Institute of Communications Research, founded by Wilbur Schramm - and its core principles. This would go on to be the home of James Carey, among others.
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Macroeconomics- Movie Location
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Exploiting Artificial Intelligence for Empowering Researchers and Faculty, In...Dr. Vinod Kumar Kanvaria
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2. et al., 2011). Equally, much is known about the primary telecommunications regulator in the US – the Federal Communications
Commission (FCC) - and its role in encouraging access to telecommunications services through its various universal service programs
(Mueller, 1998). Little, however, is known about the agency actually tasked with the responsibility of wiring rural America: the Rural
Utilities Service of the USDA.
Rooted in theories of media governance and polycentric regulation, this paper is a first attempt at fixing this knowledge gap.
Traditionally, media governance has been interested in studying multi-tiered or multi-level policymaking, an acknowledgement that
contemporary policymaking responsibility, especially internet policy, is now shared between “various policy actors at the regional,
national and inter- or supranational level (Van den Bulck, 2012, p. 17). Complicating this further, we ask: what happens when
multiple regulators share policy responsibility? Baldwin, Cave, and Lodge (2012) and Black (2008) call this a “polycentric regime”
and specifically highlight the competing claims to legitimacy that may occur.
Such is the policy environment of rural broadband in the US. While the FCC is charged with regulating interstate electronic
communication with responsibility to ensure the timely and adequate deployment of advanced telecommunications,1
other agencies,
most notably, RUS, have been operating in peripheries of telecommunications policy for decades. While there are numerous federal
agencies whose mandates broadly include broadband deployment (e.g. Departments of Education, Transportation, Health and
Human Services, and Housing and Urban Development) (BOC, 2015), RUS was selected as a case study for a number of reasons. First
and foremost, outside the FCC it has the largest broadband portfolio. Second, it has a long history in rural telecommunications. This
began with electricity, included the telephone and even, for a brief stint, cable television. Third, Congress has frequently recognized
RUS as the agency best suited to spearhead the rural broadband effort. Indeed, in the recent 2018 omnibus spending bill it allocated
an addition $600 million to RUS for rural broadband deployment (Eckelkamp, 2018). Fourth, RUS is not a traditional, dispassionate
department. Instead, it is a self-declared champion of its constituency (rural America). As such, it has a stake in the issue of rural
broadband above and beyond other agencies. With a telecommunications loan and grant portfolio of almost $1billion (USD) a year –
the largest government contributor to broadband2
- it is vital to understand the roles this agency plays in setting and implementing
American broadband policy.
Based on a thematic analysis (Hesse-Biber & Leavy, 2010) of policy documents and in-depth interviews with dozens of rural
broadband policy stakeholders, we argue RUS plays the role of a “reluctant regulator.” By this, we mean RUS flirts with being a
regulator at certain times, a policymaker more broadly, a passive stakeholder at other points. Such hedging makes it difficult to
pinpoint the responsibilities and jurisdiction of RUS vis-à-vis rural broadband. The implications of this study are four-fold. First, it
fills an important knowledge gap with respect to American rural broadband by acknowledging and describing the role played by a
heretofore-neglected policy actor. Second, it offers a more complete overview of the stakeholder terrain of rural broadband and rural
broadband policy. Third, it reinforces the validity of media governance theory, polycentric regulation theory, and multi-stakeholder
approaches to policymaking by demonstrating the complex and networked architecture of contemporary telecommunications policy.
Fourth and finally, it pushes communication policy scholars to consider the role of non-traditional communication regulators in
policymaking.
2. Theory and method
2.1. Media governance and polycentric regulation
The concept of media governance has gained in popularity in recent years amongst media policy scholars (Freedman, 2008;
Hamelink & Nordenstreng, 2007; Puppis, 2010). Its aim is to expand thinking about policy and regulation to include formal and
informal practices, processes, and actors. Hamelink and Nordenstreng (2007), define media governance as “a framework of practices,
rules and institutions that set limits and give incentives for the performance of the media” (p.232). Freedman (2008) defines it as “the
sum total of mechanisms, both formal and informal, national and supranational, centralized and dispersed, that aim to organize
media systems according to the resolution of media policy debates” (p. 14). Similarly, Puppis (2010), defines media governance as, “a
new way of describing, explaining, and criticizing the entirety of forms of rules that aim to organize media systems” (p.139).
Media governance gained prominence in the field of critical media policy studies in the late 2000s when it became clear that new
actors had entered the policy-making arena, and new technologies (notably the internet) had complicated the jurisdictional authority
of established regulators. This came about largely in discussions of global internet governance, where the role of the nation-state is
questioned. Many are keen to assert the role that civil society plays in media governance (Calabrese, 2004; Chakravaarty, 2006).
Others prefer to see contemporary media policymaking as a shared process amongst multiple actors (Hooghe & Marks, 2001). Media
governance theory was developed to theorize these emergent policy actors and relationships and to recognize that contemporary
media policymaking is a shared process. As Hamelink and Nordenstreng (2007) acknowledge, “governance is seen as a process in
which a variety of interests are coordinated through different forms of networks and forums. The preferred process may however be
engineered along top-down managerial and institutional interests.” (p.231). While governance recognizes the role and importance of
non-state actors, it does not negate the role of the state. What it does do is recognize different types of regulation, policy, regulators,
and policymakers.
Most studies of media governance concern the content industry (Burri, 2013; Van den Bulk, 2012), and civil society (Calabrese,
1
See §254 and §706 of the 1934 Communications Act as amended by the 1996 Telecommunications Act.
2
In comparison, Phase II of the Connect America Fund will mete out $1.98 billion over ten years.
C. Ali, M. Duemmel Telecommunications Policy 43 (2019) 380–392
381
3. 2004; Chakravaarty, 2006). Where we see a paucity of studies using media governance theory is in two areas: telecommunications
regulation and polycentric regulatory regimes – when multiple agencies operate at the same level (e.g. federal policy-making) with
potentially conflicting jurisdiction (Baldwin et al., 2012).
It is at the intersection of telecommunications governance and polycentric regulation, where the present study is located. Media
governance theory provides us the theoretical foundation and justification to contemplate the legitimacy of non-traditional tele-
communication regulators. In the case of American rural broadband policy, media governance helps us understand and unpack the
multiple policymakers and simultaneous policymaking processes occurring. This multiplicity renders vital activities like mapping
broadband deserts, and determining funding priorities, overly complicated and uncertain. It also makes it difficult for rural broad-
band providers. This study, for instance, found that many potential providers are dissuaded from applying for federal funding because
of the overly complex application process and an inability to determine which agency to apply to. Inspired by Black's (2008) ar-
gument that before we make policy proposals, we need to first “pay far greater attention to the dynamics of accountability and
legitimacy relationships, and to how those in regulatory regimes respond to them” (p. 137), this paper aims to pay attention to a
hitherto-unacknowledged regulatory force in rural broadband.
2.2. Stakeholder analysis
A media governance/polycentric regulatory approach demands an understanding of the actors involved in the policymaking
process and their claims to legitimacy (Van den Bulck, 2012; Black, 2008; Suchman, 1995). Stakeholder analysis is the appropriate
methodological choice to fulfill this requirement. Stakeholder analysis is literally the mapping of policy stakeholders – defined as
“people, groups or organizations with a vested interest in the outcome of a particular policy” (Van den Bulck & Donders, 2014, p. 88)
along with their political and ideological positions and claims to legitimacy, vis-à-vis a particular policy issue (Van den Bulck, 2012).
In addition to identifying stakeholders, stakeholder analysis also analyzes the particular views of stakeholders: their rationale, ar-
guments, logic and paradigmatic positions (Van den Bulck, 2012).
Stakeholder analysis tends to group organizations into different categories based on levels of perceived and actual interest and
influence. This means that a stakeholder's place in a policy issue is fluid and dynamic – at one moment it may have high legitimacy
and high power (“promoter”) while at others, it may have low power and low legitimacy (“apathetic”). It may also exist in between:
high influence but low power (“defender”) or high power low influence (“latent”). The term “actor” is also used to denote any and all
stakeholders, regardless of power or influence. In order to categorize these actors, stakeholder analysis typically employs two
complementary methods: document analysis and elite interviews (Van den Bulck, 2012).
This study presents the results of a modified stakeholder analysis. The aim was not to assess the entire field of policy actors, but
rather to focus on one particular actor – the Rural Utilities Service – and better understand its “stake” in rural broadband im-
plementation and policy. This leads to the first research question:
RQ1: What is RUS's real and perceived role in rural broadband policy in the United States?
We were also interested in RUS's claims to legitimacy in this issue. As (Ali & Puppis, 2018) note, “Legitimacy is rooted in the
acceptance of an organization by others.” It “is a generalized perception or assumption that the actions of an entity are desirable,
proper, or appropriate within some socially constructed system of norms, values, beliefs, and definitions” (Suchman, 1995, p. 574).
As Black (2008) argues
In a governance or regulatory context, a statement that a regulator is ‘‘legitimate’’ means that it is perceived as having a right to
govern both by those it seeks to govern and those on behalf of whom it purports to govern … (p.144)
Outside actors are key to the establishment of legitimacy:
Legitimacy rests on the acceptability and credibility of the organization to those it seeks to govern. Organizations (regulators) may
claim legitimacy, and may perform actions and enter into relationships in order to gain it. But legitimacy is rooted in the ac-
ceptance of that organization by others, and more
particularly in the reasons for that acceptance. (Black, 2008, p.144, p.144)
This lead to research questions two and three:
RQ2: How does RUS perceive its own legitimacy in the issue of rural broadband through its written statements?
RQ3: How do others perceive the legitimacy of RUS in the issue of rural broadband?
To answer these questions, we conducted a thematic analysis (Hesse-Biber & Leavy, 2010) of over 10,000 pages of policy
documents from the dates 1996 to present. These included comments filed by RUS to various FCC proceedings, reports authored by
RUS, evaluations of RUS programs conducted by the Congressional Research Service (CRS) and the General Accounting Office (GAO),
and all public comments filed to the joint FCC/RUS docket on crafting a rural broadband strategy (Docket No. 09–29), and comments
to the RUS-lead Broadband Opportunity Council (BOC, 2015). We also conducted 36 in-depth elite interviews with key informants
and experts on the issue of rural broadband (Herzog & Ali, 2015). These included employees (both former and current) of RUS,
former staffers at the FCC, rural broadband providers, industry watchers, foundations, policy experts, state officers, and rural re-
sidents.3
This combination of document analysis and interviews allows us to ponder what Price (2012) calls “narratives of legitimacy;
3
Because rural broadband is an ongoing issue, the decision was made to withhold all names and titles.
C. Ali, M. Duemmel Telecommunications Policy 43 (2019) 380–392
382
4. ” in our context, the narratives RUS and other actors use to justify or challenge RUS’ actions.
We make two arguments in this paper. First, that rural broadband policy meets the definition of a polycentric regulatory regime,
as understood by Baldwin et al. (2012) and Black (2008). This might not come as a surprise to those invested in media governance
theory, which posits that all communication policy issues are multi-faceted. As such, we nuance this argument with an in-depth
understanding of the role of RUS. We argue RUS represents what we call a “reluctant regulator.” That is to say that it is a stakeholder
and actor in rural broadband with ability to influence policy-making at the highest level. It even has regulatory responsibilities vis-à-
vis rural broadband in terms of funding and speed requirements. But, through its own communication and the communication of
outside actors, its role in rural broadband policy is ultimately unclear: regulator, policymaker, banker, activist – sometimes all of
these at the same time. Such uncertainty may lead to regulatory confusion and ineffective policy decisions, most notably regarding
grants and loans – the key components of RUS's regulatory toolkit (USDA, 2005). A deeper understanding of its role in rural
broadband policy may strengthen its commitment and mission.
To organize our paper, we relied on Black (2008) posits three roads to legitimacy:
(i) the institutional embeddedness of regulators, be they at the national, sub-national, supranational, or global level and the role of
that institutional environment in the construction and contestation of legitimacy; (ii) the dialectical nature of accountability
relationships; and (iii) the communicative structures in which legitimacy claims and accountability relationships are articulated
and constituted. (p.144)
In the first section, we examine the history of RUS, its legislative authority, and recent activities and programs to underscore its
institutional embeddedness. In the following section, we explore the critiques of RUS, thus exploring its accountability structures.
Lastly, in reporting our findings, we examine its communicative structures and narratives of legitimacy.
3. From REA to RUS
Little academic research has been done on RUS or its predecessor, REA. What scholarship exists is found as part of larger studies
on the electrification of rural America (Brown, 1980) or the development of the rural telephone network (Kline, 2000). The De-
partment itself has also published two official histories, one in 1966, and the other in 1999 to celebrate the 50th
anniversary of rural
telephony being added to REA's portfolio (Buckley, 1999).
REA was formed in 1935 as a temporary emergency relief agency of President Roosevelt's new deal. Its primary mission, then, as it
is today, is to subsidize private companies to provide electricity and telecommunications services to rural America. Its founding
document– the 1936 Rural Electrification Act – gives the agency its legal authority. Specifically, the Act gives authority to the Secretary
of Agriculture:
to make loans in the several States and Territories of the United States for rural electrification and for the purpose of furnishing
and improving electric and telephone service in rural areas, as provided in this Act, and for the purpose of assisting electric
borrowers to implement demand side management, energy efficiency and conservation programs, and on-grid and off-grid re-
newable energy systems. (US, 1936, §2(a))
The need for subsidy was acknowledged early in the electrification of America because of the lack of market incentives for
electricity companies. Said differently, “Until the creation of the Rural Electrification Administration (REA) in 1935, power com-
panies had the prerogative to serve farmers, but they were slow to unwilling to do so because of the high cost involved” (Brown,
1980, p. 3). In the 1920s and 1930s it was tremendously expensive to string wire and build power stations in rural communities; rural
communities that could not provide a return on investment because of the small number of potential subscribers. This was the same
for telephony in the 1940s and 1950s, and today, for broadband.
REA was set up as a loan agency that would provide self-liquidating loans to power companies (mostly cooperatives) and
households. In other words, the loans would pay for themselves through the revenue generated by the companies. Loans expired in 25
years. In 1936, REA became a permanent agency, and received an initial appropriation of $50, 000, 000 which would act as principal
for the loans. REA received $40, 000, 000 per year over the next ten years (Brown, 1980).
In 1939, REA was reorganized as a department under the auspices of the USDA. In 1944, the Agriculture Organic Act “established
a fixed interest rate of 2 percent for REA loans and extended the repayment period to 35 years” (Buckley, 1999, p. 18). Importantly
this Act also embedded the concept of universal service into the mandate of REA through the concept of “area coverage” defined as
“the practice of extending service to everyone in a given area who wants it regardless of how far they live from the main facilities
[and] considering the feasibility of a project as a whole, not based on the cost of individual extensions” (Buckley, p.18).
Telephony was added to REA's stable of loans and grants in 1949. Like electricity before, the rural telephony program proved
remarkably successful. In 1959 65% of farms reported owning a telephone (Kline, 2000). Twenty years later, 99% of farms had
electricity and over 90% of rural areas had telephony (Cowan, 2016). With its goals largely accomplished, the next few decades were
about filling the telecommunications holes. This included focusing on Native American communities, and communities in Alaska. It
also meant flirtations with emerging technologies like cable television and satellite telephony (Buckley, 1999). According to Buckley,
the 1980s also saw an increased policy focus at REA, through filings with the FCC and congressional testimony. Key issues were
telephone equipment and interconnection tolls. The relationship between the FCC and RUS would peak after the passage of the 1996
Telecommunications Act (discussed below).
In the 1990s, the emergence of the Internet and the realization of its potential ubiquity gave new purpose to REA. In 1990
Congress passed a provision in the Farm Bill that created the Distance Learning and Telemedicine Program. This authorized REA to
C. Ali, M. Duemmel Telecommunications Policy 43 (2019) 380–392
383
5. provide loan assistance for schools, libraries and rural health care providers for telecommunications (internet) equipment and fa-
cilities (Buckley, 1999). Beginning in 1993, the agency also required any phone company receiving a loan to offer internet service
(RUS, 2012).
The largest restructuring of REA came in 1994 when Congress passed the Federal Crop Insurance Reform and Department of
Agriculture Reorganization Act. This Act created a new division at USDA: the under secretary for rural economic and community
development. Telecommunications and electricity had long been thought of as central to rural development and this reorganization
codified this relationship (Buckley, 1999). The REA was renamed the Rural Utilities Service (RUS) and found its mandate expanded
from telecommunications and electricity to also include water (both potable and sewage).
The shift to “RUS” also expanded its mandate to include broadband deployment in rural areas. While RUS required all new
receivers to equip their networks for internet connectivity since 1993, the first pilot program specifically targeting household
broadband was in 2000 with a congressional appropriation of $100 million.4
It was determined that RUS would be the agency for
rural broadband because of its previous accomplishments in electricity and telephony (Romm, 2015). The program was deemed a
success (Kandilov & Renkow, 2010), and was made permanent through Section 601 of the 2002 Farm Bill.
RUS's broadband program has significantly expanded and now consists of four programs and almost $800 million in annual loans
and grants. While an impressive amount of money, it pales in comparison to the total loan and grant budget of the Office of Rural
Development, which, in 2017 stood at $40.38 billion and the budget of USDA programs at $137 billion (USDA, 2018).
4. RUS and rural broadband today
According to the FCC’s, 2018 Broadband Progress Report, over 30% of rural Americans lack access to broadband (defined as
25 mbps download/3 mbps upload). This compares to only 4% of urban Americans. Authority for fixing the digital divide is split
between two agencies: the FCC through its Connect America Fund (to be discussed below) and RUS through four different loan and
grant programs (see Table 1)5
RUS manages a total telecommunications portfolio of approximately $4billion with almost $800 million in telecommunications
loans and grants awarded each year (RUS, 2012) (see Table 1). The telecommunication programs of RUS are authorized and re-
authorized by the omnibus Farm Bills passed every 5 years (2002, 2008, 2014, 2018) and subsequent modifications to the Rural
Electrification Act of 1936. The broad mandate of RUS's broadband program is to focus on bringing service through loans and grants to
private companies to unserved and underserved rural areas (US, 2008).
While the Telecommunications Loan Program remains the longest serving program, the Rural Broadband Access Loan and Loan
Guarantee Program is the primary program targeting rural broadband. As of 2017 it offered $29 million in loans through an ap-
propriation of $5million. According to CRS, eligibility:
to receive loans include corporations, limited liability companies, cooperative or mutual organizations, Indian tribes or tribal
organizations, and state or local governments. Eligible areas for funding must be completely contained within a rural area (or
composed of multiple rural areas). Additionally, at least 15% of the households in the proposed funded service areas must be
unserved, no part of the proposed service area can have three or more incumbent service providers, and no part of the proposed
service area can overlap with the service area of current RUS borrowers or of grantees that were funded by RUS. (Kruger, 2018,
p.5, p.5)
The minimum loan is $300,000, while the maximum is $25 million. RUS set the minimum speed at 25 mbps download and 3 mbps
upload, in line with the current definition set by the FCC. It should be noted that one of the unambiguous policymaking abilities of
RUS (through the Rural Electrification Act) is to set the minimum speed thresholds necessary to meet the definition of “broadband”
(US, 2008).
RUS's telecommunications loans and grants are intimately connected with the Connect America Fund (CAF) (previously the
Universal Service Fund (USF)) of the FCC. While it is outside the scope of this paper to fully explain the USF/CAF, some words are
necessary. First, the CAF operates as an ongoing subsidy to support broadband deployment. It is funded through a levy directed at
telecommunications companies and is thus not a public subsidy but rather a cross-subsidy. Companies pay into the fund and then
competitive applications are made to fund rural broadband deployment. Importantly, these funds are doled out over ten years and are
meant to support the revenue stream of rural providers, whose profit margins would be minimal given the dearth of population.
In contrast, RUS operates various grant and loan programs, meant specifically for capital expenditures (e.g. the installation of a
fiber optic network for a rural community). To be eligible for a loan, however, RUS applicants must demonstrate a consistent revenue
stream, which may take into account USF/CAF funds. As such, many RUS applicants are dependent upon continued revenue subsidy
from the CAF/USF. A full 99% of RUS Telecommunications Infrastructure Loan Program borrowers receive USF funding, while 60%
of Broadband Improvement Program (BIP) and 10% of Broadband Loan recipients receive such funds (Kruger, 2018). Any adjustment
to the USF/CAF, therefore, will heavily impact RUS and RUS borrowers. In the history of the program, the FCC has twice restructured
the USF. First, in the late 1990s when the program was established and second in 2009–2011 when the program switched from
subsidizing telephony to subsidizing broadband. As will be noted below, changes to the Universal Service Fund/Connect America
4
HR 4461 – Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2001.
5
The National Telecommunications Information Administration (NTIA) is also attached to rural broadband through its participation on the
Broadband Opportunity Council and an appropriation from the ARRA.
C. Ali, M. Duemmel Telecommunications Policy 43 (2019) 380–392
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7. Fund represent the majority of RUS public comments to the FCC.
4.1. The American recovery and reinvestment act
The 2009 American Recovery and Reinvestments Act (ARRA) represented the single largest public contribution to broadband
deployment and demonstrated a major moment of legitimation for RUS by Congress. ARRA was a $787 billion stimulus package to
pull the American economy out of the great recession. Of this, $7.2 billion went to the expansion of rural broadband. $4.7 billion was
allocated to the Department of Commerce's National Telecommunications and Information Administration (NTIA) for an infra-
structure grant program called the Broadband Technology Opportunity Program (BTOP), which focused primarily on “middle mile”
infrastructure. The remaining $2.5 billion was given to RUS for broadband loans and grants of which 75% was to be directed towards
rural areas. This was called the Broadband Initiatives Program (BIP), which focused primarily on “last-mile” projects, bringing
broadband directly to homes and offices. Because it is also a loan agency in addition to a grant agency, RUS was able to parlay its
allotted $2.5 billion into a total of $3.5 billion in grants and loans. These went to funding 320 projects. According to RUS, the goal
was for 7 million rural Americans to be connected, along with more than 360,000 businesses and more than 30,000 critical com-
munity institutions (Tonsager, 2012).
The ARRA was a major opportunity for RUS to assert legitimacy as a stakeholder and policy actor in rural broadband. This was not
without criticism. (Kang, 2009; Romm, 2015). Both Congress and RUS received complaints from telecommunication companies,
government officials, and the popular press regarding the suitability of RUS to distribute these funds. As Romm (2015) writes in
Politico “RUS never found its footing in the digital age” compared with its historic sure-footedness in electricity and telephony. Of the
lead up to ARRA, Romm added:
Sometimes, RUS funded high-speed Internet in well-wired population centers. Sometimes, it chose not to make any loans at all.
Sometimes, RUS broadband projects stumbled, or failed for want of proper management; loans went delinquent and some bor-
rowers defaulted. Yet despite years of costly missteps that left millions of Americans stranded on the wrong side of the digital
divide, a stable of friendly lawmakers swallowed their doubts about RUS and made sure the politically protected agency wasn't cut
out of the historic stimulus effort. (p.2)
This scathing article in Politico noted that in July 2015, 150 projects had not drawn the full amount of their funds (totaling $270
million). If these funds were not accessed by September 2015, they would be forfeited as per ARRA stipulations. Romm argued that
RUS was unprepared and ill-equipped to mete out these loans and grants, which were meant to be allocated only to “shovel ready”
projects. Quick turnaround times (all awards had to be made by 2010 and all projects completed by 2013, with an absolute deadline
of 2015) made it that much harder. Other critics of the broadband stimulus package worried that it would become a “cyber bridge to
nowhere,” expressing concern that the broadband portion of ARRA was rushed and ill-considered (Herscenhorn, 2009).
The Government Accountability Office (GAO) critiqued RUS for failing to collect assessment data of recipients. According to the
GAO:
BIP's reporting has been limited and is not reflected in USDA annual performance reports. As a result, RUS has not shown how the
approximately $3 billion in funds awarded to BIP projects have affected broadband availability … Without reliable and regular
information on the results of BIP projects, it will be difficult for USDA, RUS, and policy makers to determine the impact of
Recovery Act funds and BIP's progress on improving broadband availability. (2014, p.22)
RUS's responses were 1) because it was a loan agency it has no expertise in such capacities, 2) the windfall of funds exhausted its
human resources, and 3) ARRA did not require “RUS to collect performance metrics from awardees” (p.12) (GAO, 2012). In doing so,
RUS discursively distanced itself from the identity of “policymaker” and argued instead that it was simply a bank or lender.
The GAO ultimately concluded that most projects were brought to completion by the allotted deadline of September 2015 and on
its side, RUS reported the success of the project in its final report to congress. But not all was well. RUS had to write off $325 million
in ARRA funds because of terminated projects (approximately 14% of the total appropriation). This forced RUS to readjust its
estimated number of new broadband subscribers from 847,239 to 728,733 (GAO, 2014). This, of course, was a far cry from the 7
million new broadband subscribers that RUS at the onset of ARRA.
4.2. Critiques of RUS
Reports from the CRS and GAO, in addition to the aforementioned Politico report, suggest four main critiques of how RUS handles
broadband loans and grants:
1) Not giving enough loans
2) Unclear definitions
3) Giving loans to communities too close to urban centers
4) Giving loans to communities that already have a provider
Suring the early days of the Broadband Loan Program, RUS was accused of having such exacting eligibility requirements that
many funds went unspent or underspent (Kruger, 2018; USDA, 2005). As the Inspector General of USDA noted in 2005, because of a
lack of consistent internal standards and best practices “$236.6 million in loans and grants intended to bring broadband service to
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8. rural communities was either not used as intended, not used at all, or did not provide the expected return in service.” (p.ii). Similarly,
the application process itself was deemed overly complex and a barrier to entry for many potential applicants. This was such the case
that in 2007 Congress ordered RUS to change its practices (Kruger, 2018). Interviews for this project echoed these concerns of red
tape and delays. Noted one rural provider in an interview:
You know, of all the things I've tried to do in my life, the hardest thing I've ever tried to do is to navigate how to get RUS funding,
how to get federal grant funding, so much so that a couple months ago, I went out to DC for a number of reasons … And the
purpose of my visit was simply this. "Look, you guys, your intentions are excellent with the grants for broadband, your intentions
are great with loans and loan guarantees from RUS, the Department of Agriculture. But here's the deal. I cannot … afford to figure
out how to navigate it, nor can I hire someone to figure out how to write the grant such that we would receive grant money, nor
can I figure out how to navigate how to put myself in the position to receive either grants or loan guarantees. And if you can tell
me today how I do that, I'm all ears. (personal communication, 6/23/17)
Relatedly, early RUS broadband loans and grants were often allocated to communities adjacent to major urban centers and to
communities already served by an incumbent provider, thus undermining the effort to support unserved and underserved commu-
nities. As the Inspector General noted in 2005:
We found that RUS has not maintained its focus on rural communities without preexisting service. Although the language of the
law specifies that these Federal loans and grants are for rural communities, RUS has codified and implemented a definition that
cannot reliably distinguish between rural and suburban areas. Due to this ambiguous definition, the agency has issued over $103.4
million in loans to 64 communities near large cities, including $45.6 million in loans to 19 planned subdivisions near Houston,
Texas … The agency's current system for prioritizing underserved communities cannot, however, guarantee that communities
without broadband access will be preferred to those already with access. (p.11)
Part of this problem of simultaneous under-awarding and over-building was the very definition of the words “rural” and “un-
derserved.” So vexing was this that the 2008 Farm Bill (US, 2008) ordered USDA to reevaluate its many definitions of “rural” (§6108).
For telecommunication provisions, the Bill itself specifically defined “rural” as “any area other than (1) a city or town that has a
population of great than 20,000 and (2) an urbanized area contiguous and adjacent to a city or town with a population greater than
50,000” (§6111). It also ordered that priority of broadband loans and grants be given “to applicants that offer to provide broadband
service to the greatest proportion of households currently without broadband service.”
In spite of its critics, RUS regularly claims success in rolling out broadband to rural America (RUS, 2015). What is striking in these
competing claims of success and failure is the paucity of research on RUS as a policymaker, as an institution, and as a corrective for
the market failure in broadband. What is RUS's real and perceived role in rural broadband policy? Our findings begin to fill this
lacuna.
5. Findings
5.1. GAO critiques: regulator or bank?
The obvious place to start to understand RUS′ role in rural broadband policy is to examine the language deployed by the agency
itself. Recall RUS's response to the GAO's critique over the allocation of ARRA funds noted in the previous section. RUS′ response to
these critiques was that it is not a policymaker, but rather a bank. It therefore does not possess the expertise of a regulatory body.
GAO, accepted RUS's response:
RUS officials told us that because of RUS's traditional role as a loan administrator, it tends to focus on ensuring that the funding is
disbursed, the project is built, and the agency is repaid, instead of tracking project outcome information. In addition, the Recovery
Act did not require RUS to collect performance metrics from awardees. (2012, p.12)
In the same written response, however, RUS also categorized itself as a “policy, planning, and lending agency that makes loans,
loan guarantees and grants available to finance rural electric, telecommunications and water and wastewater infrastructure” (p.32).
The narrative of RUS as a bank, as opposed to a regulator (like the FCC), was also noted in interviews with former RUS officials.
Think of it as a, RUS is the bank, and universal service [USF] provides a revenue stream to pay back the loan. In a sense RUS is like
providing the mortgage on your house, and then part of your wages come from USF … RUS provides the financing, but as a
financial institution it requires ongoing revenue stream to determine the level of loan that is … financially feasible. (personal
communication 10/23/17)
Yet, the same respondent added:
We were involved in making policy decisions with regard to the distribution of funds on the recovery act, that's why we had a lot
of digression. Congress has since tried to put more and more sort of restrictions on the digression of RUS due to complaints from
cable companies, and others who feel like they're providing loans that compete with private investment. They've tried to focus
them on areas where there's no service. The big debate, and it would apply to agricultural areas has been, do you provide funding
for areas that are underserved, or un-served?
While RUS called itself a bank to successfully mitigate critiques of regulatory neglect, its role as a policymaker for broadband is
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9. ambiguous, both legally (as we shall see below) and normatively (as found in its own communications with GAO and in interviews).
5.2. Rural broadband policy
Like ARRA, the rural broadband strategy was an optimum chance for RUS to solidify its position as a key architect of American
rural broadband policy. The 2008 Farm Bill ordered, “The Chairman of the Federal Communications Commission, in coordination
with the Secretary [of Agriculture] … [to] submit to Congress a report describing a comprehensive rural broadband strategy” (US,
2008, §6112).
The Rural Broadband Policy opened for public comment on March 10, 2009. Within the scheduled 2-week comment period,
received a total of 225 comments, with submissions ranging from rural Americans, to rural broadband providers, counties, cities, and
major telecommunication and technology companies. At the outset, it should be acknowledged that few commenters specifically
mentioned RUS, intimating a lack of perceived legitimacy. Most commenters preferred to comment on FCC policy – namely, Universal
Service. Of those that did mention RUS, three themes were present: 1) RUS should be given greater authority over rural broadband
policy, 2) RUS and FCC should work in tandem, 3) Critiques of RUS.
First, a handful of commenters such as the American Farm Bureau Federation and Texas Statewide Telephone Cooperative re-
commended that USDA/RUS become the agency solely responsible for rural broadband:
USDA has an office in almost every rural county in the nation. Local Rural Development, Farm Service Agency or Extension offices
are staffed by members of the community and are ideal locations to disseminate and collect information about federal rural
broadband deployment programs … Therefore, USDA should be designated as the lead Federal agency for rural broadband
deployment efforts and the Secretary of Agriculture held accountable for the agency's actions. (AFBF, 2009, p. 2, p. 2)
This should perhaps come to no surprise from these actors, which have historically received funding from RUS and whose cause
RUS champions.
Next, Congress mandated the report focus on interagency cooperation, and a number of commentators to the inquiry brought up
the need for such engagement. As Independent Telephone & Telecommunications Alliance (ITTA) stated:
… the agencies should commit to scheduled periodic inter-agency communications. In addition to ensuring inter-agency com-
munications, the Commission, in conjunction with NTIA and RUS, should commit, within reasonable bounds, to develop pro-
cedures that are transferable among agencies and which reduce duplicative efforts and administrative burdens on affected entities.
(ITTA, 2009, p.5)
Commenters like ITTA clearly perceive RUS as an important contributor to rural broadband policy. This was supported in multiple
interviews, where respondents strongly voiced the need for better coordination between RUS and FCC:
I believe that officially there is collaboration between the two, but I'm kind of having a tough time finding it in reality. I would like
to see them work together more closely because they are – I mean, a lot of companies, a lot of rural broadband companies accept
monies from both plans. So, you would like them to work together better than they are, but that's just my wish list. (personal
communication, 7/25/17)
The same respondent once again brought up the idea of RUS as a bank, as opposed to a regulator:
But I would say over the last 6 or 7 years, [the] relationship has gotten a lot closer with the FCC with everything that's going on.
And you know, [the FCC is] the regulator and [RUS is] the lender, so there is a line drawn between there that we have to, you
know, realize and pay attention to.
The majority of comments that discussed RUS, however, were critical of the agency. InLine Communications, for instance, re-
commended that RUS revise its definition of rural area, while WildBlue Communications accused RUS of bias against satellite internet
providers. DigitalBridge Communications criticized RUS for the slow pace of awarding grants. Interview respondents tended to agree
with these critiques, most notably the slow pace of awarding grants and the previous GAO critique of grant allocation: “… I think the
USDA has a great opportunity to really take up the mantle and really take charge and support these places. But they, their programs
just really fall flat” (personal communication, 1/10/18). This comment, which came from a digital divide solutions advocate and
organizer, positions RUS as a key policy stakeholder in rural broadband policy, but not without critique. The respondent also went on
to critique the myriad of requirements and narrow focus of RUS grants and loans (such as limiting population cap to 5000 and
narrowing the eligibility of a grant to communities that do not receive 4/1 service – severely reducing potential applicants).
In summation, while Congress recognized RUS as a policy stakeholder in rural broadband by assigning it a role in crafting the
national rural broadband policy, the majority of commentators to the docket disagreed either through omission or through critique.
The FCC, according to the majority of commentators, still held the reigns of power to set rural broadband policy. Ultimately, the
entire exercise was for not, as the final rural broadband policy report was written by the FCC, and was eventually made redundant by
the National Broadband Plan the following year.
5.3. The FCC and universal service fund
Since the passage of the 1996 Telecommunications Act, the FCC has twice overhauled the Universal Service Fund. First, when
establishing the fund, and second, in 2011 when it transitioned the High Cost Fund – which supported telephony in rural areas – to
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10. the Connect America Fund – which supports broadband. In the first instance, RUS was a consistent voice before the Commission,
lobbying for greater funding access for its constituents. It positioned itself as a major stakeholder in USF policy, writing “Universal
service is the core mission of the Commission and the RUS” and noting that the FCC cannot diffuse USF responsibility to the states,
when jurisdiction lies with the federal government (notably FCC and RUS). As it argued: “The [Telecom Act of 1996] calls for a
coordinated federal and state universal service support system where state support mechanisms were intended to augment federal
support mechanisms, not the other way around” (RUS, 1999). RUS went to pains to remind the FCC of its legislative authority in this
domain:
Congress charged … [RUS] with implementing State Telecommunications Modernization Plans. Chief among the requirements of
that legislation was that customers be able to receive 1 megabit/second data rates through their telephone lines. RUS im-
plemented these requirements over a period of time and directed the requirements only at new plant to be constructed either in
currently unserved areas or in system rebuilds” (RUS, 2000a).
In another 2000 filing to the FCC about a request from a New Mexico telephone company to be recognized as a rural provider (and
therefore have access to the USF), RUS argued emphasized its legislative authority citing the Rural Electrification Act:
The Administrator in making such loans shall, insofar as possible, obtain assurance that the telephone service to be furnished or
improved thereby will be made available to the widest practical number of rural users. This language was in the 1949 Telephone
Amendment. Advanced services capability was added to the Rural Electrification Act in 993 and is found at 7 U S C. 935(d). (RUS,
2000b)
In these early USF conservations, there is a clear attempt to lay a claim to regulatory responsibility to USF that complements that
of the FCC.
In recent years, RUS has reduced its filings to the FCC, even though in 2014 it signed a Memorandum of Understanding (USDA/
FCC, 2014) with the Commission to augmented information sharing, and despite massive changes to the USF program. Since 1996,
RUS filed 79 interventions with the FCC, but only 12 of those appeared after 2010, with six of those 12 comments concerning the
National Broadband Plan. This suggests a retreat from the policy and regulatory arenas. As one RUS official told us:
To be honest with you, it just comes down to where do we commit our resources. And you know … we just have too much other
things going on right now. (personal communication, 8/30/17)
There is a missed important opportunity for critique here by scholars, because with the transition from the FCC's High Cost Fund
to the Connect America Fund, many of RUS's constituents worried about how this will impact their RUS′ loans and any future capital
investments in their networks. Recall that upwards of 99% of RUS′ borrowers depend on USF/CAF funding. As one respondent said:
And what is it – since the FCC is rewriting those rules, that is having a direct impact over at USDA's RUS because the Rural Utility
Service is the loan – is a bank, basically, that's going to loan out money to companies to build out broadband infrastructure to
these more remote areas. But companies are being directly impacted because they don't have the certainty of what are the
regulations that are going to govern their access to the Universal Service Fund. (personal communication, 6/8/17)
RUS voiced these concerns to the FCC in a filing regarding the National Broadband Plan:
… the FCC should consult with an affected government agency if changes to an existing FCC regulation could negatively impact
that agency's broadband strategy. For example, in 2011 the FCC made significant changes to the federal USF. According to the
[GAO], since that time, a majority of [RUS] broadband borrowers have seen reductions in the amount of USF revenue they
receive. In one example provided by GAO, 18 RUS borrowers lost an average of 31 percent of their USF support between 2011 and
2013, significantly impacting their ability to repay outstanding program loans. (RUS, 2012)
Unfortunately, RUS comments falls on deaf ears, as the FCC and the Universal Service Corporation tends to make unilateral
changes to USF policy.
RUS's relationship with the FCC is fluid and fraught. In the late 1990s it was much more keen to assert expert status, whereas in
the late 2000s it fell into the role of rural champion and advocate for its constituents. What is surprising here is that the shift in
stakeholder status comes at a time when both government and rural broadband actors are clamoring for greater coordination between
the agencies (see Gilroy & Kruger, 2012). For instance, in 2015 RUS was charged by President Obama to lead the Broadband
Opportunity Council (BoC) with a specific mandate to encourage coordination between all agencies involved in funding rural
broadband projects. Underscoring RUS′ leadership, the National Telecommunications Cooperative Association wrote to the BoC:
Rather than “stepping on top of” or even competing with the efforts of RUS to manage federally-overseen resources to facilitate
the construction of networks, the FCC, NTIA, and other agencies could and should coordinate with the RUS so that each can utilize
its own expertise and operate effectively within its well-defined role, offering targeted solutions to market failure or regulatory
barriers that limit the availability or affordability of broadband service. (NTCA, 2015, p.5, p.5)
This need for stronger coordination between agencies and the leadership of RUS was also echoed by one of our interview re-
spondents:
And I think – and what's not getting as much attention is over at USDA, with the Rural Utility Service, on how … there should be
more communication, more coordination between the FCC, RUS – but then also – Department of Commerce, with the NTIA, you
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11. know, there's a lot of different areas that need to come together. (personal communication, 6/8/17)
Unfortunately, the BoC has been effectively disbanded since November 2016, and the critique of poor coordination between
agencies – especially RUS and FCC – remains both relevant and resonant.
6. Discussion
Two observations can be made from these findings. First, RUS's perceived role in rural broadband policy shifts depending on the
context and other actors in the conversation. Second, RUS's perception of itself is clearly as a bank/lender, taking a backseat in
broadband regulation to the FCC. Still, with wide responsibilities ranging from the very definition of broadband and “rural” to
managing a near-billion dollar portfolio, its legal authority and narratives of legitimacy suggest it is much more than a bank, as
suggested by this 2002 comment to the FCC:
Since the passage of the Telecommunications Act of 1996, RUS has taken an active role on behalf of rural Americans by com-
menting on the actions taken by the [FCC] as it has implemented the universal service provisions of the Telecom Act. Throughout
this process, RUS has worked to represent the interests of all rural Americans, not just those served by RUS-financed companies
and cooperatives as the financing available under the Rural Electrification Act is intended to benefit all rural areas. (RUS, 2002)
Moreover, as Black (2008) reminds us, banks are themselves part of the regulatory and policy process: “The ‘‘regulators’’ are the
banks, regulating both themselves and others to ensure compliance with the principles, at least in the initial loan documentation.”
We come back to the research questions: what is RUS's role in rural broadband policy? And, how does RUS legitimize this role?
Given the contrarian nature of the findings presented in this article, it is perhaps too soon to label RUS a regulator of rural broadband,
although it does have the authority to regulate broadband speeds for its borrowers. At the very least, we have identified RUS as a
major stakeholder, actor, and broad policymaker in this field (if we parse “regulation” as official rulemaking from “policy” as goal
setting [Freedman, 2008]). Marshaling the language of stakeholder analysis, we can label RUS a “latent” stakeholder – one with the
potential for high influence but without consistent action (Van den Bulck, 2012).
Latent stakeholders, according to Mitchell, Agle, and Wood (1997) fall into one of three categories: dormant – with high power
and low legitimacy and urgency; discretionary, with low power, low urgency, and high legitimacy, and demanding, with low le-
gitimacy, low power, but high urgency (see Fig. 1). Expectant stakeholders include the dominant, dependent, and dangerous cate-
gories. Definitive stakeholders stand on their own at the intersection of high power, legitimacy, and urgency.
Our findings suggest RUS waffles between the dormant, discretionary, and definitive categories (see Table 2). Definitive – high
legitimacy, urgency, and power, occurred when Congress recognizes RUS through appropriations or duties, or when an outside actor
recognizes RUS as the primary mover in rural broadband policy. At other times, such as the lack of acknowledgement by the GAO in
various reports on broadband, RUS falls back to dormant - high power but low legitimacy - or non-stakeholder. At other moments,
such as during the 2009 Rural Broadband Strategy Report, RUS had high legitimacy – being tasked by the Congress through the Farm
Bill to co-author the report, and high legitimacy for some outside actors like the AFBF, who championed its role in rural broadband
Fig. 1. Mitchell et al. (1997) Stakeholder typology.
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12. policy development. With a deadline on the report, we can even say RUS had high urgency.
As illustrated in Table 2, RUS's stakeholder status vis-à-vis rural broadband policy is fluid, ranging from a perceived non-sta-
keholder to one intimately involved in the crafting of American broadband policy. These findings align with Black's (2008) con-
clusions that stakeholder status and legitimacy is never static. They fluctuate in time and by actor. Depending on the issue and the
actor, RUS's position in the stakeholder typology changes, as does its own response to these changes. These fluctuations lead us to
focus on RUS's reluctance to fully intervene in the broadband policy conversation.
Implications revolve around past mistakes and improving service to rural America. As noted throughout this paper, RUS has faced
constant criticisms about its lack of transparency and accountability, mismanagement of funds, inability to agree on key terms,
definitions and eligibility criteria, the pace of funding, and its bureaucratic opacity. Nevertheless, Congress and borrowers still trust
RUS to shepherd the country through the digital divide. The discrepancy between perception, practice, and policy need to be resolved
if we are to move the dial forward. Understanding the role of RUS and the perceptions of the agency is a key step in correcting these
policy failures.
7. Conclusion
The 2018 Consolidated Appropriations Act allocated an additional $600 million to RUS for rural broadband initiatives
(Eckelkamp, 2018). In concert with the half-dozen House and Senate bills targeting RUS and broadband, it is clear the agency plays
and will continue to play an important role in rural broadband. What is less clear are the specific roles RUS plays, could play, and will
play, in confronting the challenges of the digital divide: bank, advocate, regulator, champion. Failing to clarify RUS's role risks
repeating past mistakes and contributing to an opaque regulatory and funding structure that hinders broadband deployment. It
furthermore risks exacerbating, what Koppell (2005) calls the “multiple accountability disorder” of polycentric regulation, wherein
regulators battle for legitimacy and power in an unclear regulatory landscape.
This is a critical lacuna in American broadband policy and represents the challenge of polycentric regulation as underscored by
theories of media governance and stakeholder analysis. As Black (2008) notes
polycentric regimes at any level (sub-national, national, supranational, global) pose the problem of ‘‘many hands’’ … The different
regulatory roles and responsibilities of identifying goals, formulating standards, monitoring and enforcement are often dispersed
between a number of participants, with significant implications for accountability. (p.143)
Heretofore, the “many hands” of rural broadband policy has never been investigated. Following the belief located in media
governance theory and theories of polycentric regulation that communication policymaking has become a domain of numerous actors
and stakeholders we aimed to better understand the role RUS plays in rural broadband policy, and how it legitimizes its policy
presence.
The results of our intensive policy analysis and dozens of in-depth interviews suggest RUS′ real and perceived authority in
telecommunications policy is far from stable. When it is recognized as a stakeholder, its level of power and legitimacy ebbs and flows
Table 2
Actor perceptions of RUS's stakeholder status.
Actor
Issue
Congress/Government FCC Rural Organizations (e.g.
AFBF, ITTA)
Major Telcos and
Associations (e.g. AT&T,
CTIA, US Telecom)
Rural Telcos and
Associations
ARRAa
Definitive Stakeholder/
dangerous stakeholderb
n/a Dominant n/a Dominant
Rural Broadband Policy Definitive Stakeholder Discretionary
Stakeholder
Dominant Non-Stakeholder/definitive
stakeholderc
Dominant
USF 1990s Non-stakeholderd
Discretionary
Stakeholder
n/a n/a Dominant
USF 2000s Non-stakeholdere
Dormant
Stakeholder
n/a n/a Dominant
Broadband Opportunity
Council
Definitive Stakeholder n/a Dominant Non-Stakeholder/definitive
stakeholderf
Dominant
a
It is safe to say that the aforementioned Politico article criticizing RUS's handling of its stimulus funding would put the agency in to the
demanding or dangerous stakeholder categories.
b
While Congress considered RUS a definitive stakeholder by allocating it a portion of the ARRA, the GAO as noted above, questioned both its
accountability and power to oversee the project, hence the dual categorization of definitive and “dangerous” stakeholder.
c
While some did not mention RUS in their comments at all, suggesting the agency is not a priority, others such as the NCTA – National Cable &
Telecommunications Association is an exception, which did mention RUS in their comments in order to critique the opacity of the funding programs
(NCTA, 2009).
d
Derived from GAO reports on universal broadband, which omitted RUS entirely.
e
Derived from GAO reports on universal broadband, which omitted RUS entirely.
f
While some did not mention RUS in their comments at all, suggesting the agency is not a priority, others such as the NCTA – National Cable &
Telecommunications Association is an exception, which did mention RUS in their comments in order to critique the opacity of the funding programs
(NCTA, 2009).
C. Ali, M. Duemmel Telecommunications Policy 43 (2019) 380–392
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13. depending on the context along with the presence and perception of other policy actors. It is thus a “reluctant regulator.” This study
contributes to our general theoretical understanding of multistakeholderism and polycentric regulation by operationalizing Mitchell's
typology and describing the different stakeholder positions. It also deepens our understanding of rural broadband policy in the United
States and helps fill in important knowledge gaps.
For over 70 years RUS has helped bring advanced communications technologies to America's hinterlands, making sure those
removed from the centers of power, commerce, and education, are not left isolated. As we struggle to connect the remaining 30% of
rural Americans, RUS clearly plays an important role. Understanding, clarifying, and improving the role of RUS is paramount if we
are to achieve the goal of a universally connected nation.
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