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Not surprisingly, policymakers are finding it challenging to keep up with all these developments. As but one stark example, the FCC, in its 2026 Section 706 Report released in August, noted that its Broadband Funding Map, a tool intended to facilitate interagency coordination, "does not yet include all of the funding commitments made as part of" the BEAD Program.
Have Congress and the various agencies responsible for distributing broadband infrastructure deployment subsidies allocated too much, allocated too little, and/or misallocated funding to locations already served? Today it is impossible to say – and that is precisely the concern. For as I cautioned in a November 2022 Perspectives from FSF Scholars, "the appropriation of more money than the objective requires invites waste, fraud, and abuse, along with private investment-suppressing overbuilds of existing broadband infrastructure."
Until the impact of subsidized construction projects already underway, many with multiyear buildout deadlines, is readily apparent, it would be prudent for Congress to pause the appropriation pipeline, lest more taxpayer dollars than necessary be spent. Pending legislative proposals – such as the Agricultural Act of 2026, which would authorize the appropriation of $100 million annually for fiscal years 2027 through 2031 – should move forward only if, at an appropriate point in the future, an evidence-driven determination is made that additional money in fact is required.
And, importantly, given the current level of uncertainty, including whether any more subsidies at all are needed to complete the largely achieved goal of universal broadband deployment, Congress should make no definitive judgments now regarding reform of the Universal Service regime. This is especially true with regard to the High-Cost Fund. This does not mean that the ongoing congressional efforts to reform the Universal Service regime should not continue. But it does mean it would be ill-advised to lock-in additional deployment subsidies before the impact of already committed federal spending becomes much clearer.
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