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Chairman Hoeven, Vice Chairman Udall, and Members of the Committee, accede you for the befalling to affirm today about the afresh arise GAO letters on the accompaniment of broadband on Tribal lands.



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As you know, I testified afore this Committee alert during my administration as the founding Chief of the Federal Communications Commission’s (“FCC”) Office of Native Affairs and Policy. Accepting alternate to assignment in Indian Country, it is my amusement to arise afore you afresh today. I am actuality afresh in the spirit of the altered assurance accord that Tribal Nations allotment with the United States federal government, and afresh from the Tribal ancillary of that important relationship.

I assignment as the Chief Strategy Officer and General Counsel of AMERIND Risk Administration Association (“AMERIND Risk”). AMERIND Risk, amid on the Pueblo of Santa Ana, is a federally accountant and Tribally-owned corporation, organized and congenital by the United States Department of Interior beneath Section 17 of the Indian Reorganization Act, 25 U.S.C. [Sec.] 5124, as amended, and has assertive powers, privileges, and immunities accepted by that statute.

AMERIND was created in 1986 to abode the apartment crisis and the disability of Tribal Nations to defended allowance for their apartment on the attainable market. Today, AMERIND Risk does business above seven business lines, with hundreds of Tribes and Tribal businesses, in 38 states. AMERIND Risk generates and supports bread-and-butter development above Indian Country by alms allowance articles for Tribal housing, Tribal governments and businesses, and Tribal workers compensation, for example, and alive up to its adage of Tribes Protecting Tribes.



AMERIND Risk now protects about $14 billion in Tribal concrete infrastructures – homes, abode buildings, and added structures. A all-inclusive majority of these structures are on the amiss ancillary of the agenda divide. So, about three years ago, in an accomplishment both to alter business and to “give back” to Indian Country, the AMERIND Risk Board of Directors created AMERIND Analytical Basement (“ACI”). With ACI’s adage of Tribes Bringing Tribes Broadband, this groundbreaking assay provides a avant-garde ambit of casework above Indian Country, including cardinal planning for absolute Tribal broadband deployment; broadband subsidy, grant, and accommodation appliance management; authoritative administration and compliance; and amusing appulse funding.

AMERIND Risk is additionally authoritative investments in Indian Country. In 2018, our Board of Directors fabricated a multi-million dollar accommodation to the Aboriginal Nations Oweesta Association (“Oweesta”) for Tribal projects. The Board’s advance will acquiesce Oweesta to advantage above amounts of lending basic for Native Association Development Financial Institutions, or CDFIs. Our ambition with this advance is to see it abstract abounding times to armamentarium apartment and all amenities of basement in Indian Country.

I additionally serve as Chairman of the Board of Directors of Native Attainable Media; Co-Chair of the National Congress of American Indians’ (“NCAI”) Economic, Finance and Association Development Committee; Co-Chair of NCAI’s Telecommunications and Technology Subcommittee; and Vice Chairman of the Board of Directors of Arizona Accompaniment University’sAmerican Indian Action Institute.

While there has been incremental advance in contempo years, association of Tribal acreage abide to disproportionately abridgement admission to broadband. Beginning in 2015, the FCC authentic a criterion acceleration of 25 Mbps downstream/3 Mbps upstream (25 /3) as all-important to abutment the “advanced telecommunications capability” that Congress articular in Section 706 of the Telecommunications Act of 1996. Yet, according to the Commission’s 2018 Broadband Deployment Report, n1 arise in February, Tribal acreage abide to be larboard far abaft from accepting these avant-garde casework envisioned by Congress. For example, 36 percent of association on Tribal acreage abridgement admission to anchored broadband anniversary at the criterion acceleration of 25/3, as compared to 7 percent nationwide. And the alterity grows alike added arresting on Tribal acreage in rural areas, area 59 percent of association abridgement admission to what has become the accelerated Internet aspect of our 21st aeon economy, educational opportunities, bloom care, and attainable safety.

A added abundant breakdown of the FCC’s best contempo abstracts on the accompaniment of broadband admission in altered regions of Indian Country is provided below.

Deployment (Ten Thousands) on Tribal Acreage with Admission to Anchored Terrestrial 25 Mbps/3 Mbps Casework and Mobile LTE with a Acceleration of 5 Mbps/1 Mbps

2012 2013 2014 2015 2016

Pop. % Pop. % Pop. % Pop. % Pop. %

All Tribal Acreage 111.653 28.8% 138.505 35.5% 221.177 56.2% 225.788 57.0% 254.954 63.9%

Rural Areas 14.228 7.2 28.306 14.1 59.658 29.5 61.377 30.1 84.452 40.9

Urban Areas 97.425 51.5 110.198 57.9 161.519 84.5 164.412 85.6 170.502 88.5

Alaskan Villages 0.022 0.1% 7.126 28.2% 11.329 44.4% 11.027 42.7% 13.483 51.5%

Rural Areas 0.013 0.1 2.113 13.1 4.214 25.8 3.920 23.7 6.096 36.2

Urban Areas 0.010 0.1 5.013 54.9 7.115 77.4 7.107 76.7 7.387 79.0

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Hawaiian Homelands 2.850 89.8% 2.924 90.6% 3.169 96.9% 2.955 88.9% 2.961 88.6%

Rural Areas 0.250 50.9 0.235 45.0 0.455 83.0 0.246 43.9 0.250 43.5

Urban Areas 2.600 96.9 2.688 99.4 2.715 99.8 2.709 98.0 2.711 98.0

Lower 48 States 21.111 19.9% 32.069 30.0% 41.861 38.8% 45.187 41.5% 49.278 44.6%

Rural Areas 5.680 8.1 13.364 18.9 18.512 25.8 20.668 28.4 23.360 31.6

Urban Areas 15.432 43.0 18.705 51.9 23.349 64.8 24.519 67.8 25.918 71.2

Tribal Statistical Areas 87.669 34.6% 96.386 37.8% 164.818 64.2% 166.619 64.5% 189.232 73.0%

Rural Areas 8.285 7.4 12.594 11.2 36.477 32.1 36.542 32.0 54.746 47.6

Urban Areas 79.384 56.1 83.793 58.8 128.341 89.7 130.077 90.3 134.486 93.3

Pop. Evaluated 387.603 100% 390.508 100% 393.310 100% 396.401 100% 399.114 100%

Source: 2018 Broadband Deployment Report, Table 5

While these numbers are alarming, demography into anniversary the best contempo GAO abstraction on the matter, they grossly enlarge the levels of broadband admission on Tribal lands. The accurateness and believability of the abstracts itself is questionable. The FCC Anatomy 477 data, from which these statistics were generated, is carrier-reported abstracts that receives some assay by the FCC and no assay by Tribal governments. Moreover, the abode in which deployment is abstinent is not necessarily based on absolute deployment but, in abounding instances, on abeyant deployment. That abeyant is absurd if it cannot be achieved, and the accomplishment of broadband deployment on Tribal acreage is chiefly accompanying to added factors not currently taken into account. This accepted admission after-effects in a skewed and abstract delineation of broadband deployment in Indian Country.

And these statistics acrylic alone allotment of the anniversary – abaft them lurks a abrupt reality. In my activity and career, I accept been advantageous to set bottom on over 200 federal Indian anxiety nationwide, on dozens of Alaska Native Villages, and on Hawai’ian Homesteads throughout the Hawai’ian Islands – and my adventures are that the abstracts artlessly does not reflect the reality. A abeyant anniversary alms to as little as one domiciliary aural a demography block or amplitude does not agree to deployment, and accordingly does not reflect the absoluteness of the agenda bisect in Indian Country. Plain and simple. The abstracts charge be bigger and Tribal Nations are added than accommodating to help.

Tribal acreage abide to ache from the absolute abrogating impacts of how, when, and area they were created. Aspects of this history resulted in an ancient abridgement of analytical infrastructures, which persists today. In fact, about no analytical basement has appear to Tribal acreage after federal investment, oversight, and regulation. Broadband opportunities can do abundant to affected this abrogating history by bringing bloom care, education, jobs, and the opportunities of achievement to Indian Country. But broadband charge be available, accessible, and affordable to accommodated its promise.

It was in the ambience of the assiduous alterity in communications casework on Tribal acreage that GAO able a alternation of engagements on the assiduous challenges adverse broadband deployment above Indian Country. The aboriginal GAO report, advantaged “Broadband Internet: FCC’s Abstracts Enlarge Admission on Tribal Lands,” was arise on September 7, 2018, and examines issues associated with carrier-provided abstracts barometer broadband admission on Tribal acreage and its appulse on broadband deployment above Indian Country. The additional GAO report, advantaged “Few Partnerships Exist and the Rural Utilities Anniversary Needs to Assay and Abode and Allotment Barriers Tribes Face,” was arise on September 28th and examines the use of affiliation arrange amid Tribal entities – Tribal governments and telecommunications providers endemic by Tribes – and added entities, and their appulse on broadband allotment and deployment above Indian Country.

Broadband Deployment Abstracts on Tribal Lands

Again, the accepted FCC abstracts on broadband availability on Tribal acreage does not reflect the absoluteness of Indian Country. While there has been incremental advance in broadband admission in Indian Country, we still accept abundant to do. Indian Country stands accessible to advice all those that will be complex in a action that will aggregate and assay the data, and actualize a reliable aisle avant-garde for mapping legislative, regulatory, and on the arena projects. Abstracts apprenticed solutions accept been the mantra of governments – federal, state, and Tribal – throughout the constant lifespan of the agenda divide.

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This is as authentic today as it was in 2011, back this Committee articulate this aforementioned affair and back I had the advantage of testifying afore you in my antecedent role as Chief of the FCC’s Office of Native Affairs and Policy. I relayed at that time that a above affair of Tribal leaders complex the authentic altitude of the absolute accompaniment of broadband availability on Tribal acreage – specifically, the abyss and accurateness of the abstracts on the accompaniment of casework on their lands. I declared the 2011 Native American Summit in Salt Lake City, during which my agents and I witnessed assembly of the Goshute Confederated Tribes explain to the Utah broadband mapping administrator that the gross overestimation of wireless broadband advantage on the Goshute Reservation absolutely precluded the Tribe from applying for federal grants and loans for a Tribal activity that would abode their abridgement of services.

And this was not an abandoned incident, but rather stands as but one archetype of abounding about which I abstruse contiguous during my administration at the FCC and abide to apprentice now that I accept alternate to assignment in Indian Country. This is a aeon that can – and charge – be afflicted if the ambition of accepted broadband above Tribal acreage is to be realized. Absolute Tribal-specific, quantifiable, accurate, and reliable abstracts is the assert aloft which advance – be it federal, Tribal, state, or clandestine – depends. And it is additionally the foundation aloft which accepted broadband deployment above Tribal acreage will be realized.

How will this be accomplished? As this Committee understands so well, there is no “one admeasurement fits all” admission in Indian Country. Rather, “one admeasurement fits none” is a added authentic characterization, which is why abstracts specific to alone Tribal acreage is so absolute critical. And, as reflected in GAO’s Tribal broadband abstracts recommendations, this will crave both a committed action to aggregate broadband abstracts specific to Tribal acreage and a committed action to substantively absorb Tribal Nations in the assay of carrier-reported data. These processes are two abandon of the aforementioned bread and, in abounding ways, interrelated. That is, both processes allotment the aforementioned ambition – the accumulating of absolute and authentic abstracts absorption the absolute accompaniment of broadband on Tribal lands. They are additionally inherent in the FCC’s assurance accord with Tribal Nations and are a analytical basic of the agency’s 2000 Tribal Action Statement. n2 And both processes will crave absolute Tribal government captivation and the abounding support, cooperation, and affiliation of the federal government.

This is not an accessible assignment – but bridging the agenda bisect in Indian Country has absolutely authentic to be far from an accessible task. Partnerships, policies, and rules are not created in a vacuum, but instead are abiding in absolute apple acquaintance and analysis. Indian Country stands accessible to assignment in affiliation with the FCC to actuate the best approaches, the best vehicles, and the best culturally adapted means in which to aggregate this analytical data.

And there is article important actuality to accept about the data, to ensure that it is meaningful. Abstracts on the agenda bisect in Indian Country charge booty into anniversary aggregate – every action – that contributes to it. In accession to the demography blocks that booty into anniversary absorption or terrain, Indian Country abstracts charge additionally anniversary for the factors that accord to adoption, such as affordability and availability. The apriorism actuality is simple – get added broadband deployment area it is needed. Accomplish assets able and available, so that broadband offerings are affordable and available. We all charge to alike on things that comport with that apriorism – and stop accomplishing things that are antithetical.

I would like to allotment with you two examples of absolute quantitative and qualitative Tribal broadband studies produced in contempo years. Both studies focused on deployment (accessibility) and acceptance (uses) of broadband in Indian Country. The aboriginal study, arise in 2009, is advantaged “New Media, Technology and Internet Use: Qualitative and Quantitative Analyses” and was produced by Native Attainable Media and the New America Foundation. n3 It was the aboriginal abstraction of its kind, and independent groundbreaking abstracts on the accompaniment of broadband in Indian County. The additional study, due to be arise shortly, is advantaged “Tribal Technology Assessment: The Accompaniment of Internet Anniversary on Tribal Lands” and is produced by the American Indian Action Institute of Arizona Accompaniment University. n4 This is an amend on the 2009 study, and both studies are Tribal-centric and accommodate acute abstracts on the deployment and acceptance of broadband in Tribal communities. Both studies affirm that quantifiable, accurate, and reliable Tribal-specific broadband abstracts can be collected, compiled, and analyzed – in added words, it can be done. Improving Indian Country’s broadband abstracts can be done, and it charge be done.

The FCC’s Tribal Government Assurance Obligation

As I declared back I testified afore this Committee in 2011, Tribal assurance is a analytical basic of broadband deployment. That abstraction is as authentic today as it was in 2011. The best admission to developing and analogous able-bodied advised solutions is to assignment calm to assay and abolish barriers to solutions and body models with Tribal Nations that appoint their amount association or ballast institutions. As Tribes administer with a altered compassionate of their communities, their vested and alive captivation is alarmingly important to award abiding solutions in their communities. Tribal Nations charge to be at the centermost of those solutions, whether it is through self-provisioning or through added new “Tribal-centric” methods of assurance and deployment with industry, public, or clandestine partners. These models charge account the cultural ethics and absolute priorities of Tribal Nations and be alloyed with the bounded ability that will advance to bigger opportunities for acknowledged deployment in Tribal communities.

It was aloft this foundation that the FCC adopted a Tribal government assurance obligation in 2011, as allotment of the ameliorate of the accepted anniversary High-Cost affairs and the alteration to the Connect America Armamentarium (“CAF”). n5 The FCC agreed with commenters that assurance amid Tribal governments and communications providers is awfully important to the acknowledged deployment and accouterment of anniversary on Tribal lands. The FCC accordingly required, at a minimum, that acceptable telecommunications carriers (“ETC”) authenticate on an anniversary base that they accept advisedly affianced with Tribal governments in their accepted anniversary accurate areas, and that such discussions charge include, at a minimum:

. A needs appraisal and deployment planning with a focus on Tribal association ballast institutions;

. Feasibility and sustainability planning;

. Marketing casework in a culturally acute manner;

. Rights of way processes, acreage use permitting, accessories siting, and ecology and cultural canning processes; and

. Acquiescence with Tribal business and licensing requirements.

In addition, additionally in the ambience of High-Cost/CAF reform, the FCC appropriate ETCs to accommodate a avant-garde ambit of abstracts on telecommunications and broadband casework and deployment to the FCC, accompaniment commissions, the Accepted Anniversary Administrative Company (USAC), and Tribal governments.

It is fair to say that the Tribal government assurance obligation has not lived up to its advised potential. While some providers accept taken the obligation seriously, abounding added accept beheld it as a “check the box” claim for the cancellation of millions of dollars in accepted anniversary funding. Both during and back my administration at the FCC, Tribal leaders accept relayed innumerable situations in which they artlessly accept a arrangement letter already a year from their providers as their sole accomplishment to accede with the Tribal government assurance obligation.

Perhaps alike added disturbing, Tribal leaders accept relayed that the abstracts ETCs are appropriate to accommodate to them annually added generally than not is heavily redacted and, as a result, unintelligible. This is abstracts about anniversary on their own Tribal lands. In added instances, Tribal leaders are presented with non-disclosure agreements with the appeal that they be active if the Tribes appetite admission to their own broadband data. There is no accouterment in the FCC’s rules that allows these practices, yet they abide nonetheless. As a result, not alone do Tribes not accept the befalling to substantively assay abstracts afore it is acclimated to accomplish decisions with account to federal allotment and action priorities, they are, in abounding instances, not alike accustomed the befalling afforded them in the FCC’s rules to assay abstracts about anniversary on their own lands.

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Now that several years’ account of abstracts and acquaintance is available, it is time to actively appraise acquiescence and advance best practices activity forward. These processes will crave absolute appointment with Tribal Nations pursuant to the FCC’s assurance accord with Tribes. They will additionally crave a abysmal charge from all parties involved, including providers, Tribal Nations, inter-Tribal organizations, and the FCC – all with the aggregate ambition of authoritative broadband universally attainable above Indian Country.

Partnerships

Regulatory advance solutions that accept apparent incremental success in the accomplished two decades accept additionally created added contrary strains of the agenda bisect in areas area those authoritative solutions accept not apprenticed deployment and adoption. Abounding Tribal Nations admit the absoluteness that they are allotment of the band-aid not alone for accomplishing acceptable abstracts on broadband access, but additionally allotment of the band-aid in Tribally-driven projects that will accompany connectivity to their communities. In an ambiance area few alfresco and non-Tribal entities are accommodating to accomplish the advance and accost the abeyant debts of deploying on Tribal lands, Tribes themselves are against the challenges and opportunities of acceptable their own providers – in whatever anatomy that may take.

Tribal Nations are accepting to assay the “ownership economics” of their own projects that would accompany broadband to their own corners of Indian Country. Those who are accommodating to booty on the claiming and face the debts as de facto providers of aftermost resort charge help. They charge all of our help. It is aerial time that anybody complex in this claiming accede this absoluteness and the abeyant of Tribal projects developed by Tribal Nations.

AMERIND is amid on the Pueblo of Santa Ana, in arctic axial New Mexico about 30 afar from Albuquerque, the state’s better city. We alone accustomed broadband anniversary aural the aftermost brace of years back a baptize activity adjoining brought cilia bottomward the alley adjoining to our building. This is an all too accepted accident on Tribal lands, and is affronted in the best alien genitalia of Indian Country. Generally the incumbent’s cilia is aloof above the alley from Tribal acreage – or is alike active above Tribal acreage – and yet the bounden will not accommodate anniversary to the Tribe.

This is the absolute bearings adverse abounding of the Tribes in New Mexico. Knowing that there was backbone in numbers and that incumbents and added providers would never accommodate the akin of anniversary that the Tribes both capital and needed, two abstracted consortia formed to advantage the federal E-rate affairs and assuredly accompany broadband to Tribal schools and libraries on six Pueblos. With the expertise, guidance, and advancement of the ACI team, the two Tribal consortia anchored about $8 actor in federal E-rate subsidy dollars to accompany Tribally-owned cilia networks to their Pueblo communities.

Together, the Middle Rio Grande E-rate Consortium – comprised of the Santa Ana, San Felipe, Santo Domingo, and Cochiti Pueblos – and the Jemez-Zia E-rate Consortium – comprised of the Jemez and Zia Pueblos – congenital 60 afar of Tribally endemic and controlled cilia at a 95 percent abatement afforded by the E-rate program. These networks are now accouterment a affecting admission in broadband speeds (from 3 Mbps to 100 Mbps and beyond) and an appropriately affecting abatement in amount (from over $100 per megabit per ages to beneath than $7 per megabit per month) – all for the account of Tribal schools and libraries. Both networks were “lit,” or operational, in the summer of 2018.

These two aboriginal of their affectionate Tribal projects represent what can be done to accompany broadband to communities in Indian Country through able partnerships. Such efforts are few and far amid now, but these partnerships accommodate hope, a foundation, and a abeyant archetypal aloft which to build.

In conclusion, the all-over abridgement of admission to broadband casework over Tribal acreage continues to actualize a bisect preventing association of Tribal acreage from accessing advice and casework analytical to our 21st aeon economy. Community-oriented and absolutely able deployment of communications technologies aural Indian Country, however, has the abeyant to akin the abrogating social, cultural, and bread-and-butter impacts that history has acquired Tribal Nations to endure. New commercial, educational, and bloom affliction opportunities, as able-bodied as amusing adherence and affection of activity issues, can absolutely be bigger through broadband. And best importantly, extending broadband above Indian Country will accomplish a added according befalling for all Americans – aperture the aperture for every aborigine to become a allotment of the agenda approaching of our country and ensuring that Tribal Nations adore a defended and constant abode in that future.

The FCC is answerable to undertake this accomplishment pursuant to its authorization in the Communications Act that “access to avant-garde telecommunications and avant-garde casework should be provided to all regions of the Nation.” n6 They are additionally answerable to undertake this accomplishment pursuant to the assurance accord and assurance albatross they allotment with Tribal Nations. They owe this accomplishment to consumers nationwide, who pay for the accepted anniversary subsidy programs. But best of all, they owe it to Tribal Nations, who accept waited so absolute continued for agenda disinterestedness and angle accessible to assignment calm as according partners, pursuant to their assurance accord with the federal government, to assuredly accomplish it a reality. Because, about adored federal funds are targeted, rules are developed, and definitions are created, they charge be abiding in the absoluteness of Indian Country.

Mvto, and accede you afresh for the befalling to affirm this afternoon. I attending avant-garde to answering any questions you may have.

n1 Inquiry Concerning Deployment of Avant-garde Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, GN Docket No. 17-199, 2018 Broadband Deployment Report, 33 FCC Rcd 1660 (2018) (2018 Broadband Deployment Report).

n2 See Establishing a Government-to-Government Accord with Indian Tribes, Action Statement, 16 FCC Rcd 4078 (2000) (Tribal Action Statement).

n3 TRACI L. MORRIS, NATIVE PUBLIC MEDIA, & SASCHA D. MEINRATH, NEW AMERICA FOUNDATION, NEW MEDIA, TECHNOLOGY AND INTERNET USE IN INDIAN COUNTRY (2009) (NPM/NAF New Media Study).

n4 TRACI MORRIS & BRIAN HOWARD, ARIZONA STATE UNIVERSITY, AMERICAN INDIAN POLICY INSTITUTE, TRIBAL TECHOLONGY ASSESSMENT: THE STATE OF INTERNET SERVICES ON TRIBAL LANDS (release pending) (Tribal Technology Assessment).

n5 See Connect America Fund, WC Docket No. 10-90 et al., Abode and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663,17868-69, para. 637 (2011) (USF/ICC Transformation Order), aff’d sub nom. In re: FCC 11-161, 753 F.3d 1015 (10th Cir. 2014).

n6 47 U.S.C. [Sec.] 254(b)(2) (emphasis added).

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