TRIBAL 

BROADBAND

Few Partnerships 

Exist and the Rural 

Utilities Service 

Needs to Identify and 

Address Any Funding 

Barriers Tribes Face

Report to Congressional Requesters

September 2018

GAO-18-682

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-682, a report to 

congressional requesters

September 2018

TRIBAL BROADBAND

Few Partnerships Exist and the Rural Utilities Service

Needs to Identify and Address Any Funding Barriers

Tribes Face

What GAO Found

GAO identified some partnership arrangements between tribes and other entities 

to increase broadband access on tribal lands. Among the seven examples GAO

identified, tribes partnered with different types of entities including private 

broadband providers, a community access network provider, an electric 

cooperative, a regional consortium, and tribally owned broadband providers.

According to the tribes participating in the partnerships, almost all of the 

partnerships improved broadband service on tribal lands. 

The Federal Communications Commission (FCC) and the Rural Utilities Service 

(RUS) are the primary sources of federal funding to deploy broadband 

infrastructure where the cost of providing service is high, including on tribal 

lands. GAO reviewed funding for four programs, three in FCC and one grant 

program in RUS, and found that in total, less than 1 percent has gone directly to 

tribes or to tribally owned broadband providers to expand broadband service. 

GAO found that 14 tribal entities received federal funding from FCC and RUS to 

increase broadband deployment for 2010–2017.

GAO’s Analysis of Federal Funding for Broadband Deployment, 2010-2017

a

FCC funding includes the Mobility Fund Phase I, Tribal Mobility Fund Phase I, and Connect America Fund.

The tribal officials, tribal associations, and tribally owned broadband providers 

GAO contacted cited several barriers tribes face in obtaining federal funding to 

deploy broadband service on tribal lands. For example, they said tribes face 

regulatory barriers in applying for RUS’s grant funding, including (1) preparing 

existing and proposed network design, (2) demonstrating financial sustainability

of the broadband project within 5 years, and (3) obtaining matching funds. An 

interagency council recently recommended that federal agencies identify and 

address regulatory barriers that may unduly impede broadband deployment. 

Although RUS conducts some outreach with tribes, it has not undertaken a 

formal assessment to identify and address the regulatory barriers that tribes may 

face in obtaining RUS’s funding for broadband deployment. RUS officials told 

GAO that they do not have the resources to do so. Nevertheless, lacking such an 

assessment, tribes may continue to face regulatory barriers in obtaining RUS 

funding for broadband deployment on their lands. By identifying and addressing 

any regulatory barriers that impede tribal entities’ access to RUS funding, RUS 

could help tribes obtain funding to expand broadband deployment on tribal lands.

View GAO-18-682. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov.

Why GAO Did This Study

In 2018, FCC estimated that 35 

percent of Americans living on tribal 

lands lack broadband service 

compared to 8 percent of Americans

overall. Various federal programs 

support increasing broadband 

deployment in unserved areas, 

including tribal lands. Tribes can form 

partnerships with private sector 

companies and others to deploy 

broadband infrastructure on tribal 

lands. GAO was asked to provide 

information on these partnerships.

This report discusses (1) examples

and outcomes of tribal partnership

arrangements, (2) the amount of 

federal funding provided to tribal 

entities for broadband deployment, and 

(3) stakeholder-identified barriers that 

tribes face in obtaining federal funding

and the extent to which federal 

agencies have addressed those 

barriers. GAO identified partnerships 

by reviewing federally funded

broadband projects that included a 

partnership component; analyzed 

federal funding dedicated to broadband 

deployment; interviewed agency and 

tribal government officials, tribal

associations, tribally owned broadband 

providers, and industry stakeholders; 

and assessed RUS’s efforts to address 

the regulatory funding barriers tribes 

may face. The information presented is 

illustrative and is not generalizable to 

all tribes or all partnerships.

What GAO Recommends

GAO recommends that RUS identify

and address regulatory barriers that 

impede tribal entities from obtaining 

RUS funding for broadband 

deployment. RUS neither agreed nor 

disagreed with this recommendation.
Page i GAO-18-682 Tribal Broadband

Letter 1

Background 5

Selected Tribes Partnered with Various Entities to Increase 

Broadband Deployment and Outcomes Varied 9

Few Federal Funds Were Provided to Tribal Entities to Increase 

Broadband Deployment from 2010 to 2017 16

Stakeholders Cited Barriers for Tribes to Obtain Federal Funding 

and Federal Agencies Have Taken Few Actions to Address the 

Barriers 18

Conclusions 23

Recommendation for Executive Action 23

Agency Comments 24

Appendix I Objectives, Scope, and Methodology 25

Appendix II GAO Contact and Staff Acknowledgments 30

Table

Table 1: List of Entities Interviewed 28

Figures

Figure 1: Examples of Broadband Infrastructure 6

Figure 2: Percentage of Tribal Entities and Non-Tribal Broadband 

Providers Receiving Funds from Ongoing FCC and RUS 

Programs to Increase Broadband Deployment, 2010-

2017 18

Contents
Page ii GAO-18-682 Tribal Broadband

Abbreviations

BIP Broadband Initiatives Program 

BTOP Broadband Technology Opportunities Program 

CAF Connect America Fund 

EDA Economic Development Administration 

ETC eligible telecommunications carrier 

FCC Federal Communications Commission 

KCEC Kit Carson Electric Cooperative 

NoaNet Northwest Open Access Network 

NTIA National Telecommunications and Information 

Administration 

NTUA Navajo Tribal Utility Authority 

RUS Rural Utilities Service 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-682 Tribal Broadband

441 G St. N.W.

Washington, DC 20548

September 28, 2018

The Honorable John Hoeven

Chairman

The Honorable Tom Udall

Vice Chairman

Committee on Indian Affairs

United States Senate

The Honorable John Barrasso 

The Honorable Maria Cantwell 

The Honorable Steve Daines 

The Honorable Martin Heinrich 

The Honorable Heidi Heitkamp 

The Honorable Brian Schatz 

The Honorable Jon Tester 

United States Senate

Broadband service provides users with many opportunities to improve 

communications, including enhancements in e-commerce, telemedicine, 

and education tools.1 In 2018, the Federal Communications Commission 

(FCC) estimated that 35 percent of Americans living on tribal lands lack 

broadband service, compared to 8 percent of Americans overall.2

According to FCC, the gap in broadband access between rural areas and 

rural tribal lands is even larger. Further, when including mobile broadband 

service, FCC reported that nearly 60 percent of Americans living in rural 

 1

The term “broadband” commonly refers to Internet access that is high speed and 

provides an “always-on” connection, so users do not have to reestablish a connection 

each time they access the Internet.

2

See FCC, Inquiry Concerning Deployment of Advanced Telecommunications Capability 

to All Americans in a Reasonable and Timely Fashion, 33 FCC Rcd 1660 (2018) (2018 

Broadband Deployment Report). For the purposes of this report, we use the definition of 

“tribal lands” from this report. That report defines tribal lands as: (1) Joint Use Areas; (2) 

legal federally recognized American Indian area consisting of reservation and associated 

off-reservation trust land; (3) legal federally recognized American Indian area consisting of 

reservation only; (4) legal federally recognized American Indian area consisting of offreservation trust land only; (5) statistical American Indian area defined for a federally 

recognized tribe that does not have reservation or off-reservation trust land, specifically a 

tribal designated statistical area or Oklahoma tribal statistical area; (6) Alaskan Native 

village statistical area, and; (7) Hawaiian Home Lands established by the Hawaiian 

Homes Commission Act of 1921. See Federal Communications Commission (FCC), 2018 

Broadband Deployment Report, FCC 18-10 (Washington, D.C.: Feb. 2, 2018).

Letter
Page 2 GAO-18-682 Tribal Broadband

tribal lands nationwide lack broadband access, compared to about 31 

percent of rural Americans overall.3 This large difference is due, in part, to 

the relatively high proportion of tribal lands that are located in rural areas 

with rugged terrain and low population density, which decreases business 

incentives to invest in broadband infrastructure in these areas. According 

to FCC, this lack of service on tribal lands could impede efforts by Indian 

tribes to achieve self-governance and promote economic opportunity, 

education, public safety, and cultural preservation.

Currently, the federal government has programs that support increasing 

broadband deployment in rural and unserved areas (including tribal 

lands). Most notably, Congress has tasked FCC with encouraging the 

deployment of advanced telecommunications capability in a reasonable 

and timely fashion to all Americans, including those in rural areas and on 

tribal lands.4 To accomplish this requirement, FCC is responsible for 

implementing Universal Service Fund programs, one of which, the 

Connect America Fund, provides approximately $4.5 billion annually to 

support broadband service in underserved and unserved areas.5 The 

Rural Utilities Service (RUS), a component agency of the U.S. 

Department of Agriculture, also has the Community Connect Program 

that provides grant funding to improve broadband service.6 Tribes as well 

as partnerships between tribes and other entities may apply for such 

funding in order to expand service on tribal lands.

You asked us to examine several issues related to broadband access on 

tribal lands, including the use of partnership arrangements between tribal 

entities—that is, tribal governments and telecommunications providers 

owned by tribes—and other entities. This is the second report we are 

 3

Levels of broadband access may vary between specific tribal lands, which may not be 

reflected in these nationwide figures. We previously reported that FCC’s broadband data 

overstate broadband access on tribal lands. As such, it is possible that the percentage of 

Americans living on tribal lands that lack broadband access is higher than reported. See 

GAO, Broadband Internet: FCC’s Data Overstate Access on Tribal Lands, GAO-18-630 

(Washington, D.C.: Sept. 7, 2018).

4

47 U.S.C. § 1302(a). Advanced telecommunications capability enables users to originate 

and receive high-quality voice, data, graphics, and video telecommunications using any 

technology.

5

47 U.S.C. § 254.

6

Other federal programs can also be used to fund broadband deployment, including 

additional RUS programs. A list of funding resources is available at: 

https://broadbandusa.ntia.doc.gov/funding-list.
Page 3 GAO-18-682 Tribal Broadband

issuing in response to your request.7 This report discusses (1) examples 

of partnership arrangements that tribal entities have used to increase 

broadband deployment on tribal lands and the outcomes of those 

partnerships, (2) the amount of funding provided to tribal entities for 

broadband deployment from key federal programs, and (3) stakeholderidentified barriers that tribal entities face in obtaining federal funding for 

broadband deployment and the extent to which federal agencies have 

taken action to address those barriers. In this report, we use the term 

“partnerships” to refer to when an Indian tribe works with another entity to 

design, build, or operate infrastructure assets to improve or enhance 

broadband access.

To address these objectives, we reviewed the Communications Act of 

1934, as amended,8 the National Broadband Plan,

9 and relevant literature 

identified through a literature search of tribal partnerships for broadband 

deployment. In addition, we reviewed documentation and interviewed 

officials from FCC, RUS, and the Department of Commerce’s National 

Telecommunications and Information Administration (NTIA).10

To identify examples of tribal broadband partnerships for our review, we 

first interviewed agency officials, tribes, private providers, and tribal 

associations to determine if they were aware of any partnerships focused 

on broadband deployment on tribal lands. We then identified any 

broadband projects with a tribal partnership component by reviewing 

financial information from 2010 to 2017 for the following federal programs: 

(1) FCC’s Universal Service Fund high-cost program and Connect 

America Fund (including the Mobility Fund Phase I (Auction 901) and 

Tribal Mobility Fund Phase I (Auction 902)); (2) RUS’s Community 

Connect Grant Program; (3) RUS’s Broadband Initiatives Program; and 

(4) NTIA’s Broadband Technology Opportunities Program. While there 

may be other tribal partnerships that exist, through these efforts we found 

seven tribal partnership examples that we discuss in this report. The 

 7

GAO-18-630.

8

Pub. L. No. 73-416, 48 Stat. 1064 (1934) codified as amended at 47 USC §§ 151 et seq. 

9

In March 2010, an FCC task force issued the National Broadband Plan that included a 

centralized vision for achieving affordability and maximizing use of high-speed Internet. 

See, FCC, Connecting America: The National Broadband Plan (Washington, D.C.: 2010).

10NTIA advises the President on telecommunications and information policy issues, 

including broadband access. 
Page 4 GAO-18-682 Tribal Broadband

identified tribal broadband partnerships are intended to be illustrative 

examples and, accordingly, are not generalizable to others that may exist.

To determine the amount of funding from key federal programs provided 

to tribal entities for broadband deployment, we first identified the federal 

programs that provide broadband funding from NTIA’s Guide to Federal 

Funding of Broadband Projects.

11 The guide lists 17 federal programs that 

fund broadband infrastructure. Of those federal programs, we focused our 

review on four programs—three in FCC and one grant program in RUS—

selected because they provide the most directly relevant funding for 

broadband deployment in unserved areas, which includes tribal lands.12

We compiled total funding data for these four federal programs and the 

amount of funding provided to tribes and tribal entities for broadband 

deployment projects for 2010 to 2017. We took steps to assess the 

reliability of the data, such as cross-checking the data, following up with 

agency officials, and reviewing documentation, and found the data were 

sufficiently reliable for the purposes of summarizing total funding and the 

amount provided to tribes and tribal entities. Because we relied upon titles 

or names of grant recipients to identify those grants awarded to tribes and 

tribally owned providers, our analysis may not include some grants 

awarded to broadband providers that deploy infrastructure to larger 

service areas that may also include tribal lands.

We obtained stakeholder views on barriers that tribal entities face in 

obtaining federal funding and federal government efforts to address those 

barriers by interviewing FCC and RUS officials and 17 tribal government 

officials, 9 tribally owned broadband providers, and 5 tribal associations. 

We selected tribal governments to interview to include variation in 

geographic location, level of broadband deployment, and population 

density. We visited six tribes in Idaho, New Mexico, and Washington 

State. We also interviewed other stakeholders selected to represent a 

range of views and those with experience working with Indian tribes and 

broadband service. These stakeholders included 10 private broadband 

providers and associations; 2 regional consortium; 2 community access 

 11Department of Commerce, National Telecommunications and Information 

Administration, Broadband USA: Guide to Federal Funding of Broadband Projects (June 

2017).

12We found that broadband deployment and infrastructure projects are often included in 

federal funding programs as auxiliary components of the project and that the primary 

purpose is not telecommunications related, but rather related to healthcare, telemedicine, 

or economic growth. Therefore, we excluded those types of programs from our review.
Page 5 GAO-18-682 Tribal Broadband

providers; an academic institution; and a cooperative. The views obtained 

from the interviews are not generalizable to all tribes, all broadband 

providers, or all industry stakeholders. We reviewed a report from the 

Broadband Opportunity Council recommending that agencies identify and 

address regulatory barriers that may unduly impede broadband

deployment and assessed RUS’s efforts to address the regulatory 

barriers tribes may face in attempting to obtain RUS funding for 

broadband deployment.13 Appendix I describes our scope and 

methodology in greater detail.

We conducted this performance audit from September 2017 to 

September 2018 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

The federal government has recognized 573 Indian tribes as distinct, 

independent political communities with inherent powers of a limited 

sovereignty, which has never been extinguished. These tribes can vary 

significantly in regard to tribal size, population, and ownership status of 

land. For instance, some tribal lands include reservations—land set aside 

by treaty, federal law, or executive order for the residence or use of an 

Indian tribe.14 Some tribal lands include parcels with different ownership; 

parcels may be held in trust by the federal government for the benefit of a 

tribe or an individual tribal citizen. Trust and restricted lands can affect a 

tribe’s ability to use their land as collateral to obtain a loan. In addition, 

the size of a tribe’s land base can range from less than one square mile 

to more than 24,000 square miles (the size of West Virginia). Some tribes 

 13The Broadband Opportunity Council was created by the March 2015 Presidential 

Memorandum “Expanding Broadband Deployment and Adoption by Addressing 

Regulatory Barriers and Encouraging Investment and Training.” The Broadband 

Opportunity Council includes 25 federal agencies and departments with missions or 

programs with the potential to drive broadband infrastructure investment and adoption. 

The memorandum asked the Council to produce specific recommendations to increase 

broadband deployment, competition, and adoption through executive actions within the 

scope of agency programs, mission, and budgets.

14The land within the reservation may include a mixture (or checkerboard) of tribal trust 

land, individual Indian trust land, and non-Indian land.

Background
Page 6 GAO-18-682 Tribal Broadband

are located in extremely remote, rural locations and others are located in 

urban areas.

The term “broadband” commonly refers to Internet access that is high 

speed and provides an “always-on” connection, so users do not have to 

reestablish a connection each time they access the Internet. Broadband 

providers deploy and maintain infrastructure to connect consumers to the 

Internet and provide Internet service through a number of technologies. 

Broadband infrastructure may include burying fiber-optic or copper 

cables, stringing cable on existing poles, or erecting towers for wireless 

microwave links, which relay wireless Internet connections from tower to 

tower. Figure 1 illustrates some of the options for broadband deployment 

infrastructure. To install this infrastructure, providers must obtain permits 

from government entities with jurisdiction over the land or permission from 

public utilities to deploy infrastructure on existing utility poles.

Figure 1: Examples of Broadband Infrastructure

The federal government has emphasized the importance of ensuring 

Americans have access to broadband, and a number of agencies, 

including FCC and RUS, currently provide funding to subsidize 

broadband deployment in areas in which the return on investment has not 

attracted private investment. FCC funds a number of programs through 
Page 7 GAO-18-682 Tribal Broadband

the Universal Service Fund, which may increase broadband deployment 

on tribal lands.15 One program is the high-cost program (renamed the 

Connect America Fund (CAF) in 2011), which provides financial support 

to both wireline and wireless telecommunications carriers that provide 

telecommunications services (referred to as providers in this report) to 

supplement their operating costs to serve consumers in rural or remote 

areas, where the cost of providing service is high.16 From 2010 to 2017, a 

total of $34.5 billion in annual and standalone Universal Service Fund 

high-cost support was disbursed to providers, as follows:

• In total, the high-cost program and Connect America Fund provided 

$34.1 billion from 2010 to 2017 in financial support to providers, 

consisting of annual disbursements between $3.7 and $5 billion.

• The Mobility Fund Phase I provided $300 million in 2012 in one-time 

support to providers to expand broadband service in areas where 

service was not available, including tribal lands.17

• The Tribal Mobility Fund Phase I provided $49.8 million in 2014 in 

one-time support to providers to deploy broadband service to 

unserved tribal lands.18

To be eligible to receive for Universal Service Fund program support, a 

provider must be designated an eligible telecommunications carrier (ETC) 

 15The Universal Service Fund also includes the Schools and Libraries Support Program 

(commonly referred to as E-rate). We did not include this program in our review because it 

primarily provides assistance to eligible schools and libraries through discounted 

telecommunications and information services, rather than funding broadband deployment. 

16In November 2011, FCC fundamentally reformed the high-cost program so that it could 

support both telephone and broadband service. See FCC, Connect America Fund et al., 

Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663 

(2011).

17Those providers wishing to receive this support were asked to indicate the amount of 

one-time support they needed to provide service to a particular area in a process FCC 

refers to as a “reverse auction.” Winning bids were based on the lowest per-unit bid 

amounts and one provider per area received support to deploy the broadband-capable 

network in the areas winning bids. FCC sometimes refers to this competitive bidding 

process as a reverse auction since the lower bids win. Mobility Fund Phase II will make up 

to $4.53 billion in support available over 10 years to primarily rural areas that lack 

unsubsidized 4G Long Term Evolution (LTE) service.

18According to FCC’s March 2017 Report and Order and Further Notice of Proposed 

Rulemaking, funds reserved for tribal lands will be included as part of the Mobility Fund 

Phase II auction. See FCC, In the Matter of Connect America Fund Universal Service 

Reform – Mobility Fund, Report and Order and Further Notice of Proposed Rulemaking, 

FCC 17-11, 32 FFC Rcd 2152 (2017)).
Page 8 GAO-18-682 Tribal Broadband

by the appropriate state or by FCC. Under FCC rules, which many state 

programs mirror, ETCs must meet certain service obligations as 

described below:19

• provide a 5-year plan showing how program support will be used to 

improve its coverage, service quality, or capacity in each service area 

where it seeks designation;

• demonstrate its ability to remain functional in emergency situations;

• demonstrate that it will satisfy consumer protection and service quality 

standards;

• offer local usage plans comparable to those offered by the incumbent 

carrier in the areas for which it seeks designation; and

• acknowledge that it may be required to provide equal access to other 

providers within the service area if all other ETCs in the designated 

service area relinquish their designations.

In addition to FCC’s funding, RUS has a current program and had a prior 

program and NTIA had a prior program that provided funding to improve 

broadband service in unserved or underserved areas.20 The RUS and 

NTIA prior programs were authorized by the American Recovery and 

Reinvestment Act of 2009 (Recovery Act) to expand high-speed Internet 

service in unserved areas, and there is no current funding for these 

programs.21

• RUS’s Community Connect program currently provides grants to rural 

communities to provide high-speed Internet service to unserved 

areas.22 The Community Connect program is significantly smaller than 

FCC’s programs, with $95.2 million awarded to 36 recipients from 

2010 to 2017.23 The purpose of the RUS Community Connect 

 1947 C.F.R. § 54.202

20RUS has other programs to finance broadband deployment in rural areas for which tribal 

entities are eligible, but those programs are not the subject of this report.

21Pub. L. No. 111-5, 123 Stat. 115, 118-119 (2009).

22The fiscal year 2018 omnibus spending bill includes $600 million for RUS for a new 

broadband loan and grant pilot program in which at least 90 percent of the households 

served by projects receiving a loan or grant do not have sufficient access to broadband. 

23RUS has a more robust broadband loan program for broadband infrastructure projects, 

including the Telecommunications Infrastructure Loans and Guarantees program and the 

Rural Broadband Access Loan and Loan Guarantee program. However, the scope of this 

review does not include federal loan programs. 
Page 9 GAO-18-682 Tribal Broadband

program is to provide financial assistance to eligible applicants that 

will provide broadband service that fosters economic growth and 

delivers enhanced educational, healthcare, and public-safety benefits. 

In addition, RUS previously administered the Broadband Initiatives 

Program (BIP), authorized by the Recovery Act to expand high-speed 

Internet service in unserved areas. BIP funding included $2.2 billion 

dedicated to deploy broadband infrastructure. Through the program, 

RUS funded a total of 247 infrastructure projects with the requirement 

that all projects be fully completed by June 30, 2015. In addition to the 

infrastructure awards, 12 technical assistance grants went to tribal 

communities to develop regional plans to provide broadband service 

in rural areas that remain critically unserved.24

• NTIA administered a prior program also authorized by the Recovery 

Act called the Broadband Technology Opportunities Program (BTOP). 

NTIA made available $3.1 billion in BTOP funding to deploy 

broadband infrastructure. Through the program, NTIA awarded a total 

of 116 infrastructure grants with the requirement that all projects be 

fully complete within 5 years of the award date.

Although we identified some partnership arrangements between tribes 

and other entities to increase broadband deployment on tribal lands using 

prior authorized funding, based on our review, these arrangements are 

not being used under currently available programs.25 As previously noted, 

there are greater costs associated with deploying broadband on unserved 

tribal lands because the unserved areas are generally rural, with possibly 

rugged terrain, and have low population densities. Because of these 

greater costs, there may be little to no private sector incentive to deploy 

broadband or enter into a partnership arrangement to do so.

During our review, we did not find any partnership arrangements that 

leveraged currently available federal funding from FCC’s CAF or RUS’s 

Community Connect Program. The seven partnership examples we 

identified were ones that obtained federal funding under past programs, 

namely BIP and BTOP that were funded by the Recovery Act. Among 

 24Through BIP, RUS funded 19 technical assistance programs, the majority of which went 

to tribal communities. 

25Specifically, we looked for broadband projects with a tribal partnership component by 

reviewing financial information from 2010 to 2017 for (1) FCC’s high-cost program and 

Connect America Fund (including the Mobility Fund Phase I (Auction 901), and Tribal 

Mobility Fund Phase I (Auction 902)); (2) RUS’s Community Connect Program; (3) RUS’s 

BIP; and (4) NTIA’s BTOP. 

Selected Tribes 

Partnered with 

Various Entities to 

Increase Broadband 

Deployment and 

Outcomes Varied
Page 10 GAO-18-682 Tribal Broadband

these examples, tribes partnered with several different types of entities 

that were eligible to receive federal grants, including (1) private providers; 

(2) a community access network provider; (3) an electric cooperative; (4) 

a regional consortium; and (5) tribally owned telecommunications 

companies (which we will refer to as tribally owned providers). These 

types of arrangements are explained below. Outcomes of these 

partnership arrangements varied, as reported by tribal officials and other 

stakeholders we interviewed, but these stakeholders did not always agree 

on the outcomes.26

Private providers can partner with a tribe to deploy broadband 

infrastructure on tribal lands. We found two instances in which a tribe 

partnered with private providers to improve broadband service.

• Pine Telephone Company and Choctaw Nation. With the land the 

tribe has jurisdiction over covering over 10 counties across 12,000 

square miles in Oklahoma, the Choctaw Nation’s lands encompasses 

about 15 percent of the State of Oklahoma’s total area—an area 

larger than the entire state of Maryland. According to the Oklahoma 

Department of Transportation, the Choctaw Nation is the largest 

employer in the southeastern Oklahoma region and its businesses are 

key contributors to the state’s economy. However, a tribal official told 

us that the tribal government has struggled to meet the tribe’s 

broadband needs. According to the Choctaw Nation official, Pine 

Telephone Company (Pine), a privately owned company, has a 

history of partnering with the Choctaw Nation. In 2010, Pine received 

a BTOP grant of $9.5 million to deploy broadband infrastructure to 

underserved areas of Southeastern Oklahoma, including Choctaw 

Nation lands.

According to tribal officials and representatives from Pine, the 

partnership enabled tribal government agencies and buildings—

including public schools, public safety agencies, fire and police 

departments, and a health clinic—to get broadband service. The 

partnership also improved broadband service for the Choctaw Nation. 

Additionally, Pine had been proactive in partnering with the Choctaw 

Nation to secure federal grants and assist with land use and rights-of-

 26We did not independently verify or evaluate the accuracy of project information as 

reported by the tribal officials and other stakeholders involved in the partnership 

arrangements. 

Private Providers
Page 11 GAO-18-682 Tribal Broadband

way issues, according to a tribal official.27 Pine representatives told us 

that partnering with the Choctaw Nation had been beneficial based on 

their common interest to increase broadband service to the area.

• Inland Cellular, First Step, and Nez Perce. The Nez Perce Tribe’s 

reservation consists of 750,000 acres located in north central Idaho. 

Tribal officials told us that the terrain on the reservation makes 

broadband deployment challenging because it has very large hills and 

deep valleys; additionally the reservation is sparsely populated. Tribal 

officials told us that prior to 2010, there was no broadband service 

available on the Nez Perce reservation. In 2010, the tribe received a 

BTOP grant of $1.6 million for the Nez Perce Broadband 

Enhancement Project; the project was completed in 2013. The tribe 

used that federal grant to deploy 216 miles of broadband (wireless)

infrastructure across its reservation to provide broadband service in 

four northern Idaho counties. As part of the project, the tribe partnered 

with two private providers, Inland Cellular and First Step, to expand 

broadband service on the reservation. The tribe used BTOP funding 

for infrastructure buildout in areas in need of connectivity, while Inland 

Cellular and First Step focused their efforts on infrastructure buildout 

in more populated areas.

According to Nez Perce and Inland Cellular officials, the partnership 

resulted in broadband service being provided to previously 

underserved rural communities and 17 community institutions, 

including schools and public safety organizations. Because the 

partners each own towers on the reservation, the officials told us they 

could collocate equipment on each other’s towers, an approach that 

resulted in more reliable service. Further, Nez Perce officials and 

Inland Cellular representatives told us that their partnership was 

complementary, in that Inland Cellular offered voice services and the 

tribe’s enterprise offered data services.

Community access network providers are typically owned and operated 

by public entities rather than by a private corporation. All profits are 

reinvested to operate, maintain, and expand the community network. 

Community access networks focus on building broadband infrastructure 

 27Securing rights-of-way across Indian lands is an important component of providing tribal

lands with the critical infrastructure needed to support economic activity. Obtaining rightsof-ways to deploy telecommunications equipment across tribal lands could involve 

individual landholders, tribal governments, service providers, and the federal government.

Community Access 

Network Provider
Page 12 GAO-18-682 Tribal Broadband

that allows multiple Internet service providers to offer their services to 

customers. For example, rather than having one choice for Internet 

service, community access network providers will allow several service 

providers to compete for customers.

• Northwest Open Access Network (NoaNet). NoaNet, a utility network 

that offers communities access to broadband infrastructure, has 

deployed infrastructure in rural areas of Washington State, including 

on tribal lands. NoaNet received two BTOP grants in 2010—one grant 

for $84 million and the other for $54 million—to enhance existing 

infrastructure and improve broadband service in unserved areas. 

NoaNet representatives told us that over the course of several years, 

NoaNet deployed 2,300 miles of fiber-optic cable across tribal lands in 

Washington State and partnered with several Indian tribes and 

nations, including the Kalispel Indian Community of the Kalispel 

Reservation, Lower Elwha Tribal Community, and Yakama Nation, to 

deploy broadband infrastructure. For example, NoaNet 

representatives told us they partnered with Yakama Nation and 

exchanged a NoaNet-owned asset for access to a power source and 

the right to install fiber-optic lines on Yakama tribal land.

According to NoaNet representatives, NoaNet’s infrastructure buildout 

improved broadband services and created new economic 

development opportunities for several tribes in Washington State. For 

example, they said NoaNet collaborated with Yakama Nation 

Networks—a wireless network and tribal enterprise serving the tribe—

to provide faster broadband service to the reservation. Further, the 

NoaNet representatives said the availability of broadband service 

created new technical jobs with professional growth opportunities on 

the reservation. NoaNet representatives added that NoaNet enabled 

high-speed Internet service to the Makah Tribe’s health clinic, 

government offices, school, and library, where they previously had no 

Internet service at all. Moreover, they told us that partnerships are 

beneficial in helping tribes gain telecommunications experience. 

Similarly, according to a tribal representative from Jamestown 

S’Klallam Tribe, NoaNet’s infrastructure buildout helped the tribe 

obtain broadband services for its library and also helped create 

economic opportunities for the tribe. 

Rural electric cooperative networks typically serve areas that have low 

population density where traditional providers do not want to serve 

because of limited opportunities for financial return on investment.

Electric Cooperative
Page 13 GAO-18-682 Tribal Broadband

• Kit Carson Electric Cooperative and Taos Pueblo. Kit Carson Electric 

Cooperative (KCEC) is a member-owned, nonprofit electric 

distribution cooperative that operates a fiber-optic broadband network. 

In 2010, KCEC received $64 million in grant funding from RUS’s BIP 

to create a 2,400-mile broadband network in northern New Mexico 

and provide broadband service to businesses and homes, including 

those on the Taos Pueblo and Picuris Pueblo.

In an August 2016 presentation to the New Mexico state legislature, 

KCEC stated that that the project connected tribal members and 

community institutions, created job opportunities, and improved public 

safety by improving emergency communications services.28 According 

to Taos Pueblo officials, the impetus to work with KCEC was to 

improve broadband service to meet immediate economic, education, 

health service, and public safety needs of the tribe. However, based 

on our meetings with both KCEC representatives and Taos Pueblo 

officials they have different perspectives about the success of this 

partnership at delivering broadband service to the tribe. For example, 

KCEC representatives told us that the cooperative constructed the 

fiber-optic network and connected the government buildings and 

homes of Taos Pueblo and Picuris Pueblo members as promised, and 

that KCEC has responded to service interruptions when they occurred

on tribal lands. On the other hand Taos Pueblo officials told us, that 

KCEC did not deploy broadband infrastructure to enable service to all 

homes and buildings on tribal lands as the tribe had expected. 

Similarly, KCEC representatives told us that they worked regularly 

with the Taos and Picuris tribal governments and had good 

relationships with them; they noted that they meet with tribal 

leadership every quarter to maintain effective communications and 

address any issues. In contrast, according to Taos Pueblo officials, 

KCEC did not solicit tribal input when building out the fiber-optic 

network, and only met with Taos Pueblo officials about once a year 

and did not follow up on the issues the tribe raised. Further, according 

to KCEC representatives, in its federal funding application, KCEC 

made a commitment that the Taos and Picuris tribal lands would be 

the first areas targeted for building out the network, and the 

representatives said that KCEC completed 100 percent of the 

construction and connected the tribal governments as promised. Taos 

 28Kit Carson Electric Cooperative presentation to the New Mexico Committee on Science, 

Technology, and Telecommunications presented by Luis A. Reyes, Chief Executive Office 

on August 22, 2016. 
Page 14 GAO-18-682 Tribal Broadband

Pueblo officials, however, said that their tribe was the last to receive 

service and that KCEC did not complete the broadband construction, 

including service to the homes of some of its members, because 

KCEC exhausted its BIP funding. 

We have previously reported that regional consortium, which are typically 

formed by groups to undertake an enterprise beyond the resources of any 

one member, can sponsor regional networks that focus on building 

broadband networks and providing broadband services to schools, 

medical providers, public safety agencies, and other community 

institutions.29

• North Central New Mexico Economic Development District. Located in 

northern New Mexico, the Pueblo of Pojoaque, Santa Clara Pueblo, 

Tesuque Pueblo, and Ohkay Owingeh partnered with local 

governments to establish the North Central New Mexico Economic 

Development District (the District), a regional consortium, to address 

the socio-economic needs of its members. In 2008, regional planners 

and government officials identified broadband as the region’s numberone infrastructure priority because rural north central New Mexico 

relied significantly on dial-up Internet service and lacked affordable 

service to small businesses, libraries, schools, and other community 

institutions. In 2010, the District received a BTOP grant of $10.6 

million to build a community-owned broadband network, known as 

REDI Net. The District sought the BTOP grant to improve rural 

healthcare services, make public and higher education more 

accessible, and improve local government services, like public safety. 

REDI Net’s construction included upgrading existing infrastructure and 

deploying 136 miles of new fiber-optic cable across the region and on 

pueblo lands to replace low-performing dial-up service with faster, 

more affordable broadband service.

According to the project’s progress report submitted to NTIA, the 

partnership enabled broadband infrastructure to be deployed across 

the four participating lands and connect 110 community institutions. 

The project’s description stated that REDI Net was being used to 

deliver telemedicine services, distance-learning applications, and 

critical communications for emergency first-responders. According to 

REDI Net representatives, in 2017, REDI Net became a standalone 

 29GAO, Telecommunications: Projects and Policies Related to Deploying Broadband in 

Unserved and Underserved Areas, GAO-14-409 (Washington, D.C.: Apr. 23, 2014). 

Regional Consortium
Page 15 GAO-18-682 Tribal Broadband

organization, separate from the District, and currently charges a 

monthly fee for the pueblos to use the broadband network. A REDI 

Net representative told us that the biggest outcome of the partnership 

has been the improved relationships and collaboration among the 

Pueblo of Pojoaque, Santa Clara Pueblo, Tesuque Pueblo, and 

Ohkay Owingeh and other local municipalities.

Some tribes have created their own telecommunications companies to 

provide broadband access to their communities. Based on the examples 

we identified, a tribe may create its own telecommunications or 

broadband company or a tribe may partner with an existing tribal 

enterprise such as an electrical utility to provide broadband services.

• Navajo Nation and Navajo Tribal Utility Authority. The Navajo 

Nation—which spans across Arizona, New Mexico, and Utah—

partners with a tribally owned entity, the Navajo Tribal Utility Authority 

(NTUA), to provide broadband service to residents and households. 

According to a NTUA representative, the Navajo Nation has diverse, 

challenging terrain—which includes canyons, valleys, timber forest, 

desert, and mountains—making it difficult to provide broadband 

service to tribal residents. In 2010, NTUA received a BTOP grant of 

$32 million to deploy broadband infrastructure covering 15,000 square 

miles across the three states. According to the project’s progress 

report submitted to NTIA, by 2013, NTUA leveraged BTOP funding to 

deploy 570 miles of fiber-optic cable and 775 miles of wireless 

infrastructure resulting in a total of 1,345 new network miles.

According to NTUA representatives, the partnership between the 

Navajo Nation and NTUA increased broadband deployment on the 

nation and created new opportunities for NTUA to partner with other 

private providers to further expand broadband services. For example, 

NTUA representatives said NTUA partnered with a private broadband 

provider, Commnet, to deploy wireless broadband infrastructure that

enabled tribal citizens to receive 4G LTE service. NTUA and 

Commnet representatives told us NTUA’s relationship with Navajo 

Nation represented an attractive business opportunity for Commnet 

because of NTUA’s established rights-of-ways on the Navajo Nation’s 

tribal lands.

• Saint Regis Mohawk Tribe and Mohawk Networks. The Saint Regis 

Mohawk Tribe, located in the northern region of New York, received a 

$10.5 million BIP grant in 2010 to complete a large broadband project 

expanding access to unserved areas. According to tribal officials and 

Tribally Owned Providers
Page 16 GAO-18-682 Tribal Broadband

Mohawk Networks representatives, the tribe completed a $15 million 

broadband infrastructure project laying 68 miles of fiber and 

connecting 1,500 tribal households and community institutions. Upon 

completion of the BIP broadband project, the tribal officials said the 

tribe launched its tribally owned broadband provider, Mohawk 

Networks, LLC in 2015, to respond to tribal residents’ need for 

reliable, cost-effective broadband service. Tribal officials said Mohawk 

Networks currently provides high-speed Internet to tribal homes and 

businesses.

According to tribal officials, in addition to providing broadband service 

to tribal residents for the first time, the partnership between Saint 

Regis Mohawk Tribe and its tribally owned broadband provider 

created new jobs and opportunities to expand broadband services. 

For example, the officials said the partnership resulted in the creation 

of a tribal subsidiary, North Country Broadband Services, Inc., to 

deploy wireless infrastructure to neighboring counties, thus generating 

new revenue for Mohawk Networks.

FCC and RUS are the primary sources of federal funding to deploy 

broadband infrastructure in rural and remote areas where the cost of 

providing service is high, including tribal lands. Based on our review of 

the funding provided by four federal programs targeted to increase 

deployment in unserved areas, very little has gone directly to tribes or to 

tribally owned broadband providers. Specifically, from 2010 to 2017, we 

found that less than 1 percent of FCC funding and about 14 percent of 

RUS funding went directly to tribes and tribally owned providers. 

Combined, FCC and RUS funding totaled $34.6 billion during that time 

period and tribes and tribally owned providers received $235 million, or 

about 0.7 percent.

30

While the majority of the funding from the four programs we reviewed 

from both agencies is provided to deploy broadband to rural, unserved, or 

underserved areas, only one source of funding, FCC’s Tribal Mobility 

Fund Phase I, is dedicated specifically to deploying broadband on tribal 

lands.31

 30According to RUS officials, Community Connect grant funding has also been awarded to 

non-tribal providers that serve tribal lands.

31The Mobility Fund Phase II will include a tribal reserve to ensure some of the support is 

directed to tribal lands. 

Few Federal Funds 

Were Provided to 

Tribal Entities to 

Increase Broadband 

Deployment from 

2010 to 2017
Page 17 GAO-18-682 Tribal Broadband

The National Broadband Plan stated in 2010 that tribes needed 

substantially greater financial support than was available to them at the 

time and that accelerating tribal broadband deployment would require 

increased funding.32 Furthermore, the National Congress of American 

Indians expressed concerns that the needs for federally funded 

broadband projects are greater on tribal lands but tribes do not receive 

the appropriate share of federal funding aimed at increasing broadband 

deployment.33

Through our analysis we found that 14 tribal entities received federal 

funding from FCC and RUS to increase broadband deployment from

2010-2017 (see fig. 2). Of the four main programs we reviewed, tribes 

and tribally owned providers received the following funds:

• Connect America Fund: Nine tribally owned providers received highcost support funding totaling $218.1 million.

• Mobility Fund Phase I: One tribally owned provider received support 

totaling $3.3 million.

• Tribal Mobility Fund Phase I: No tribal providers received funding.

• RUS Community Connect Grants: Four tribal entities received $13.5 

million.

 32FCC, Connecting America: The National Broadband Plan (Washington, D.C., 2010).

33According to its website, the National Congress of American Indians is the oldest, 

largest, and most representative American Indian and Alaska Native organization serving 

the broad interests of tribal governments and communities.
Page 18 GAO-18-682 Tribal Broadband

Figure 2: Percentage of Tribal Entities and Non-Tribal Broadband Providers Receiving Funds from Ongoing FCC and RUS 

Programs to Increase Broadband Deployment, 2010-2017

a

FCC funding includes Mobility Fund Phase I, Tribal Mobility Fund Phase I, and Connect America 

Fund.

The tribal officials, tribal associations, and tribally owned broadband 

providers we interviewed cited several barriers that tribes may face when 

seeking federal funding for broadband deployment. The two primary 

barriers these interviewees cited were (1) the statutory requirement for 

ETC designation and (2) grant application requirements.

FCC’s Connect America Fund (CAF) is the largest source of federal 

funding for broadband deployment in unserved and underserved areas; 

however, very few tribes are currently eligible for this source of funding. 

At the time of our review, FCC officials told us there were 11 tribes that 

have providers that are designated as ETCs and therefore would be 

eligible to receive CAF funding. Although FCC adopted rules in 2011 to 

Stakeholders Cited 

Barriers for Tribes to 

Obtain Federal 

Funding and Federal 

Agencies Have Taken 

Few Actions to 

Address the Barriers

Statutory Requirement for

ETC Designation
Page 19 GAO-18-682 Tribal Broadband

create CAF and modernize the program so that it could support 

broadband capable networks, FCC officials told us that most ETCs are 

the telephone companies that were in existence when Congress passed 

the Telecommunications Act of 1996.34 According to FCC officials, FCC 

has explored whether it has authority to allow non-ETC providers to 

receive CAF support payments but determined that the statute is clear 

that only ETCs can receive program support. Between 2012 and 2017, 

FCC officials said FCC received nine ETC applications, four of which 

were from tribally owned providers. Of those four, only one tribally owned 

provider was designated an ETC. Three tribes we contacted said they 

would like the opportunity to receive CAF support to deploy broadband on 

tribal lands, but they realize they are not eligible to receive funding unless 

they have the ETC designation. Moreover, officials from two tribes and a 

tribal association stated that while they want to provide broadband 

services in their communities, they did not seek the ETC designation 

because of the ETC service obligations described above.

The Leech Lake Band of Ojibwe applied for ETC status in 2013. We met 

with tribal officials who told us that the tribe was providing broadband 

service in its community through its own, tribally chartered 

telecommunications company and at the time of our visit, they had been 

waiting several years for a decision from FCC on their ETC application. 

The tribal officials told us that if FCC did not make a decision soon, the 

tribal government would need to shut down the broadband network, as 

the tribe’s original decision to fund the network assumed there would be a 

CAF subsidy to help defray the costs. The Leech Lake reservation is rural 

with low population density and is surrounded by the Chippewa National 

Forest. Subsequent to our meeting with the tribe in November 2017, the 

tribe withdrew its application in March 2018, noting that it was ceasing its 

attempt to run its telecommunications company specifically “due to 

inaction” by FCC.

According to representatives from a tribal association we contacted, FCC

has provided ETCs with billions of dollars to deploy service to unserved 

areas through the Universal Service Fund programs, but FCC’s efforts 

have not always been successful in the hardest to reach areas, 

particularly tribal lands. The representatives noted that FCC’s competitive 

market approach does not work where competition cannot be supported 

and that there needs to be a different approach. Similarly, tribal officials 

 34Pub. L. No. 104-104, 110 Stat. 56 (1996).
Page 20 GAO-18-682 Tribal Broadband

from Idaho told us that rural service providers are able to operate due to 

CAF support, but the tribe is not eligible to receive those subsidies. 

Officials said although the provider in their area has received millions of 

dollars in CAF subsidies, it has not deployed broadband on the tribal 

lands. Other tribal officials from Washington State told us that although 

private providers received CAF subsidies to deploy broadband service to 

their reservation, the private providers told the tribe it would be years 

before they offer service on tribal lands.

In 2014, FCC conducted its Rural Broadband Experiment to open up 

eligibility for CAF funding to non-ETC providers. FCC made $100 million 

available for the experiment and applicants included a diverse group of 

entities, including competitive providers, electric utilities, wireless Internet 

service providers, and others. However, while this experiment opened the 

application process to non-ETC providers, it did not remove the ETC 

requirement. CAF support awarded through this experiment was 

provisional pending the broadband providers’ obtaining ETC status. 

According to FCC documentation, there were 181 applicants for the 

experiment, but only 16 ended up meeting all the requirements to receive 

funding. None of those 16 entities was tribal.

Stakeholders we interviewed said tribes may face barriers completing 

federal grant applications to obtain funding for broadband deployment. In 

particular, two community access providers, five tribally owned providers, 

and one regional consortium we contacted said that meeting the 

application requirements was difficult. Representatives from eight of the 

tribes we contacted told us that in general, the language included in the 

federal grant applications is difficult to understand or the administrative 

requirements of federal grants are burdensome. Another tribal 

representative told us he would only recommend applying for RUS’s 

Community Connect program if the tribe has an entire team of dedicated 

people to manage the grant process. Some of the tribal officials we 

contacted cited difficulties preparing required application materials 

between the time a grant announcement was made and the submission 

deadline. For example, tribal officials we contacted from New Mexico and 

Oklahoma stated that the constrained time frames prevented them from 

effectively preparing a comprehensive application package. In some 

cases, the narrow application windows prevented the tribes from applying 

Grant Application 

Requirements
Page 21 GAO-18-682 Tribal Broadband

at all.35 Furthermore, tribal officials, tribal associations, and tribally owned 

broadband providers told us that complying with the following regulatory 

requirements for RUS Community Connect grants could be challenging 

for tribes:

• Preparing existing and proposed network design: RUS’s Community 

Connect program requires applicants to submit information on the 

network’s design that contains all the technical information on the 

applicant’s existing (if applicable) and proposed network. The network 

design is typically completed by a licensed engineer. Tribal officials in 

Washington State told us that conducting analyses of existing 

infrastructure and what improvements are needed can be costprohibitive for some tribes because it requires financial resources that 

the tribe may not have before applying for the grant. Many of these 

costs are related to the expense of bringing in outside experts or 

consultants who are needed to perform the technical studies. Another 

tribal representative told us since the tribe has no way of knowing if 

the grant will be approved, spending money to complete the 

application is a large risk. According to RUS officials, the Community 

Connect program is not authorized to fund pre-planning activities.

• Demonstrating financial sustainability within 5 years: The RUS 

Community Connect grant application requires a “financial forecast” 

that includes the applicant’s existing operations and the proposed 

project and must be supported by a detailed narrative that explains 

the methodology and assumptions used to develop the projections, 

including the number of subscribers projected to take the applicant’s 

service. The financial forecast must cover at least 5 years, and it is 

used by RUS to determine whether the proposed project is financially 

sustainable. However, tribal officials from Idaho told us that it is not 

feasible for tribes to show financial sustainability (a return on 

investment) in 5 years in high cost areas. They noted that a period of 

15 years may be needed to produce a return on investment in those 

areas, and this requirement prevents tribes from qualifying for 

Community Connect grants.

• Obtaining matching funds required to apply for federal grants: RUS’s 

Community Connect program requires grant applicants to provide 

matching funds of at least 15 percent from non-federal sources and 

 35For example, the Community Connect grants for 2018 were announced in March 2018,

and completed applications were due in May 2018.
Page 22 GAO-18-682 Tribal Broadband

does not accept in-kind contributions of goods or services.36 The 

matching fund requirement can be difficult for some tribes to obtain. 

For example, officials from RUS and the tribal entities we contacted 

told us that tribes often times do not have the upfront cash to meet the 

matching requirement. According to a tribal association we contacted, 

obtaining credit is a serious problem for some tribes. In general, tribes 

cannot collateralize tribal property, and therefore often times are 

unable to get bank loans for infrastructure projects.

The National Broadband Plan recommended that federal agencies 

facilitate tribal access to broadband funding opportunities. Furthermore, 

recognizing the need to reduce barriers to expand broadband 

deployment, the Broadband Opportunity Council, established in March 

2015, issued a report stating that federal agencies should use all 

available and appropriate authorities to identify and address regulatory 

barriers that may unduly impede either broadband deployment or the 

infrastructure to augment broadband deployment.37 RUS officials said 

they have held a number of external training and outreach events, such 

as workshops and seminars, with tribes over the past 5 years to provide 

information about RUS’s broadband programs.38 For example, in April 

2018, before the 2018 Community Connect grant’s application deadline, 

RUS hosted a webinar on various requirements for grant applications. 

RUS officials told us that RUS’s outreach efforts generally focus on 

specific programs and instructing potential applicants on program 

requirements and how to complete application packages.

However, beyond these outreach efforts, RUS officials said they have not 

undertaken a formal assessment to identify and address the regulatory 

barriers that tribes may face in obtaining RUS funding for broadband 

deployment. When we asked RUS officials about the feasibility of doing 

so, they said that they have limited resources and multiple competing 

priorities for those resources. RUS officials also noted that BIP authorized 

 36Examples of in-kind contributions include the donation of personal service, material, 

equipment, buildings, land and other non-cash goods or services.

37The Broadband Opportunity Council was tasked with producing specific 

recommendations to increase broadband deployment, competition, and adoption through 

executive actions within the scope of agency programs, mission, and budgets. 

38Additionally, according to the Department of Agriculture’s Office of Tribal Relations 2017 

Communication and Outreach Plan, that office intends to identify and expand current 

modes of outreach to prospective tribal applicants to ensure that relevant programs and 

policies are efficient, easy to understand, accessible, and developed in consultation with 

the American Indian and Alaska Native constituents they impact.
Page 23 GAO-18-682 Tribal Broadband

and provided funding for technical assistance for applicants, funding that 

enabled RUS to address some of the barriers tribes face. Nevertheless, 

lacking such an assessment, tribes may continue to face the regulatory 

barriers described above in obtaining RUS funding for broadband 

deployment on their lands.39 According to the National Broadband Plan, 

local entities (including tribal, state, regional, and local governments) 

decide to offer broadband services when no providers exist that meet 

local needs, and local entities do so after trying to work with established 

carriers to meet local needs. Several of the tribes we visited told us they 

were trying to deploy broadband infrastructure or offer service because 

the private providers were not building out on their lands. For example, 

one tribe stressed that unlike private providers, they would prioritize tribal 

areas needing broadband service, but they need federal funding to do so.

An estimated 35 percent of Americans living on tribal lands lack 

broadband service, which could hinder tribal efforts to promote selfgovernance, economic opportunity, education, public safety, and cultural 

preservation. However, little federal funding aimed at increasing 

broadband service actually goes to tribal entities, even though the 

National Broadband Plan stressed that tribes needed substantially greater 

financial support and recommended that federal agencies facilitate tribal 

access to broadband funding opportunities. Tribes may face barriers in 

obtaining federal funds to deploy broadband, and the Broadband 

Opportunity Council recognized the need for federal agencies to reduce 

the barriers that are impeding broadband deployment. However, RUS has 

not taken steps to identify or address the barriers tribes face when 

applying for RUS grant funding. By identifying and addressing any 

regulatory barriers that impede tribal entities’ access to RUS funding, 

RUS could help tribes obtain funding to expand broadband deployment 

on tribal lands.

The Secretary of Agriculture should direct the Administrator of RUS to 

undertake an assessment to identify any regulatory barriers that may 

unduly impede efforts by tribes to obtain RUS federal grant funds for 

broadband deployment on tribal lands and implement any steps 

necessary to address the identified barriers. (Recommendation 1)

 39Because the information we present is not generalizable to all tribes, tribes may face 

other barriers in obtaining RUS funding.

Conclusions

Recommendation for 

Executive Action
Page 24 GAO-18-682 Tribal Broadband

We provided a draft of this report to FCC, RUS, and NTIA for comment.

FCC and RUS provided technical comments, which we incorporated as 

appropriate; NTIA did not have any comments. A Department of 

Agriculture official indicated in an e-mail message that RUS neither 

agreed nor disagreed with the recommendation. RUS’s technical 

comments noted that RUS has and will continue to work with tribes to 

facilitate broadband deployment, whether tribes have the desire and 

capacity to provide the service or whether another provider is able to 

bring that service to tribal areas. 

We are sending copies of this report to the appropriate congressional 

committees, the Chairman of FCC, the Secretary of Agriculture, the 

Secretary of Commerce, and other interested parties. In addition, the 

report is available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix II.

Mark L. Goldstein

Director, Physical Infrastructure

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-18-682 Tribal Broadband

This report discusses (1) examples of partnership arrangements that 

tribal entities have used to increase broadband deployment on tribal lands 

and the outcomes of those partnerships, (2) the amount of funding 

provided to tribal entities for broadband deployment from key federal 

programs, and (3) stakeholder-identified barriers that tribal entities face in 

obtaining federal funding for broadband deployment and the extent to 

which federal agencies have taken action to address those barriers.

To address these objectives, we reviewed relevant federal statutes, 

including the Communications Act of 1934, as amended,1 and Federal 

Communications Commission’s (FCC) regulations, orders, and policy 

statements including FCC’s Statement of Policy on Establishing a 

Government-to-Government Relationship with Indian Tribes.

2 In addition, 

we reviewed documentation and interviewed officials from FCC, including 

officials from the Office of Native Affairs and Policy; U.S. Department of 

Agriculture’s Rural Utilities Service (RUS); U.S. Department of 

Commerce’s National Telecommunications and Information 

Administration (NTIA); and U.S. Department of Housing and Urban 

Development’s Office of Native American Programs.

To gather information on partnership arrangements that tribes have 

entered to increase broadband deployment on tribal lands and their 

outcomes, we conducted a review of relevant published literature that 

included government reports, industry articles, and publications from 

associations, non-profits, and public policy research organizations.3

Although we were not able to identify an industry-accepted definition of 

 1

The Communications Act of 1934, as amended, codified at 47 U.S.C. § 151, et seq.

2

FCC, In the Matter of Wireless Accelerating Wireless Broadband Deployment by 

Removing Barriers to Infrastructure Investment, Second Report and Order (FCC 18-30) 

(2018) and In the Matter of Statement of Policy on Establishing a Government to 

Government Relationship with Indian Tribes, 16 FCC Rcd 4078 (2000). 

3

For the purposes of this report, we use the definition of “tribal lands” from FCC’s 2018 

Broadband Deployment Report. That report defines tribal lands as: (1) Joint Use Areas; 

(2) legal federally recognized American Indian area consisting of reservation and 

associated off-reservation trust land; (3) legal federally recognized American Indian area 

consisting of reservation only; (4) legal federally recognized American Indian area 

consisting of off-reservation trust land only; (5) statistical American Indian area defined for 

a federally recognized tribe that does not have reservation or off-reservation trust land, 

specifically a tribal designated statistical area or Oklahoma tribal statistical area; (6) 

Alaskan Native village statistical area, and; (7) Hawaiian Home Lands established by the 

Hawaiian Homes Commission Act of 1921. See FCC, Inquiry Concerning Deployment of 

Advanced Telecommunications Capability to All Americans in a Reasonable and Timely 

Fashion, 33 FCC Rcd 1660 (2018) (2018 Broadband Deployment Report).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-18-682 Tribal Broadband

partnerships, we used the term partnerships to refer to instances in which 

a tribal nation or tribal government works with another entity to design, 

build, or operate infrastructure assets, or other capital assets to improve 

or enhance broadband service. This also included partnerships between 

a tribe and its tribally owned broadband provider. To identify examples of 

tribal broadband partnerships for our review, we first interviewed agency 

officials, tribes, private providers, and other stakeholders such as tribal 

associations. We also identified broadband projects with a tribal 

partnership component by reviewing reports from 2010 to 2017 for the 

following federal programs: (1) FCC’s Universal Service Fund high-cost 

program and Connect America Fund (including the Mobility Fund Phase I 

(Auction 901) and Tribal Mobility Fund Phase I (Auction 902)); (2) RUS’s 

Community Connect Program; (3) RUS’s Broadband Initiatives Program; 

and (4) NTIA’s Broadband Technology Opportunities Program. While 

there may be other tribal partnership examples that exist, through these 

efforts we identified seven broadband projects with a tribal partnership 

component completed within the last 5 years (2013 to 2017). We 

interviewed tribal leaders and officials from the seven tribes that were 

involved in the selected partnerships, and visited six tribes in Idaho, New 

Mexico, and Washington State. When meeting with tribal leaders and 

officials, we used the same semi-structured interview questions for all 

tribes; however, tribal officials may not have answered all questions. 

Because we limited our review to these seven selected partnership 

examples, our findings are not generalizable.

To determine the amount of funding from key federal programs provided 

to tribal entities for broadband deployment, we first identified the federal 

programs that provide broadband funding from NTIA’s Guide to Federal 

Funding of Broadband Projects.

4 The guide lists 17 federal programs that 

fund broadband infrastructure. Of those federal programs, we focused our 

review on four programs, three in FCC and one grant program in RUS, 

selected because they provide the most directly relevant funding for 

broadband deployment in unserved areas, which includes tribal lands. We 

first identified federal agencies and programs that provide grants or loans

to tribal and non-tribal entities to buildout broadband infrastructure on 

tribal lands including: FCC, RUS, U.S. Department of Commerce 

Economic Development Administration (EDA), and NTIA. We interviewed 

federal agency officials to identify any additional federal programs that 

 4

Department of Commerce, National Telecommunications and Information Administration, 

Broadband USA: Guide to Federal Funding of Broadband Projects (June 2017).
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-18-682 Tribal Broadband

provided funding in the last 7 years. We excluded federal loan programs 

because they may require letters of credit and or assets as collateral, 

which is often not a feasible option for tribes given land ownership issues. 

We also considered but excluded those federal programs that are not 

directly related to broadband expansion and deployment, such as the 

Department of Housing and Urban Development’s Choice Neighborhoods 

Program, whose primary purpose is housing related. We compiled total 

funding data for these four federal programs and the amount of funding 

provided to tribes and tribal entities for broadband deployment projects for 

2010 to 2017. We took steps to assess the reliability of the data—such as 

cross-checking the data, following up with agency officials, and reviewing 

documentation—and found the data were sufficiently reliable for the 

purposes of summarizing total funding and the amount provided to tribes 

and tribal entities. Because we relied upon titles or names of grant 

recipients to identify those grants awarded to tribes and tribally owned 

providers, our analysis may not include some grants awarded to 

broadband providers that deploy infrastructure to larger service areas that 

may also include tribal lands.

To determine stakeholder-identified barriers that tribal entities face in 

obtaining federal funding for broadband deployment and federal 

government efforts to address those barriers, we interviewed FCC and 

RUS officials and the tribal government officials, tribally owned broadband 

providers, and tribal associations listed in table 1. We interviewed 

representatives from 17 tribes in different locations with varying 

population sizes and levels of broadband deployment. Additionally, we 

interviewed officials from 9 tribally owned and 7 private broadband 

providers operating on tribal lands. We selected these broadband 

providers to interview because they received federal support to serve on 

tribal lands or because they were a designated eligible 

telecommunications carrier (ETC) serving tribal interests. Furthermore, 

we identified and interviewed industry stakeholders such as research 

groups and telecommunications associations on their views regarding 

barriers to obtaining federal program assistance for broadband 

deployment on tribal lands. These stakeholders were selected based on 

their exposure to broadband issues on tribal lands such as representing 

tribally owned broadband providers. The views obtained from these 

interviews are not generalizable to all tribes, all broadband providers, or 

all industry stakeholders. We also reviewed a report from the Broadband 

Opportunity Council directing agencies to identify and address regulatory 

barriers that may unduly impede broadband deployment and assessed 

RUS’s efforts to address the regulatory barriers tribes may face in 
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-18-682 Tribal Broadband

attempting to obtain RUS funding for broadband deployment. For a 

complete list of entities we interviewed see table 1.

We conducted this performance audit from September 2017 to 

September 2018 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

Table 1: List of Entities Interviewed

Representatives from Tribal Governments 

Choctaw Nation of Oklahoma (OK)

Confederated Tribes of the Colville Reservation (WA)

Coeur d’Alene Tribe (ID)

Fond du Lac Band of Lake Superior Chippewa (MN)

Fort Belknap Indian Community (MT)

Jamestown S’Klallam Tribe (WA)

Karuk Tribe (CA)

Leech Lake Band of Ojibwe (MN)

Makah Tribe (WA)

Nez Perce Tribe (ID)

Pueblo of Acoma (NM)

Pueblo of Pojoaque (NM)

Pueblo of San Ildefonso (NM)

Taos Pueblo (NM)

Saint Regis Mohawk Tribe (NY) 

Spokane Tribe of Indians (WA)

Yurok Tribe (CA)

Representatives from Tribally Owned Broadband Providers

Gila River Telecommunications, Inc. (AZ)

Hopi Telecommunications, Inc. (AZ)

Mohawk Networks, LLC (NY)

Mescalero Apache Telecommunications (NM)

Navajo Tribal Utility Authority (AZ, NM, UT)

Red Spectrum Communications (Coeur d’Alene Tribe (ID))

San Carlos Apache Telecommunications Utility, Inc. (AZ)
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-18-682 Tribal Broadband

Standing Rock Telecommunications, Inc. (SD)

Warm Springs Telecommunications Co. (OR)

Representatives from Tribal Associations

Affiliated Tribes of Northwest Indians

National Congress of American Indians

National Tribal Telecommunications Association

Native American Finance Officers Association (NAFOA)

Southern California Tribal Chairmen’s Association - Tribal Digital Village Network (CA)

Representatives from Companies Groups that Work with Tribes

AMERIND Risk

Mobius Legal Group PLLC

Cooperatives

Kit Carson Electric Cooperative 

Regional Consortia

Middle Rio Grande Pueblo Consortium 

North Central New Mexico Economic Development District 

Community Access Providers 

Northwest Open Access Network

REDI Net

Representatives from Providers and Trade Associations 

Carlson Wireless

Century Link

Commnet

Connected Nation

Frontier 

Inland Cellular

NTCA – The Rural Broadband Association

Pine Telephone Company

Rural Wireless Association

Verizon 

Source: GAO. | GAO-18-682
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 30 GAO-18-682 Tribal Broadband

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov.

In addition to the contact named above, Sally Moino (Assistant Director);

Tina Paek (Analyst in Charge); Rose Almoguera; Sharon Dyer; Hannah 

Laufe; Serena Lo; Cheryl Peterson; Malika Rice; Amy Rosewarne; Jay 

Spaan; James Sweetman, Jr.; Hai Tran; and Jade Winfree made key 

contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102292)
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