rosenworcel, Commissioner
Hon. Michael O’Rielly, Commissioner
Hon. Brendan Carr, Commissioner
Hon. Geoffrey Starks, Commissioner
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

RE: Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, WC Docket No. 17-84

Dear Chairman Pai and Commissioners:

Our respective organizations have long advocated for digital inclusion and policies that ensure that
Latino and economically disadvantaged communities are able to benefit from the wide range of
opportunities offered by broadband access. While we do not speak to the legal arguments set forth in
the NCTA Petition in the above-referenced matter, we strongly support efforts to expand broadband
deployment in rural areas and encourage the FCC promptly to consider the NCTA Petition in order to
ensure that broadband is being delivered to rural areas in an equitable and time efficient manner.

While U.S. broadband networks have performed reasonably well during the pandemic, the pandemic
has exposed certain remaining and persistent gaps in the digital divide, especially in rural areas. Now
more than ever, access to reliable, high-speed internet is a necessity, as Americans have turned to the
internet for a range of digital services during the pandemic, including online learning, remote work, andtelehealth. Unfortunately, reports have shown that the vast majority of Americans lacking access to
high-speed internet live in rural areas.1 This includes communities of color which (on average) make up 20 percent of these rural communities.

Indeed, low-income Latino and Black individuals make up a significant portion of the millions of
households across the country that lack access to broadband, a disparity that is only further worsened
by the disproportionate economic impact COVID-19 has had on these communities in the form of temporary and permanent job loss.2 Hispanic and black Americans have been hit the hardest, with 61%
and 44% respectively reporting a job or wage loss due to Covid-19, compared with 38% of whites. High rates of unemployment in communities of color have only intensified the need for broadband access in rural communities, along with other emerging digital needs related to online schooling and access to telehealth services. The federal government and the FCC should take the steps needed to bridge this exacerbated digital divide.

In addition to providing financial resources where appropriate, these steps by Congress and the FCC
should include removing unnecessary legal, regulatory, and economic barriers to broadband
deployment and investment. Given the expansive geographic nature of most rural areas, eliminating
infrastructure barriers is critical and necessary to delivering broadband connectivity to rural households
and businesses.

COVID-19 has exposed the gaps that still exist in delivering high-speed internet to all Americans,
especially in rural areas. We hope that you will stand with us to expand opportunities by encouraging
broadband buildout and connecting as many rural communities as possible to the internet. There has
never been a more urgent time to ensure that rural unserved communities gain access to broadband as
soon as possible, including the millions of rural Hispanic and communities of color that have too often
been left behind.

We encourage timely review of the NCTA Petition in order to ensure that any barriers to rural
broadband deployment and investment are removed.


Sindy Benavides                     Frankie Miranda            Rudy Arredondo
Chief Executive Officer           President & CEO             President & CEO
LULAC                                    Hispanic Federation         Latinos Farmers & Ranchers

1 Rural Health Research Gateway, Disparities in Preventive Care by Race and Ethnicity Among Rural Adults -https://www.ruralhealthresearch.org/projects/100002425#:~:text=Currently%2C%201%20in%205%20rural,Preven
tion%20(James%20et%20al. “Currently, 1 in 5 rural residents is a person of color or American Indian, adding up to
nearly 10 million rural residents who are black, Latinx, Indigenous, Asian, or mixed-race.” Id.

2 According to recent findings by the Pew Research Center, “job and wage losses due to COVID-19 have hit Hispanic
adults the hardest.” Pew Research Center, Financial and health impacts of COVID-19 vary widely by race and
ethnicity, May, 5, 2020 - https://www.pewresearch.org/fact-tank/2020/05/05/financial-and-health-impacts-ofcovid-
19-vary-widely-by-race-and-ethnicity/. Pew reports that 61% of Hispanic Americans reported a job or wage
loss in their household due to the coronavirus outbreak, compared with 38% of white adults and 44% of black
Americans. Id

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