The Michigan High-Speed Internet Office, or MIHI, requested comments on its initial proposal on how to spend the $1.559 billion available through the federal Broadband Equity Access and Deployment Program. This brief was submitted as a comment to MIHI on Oct. 31, 2023.

The brief describes several major shortcomings with the office’s proposal. Namely, it overestimates how many Michigan residents lack access to broadband internet by inappropriately modifying how “unserved” and “underserved” populations are calculated. It picks winners and losers, favoring certain types of internet service technologies over others. It does far too little to help rural areas get access to higher speeds, which should be its primary focus. This comment argues that the initial proposal would squander much of these federal funds, crowding out private investment and wastefully building duplicative infrastructure.