Planning and Flexibility Are Key to Effectively Deploying Broadband Conduit through Federal Highway Projects

Published by the Government Accountability Office on 2012-06-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

United States Government Accountability Office
Washington, DC 20548

              June 27, 2012

              The Honorable Henry A. Waxman
              Ranking Member
              Committee on Energy and Commerce
              House of Representatives

              The Honorable Anna G. Eshoo
              Ranking Member
              Subcommittee on Communications and Technology
              Committee on Energy and Commerce
              House of Representatives

              The Honorable Edward J. Markey
              The Honorable Doris O. Matsui
              House of Representatives

              Subject: Planning and Flexibility Are Key to Effectively Deploying Broadband Conduit through
              Federal Highway Projects

              Affordable access to broadband telecommunications is increasingly viewed as vital to the
              country’s economic growth as well as for improving state and local systems for traffic
              management, public safety, and educational goals. 1 According to the Federal Communications
              Commission (FCC), the largest cost element for deploying broadband via fiber optic cable is the
              cost of placement, such as burying the fiber in the ground, rather than the cost of the fiber itself.
              Recent legislation introduced in both the U.S. Senate and House of Representatives would
              require the Secretary of Transportation to require states to install broadband conduit during
              construction for certain federally funded highway projects in compliance with standards
              developed by the Secretary, in coordination with FCC. 2 Both the House and Senate bills would
              make conduit available to any requesting broadband service provider for a “charge not to
              exceed a cost-based rate.” Both bills would affect only new construction or highway expansion
              projects that receive federal funding and would not, for example, affect projects limited to road
              resurfacing or general maintenance.

               The term broadband commonly refers to high speed Internet access. GAO, Telecommunications: Broadband
              Deployment Is Extensive throughout the United States, but It Is Difficult to Assess the Extent of Deployment Gaps in
              Rural Areas, GAO-06-426 (Washington, D.C.: May 5, 2006).
               H.R. 1695, 112th Cong. (2011); S. 1939, 112th Cong. (2011). As of our reporting date, both bills were pending in

                                                                                       GAO- 12-687R Broadband Conduit Deployment
You requested that we examine proposed federal “dig once” policies that would require the
deployment of broadband conduit in conjunction with federally funded highway construction
projects as a way to decrease the costs of deploying fiber and eliminate the need for multiple
excavations. 3 This report presents information on (1) the advantages and disadvantages of dig
once policies and (2) how the broadband deployment experiences of states and localities that
have implemented dig once policies can inform the consideration of a federal dig once policy.

Scope and Methodology
This information is based on our analysis of documents from and interviews with officials from
FCC; the Federal Highway Administration (FHWA); state departments of transportation in
California, Massachusetts, Michigan, Oregon, Utah, and Virginia; associations including the
Telecommunications Industry Association, the National Association of Telecommunications
Officers and Advisors, the National Association of Regulatory Utility Commissioners, the
American Association of State Highway and Transportation Officials, the New America
Foundation, the California Emerging Technology Fund, and the Massachusetts Broadband
Institute; providers of broadband service and infrastructure including Google, Verizon, Inyo
Networks, Sonic.net, Monkeybrains, Slic Network Solutions, and Jaguar Communications; and
local government agencies in San Francisco, California; Santa Monica, California; Burbank,
California; and Portland, Oregon. State departments of transportation and local government
agencies were selected based on recommendations from U.S. Department of Transportation
(DOT) and FCC officials and others we spoke with during the course of our work because of
their experience with dig once or similar policies. Broadband service and infrastructure providers
were selected to achieve a diversity of viewpoints, sizes, and company types. Our selection of
stakeholders was judgmental and thus, responses are not generalizable but provide key insights
into the experiences of state and local governments and others with experience deploying
broadband conduit and networks.

We conducted this performance audit from December 2011 through June 2012 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

Results in Brief
A federal dig once policy would likely have several advantages, including potentially decreasing
the frequency of construction on major highways and the cost of installation, while accelerating
access to and reliability of broadband networks. However, disadvantages—which could be
exacerbated by a requirement to install conduit as part of certain federally funded highway
construction—include the potential to install conduit that telecommunications companies might
not use and to divert highway funding away from highway construction. DOT, FCC, and state
DOT officials we spoke with supported the concept of a dig once policy, but suggested
alternative approaches to a federal requirement to install conduit in all covered projects. For
example, FCC officials expressed support for a federal requirement for evaluation of the
feasibility and need for conduit during federal highway construction, and state and U.S. DOT

 Throughout this report we refer to “dig once” policies as those broadband deployment policies focused on increasing
coordination between government agencies and utility companies to decrease the frequency of highway excavation.

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officials expressed support for a federal role in facilitating discussion and best practice sharing
among states implementing broadband deployment policies.

State and local broadband deployment experiences demonstrate the importance of planning
and flexibility to effectively implement dig once policies. Officials from states and localities we
spoke with have adopted various strategies—including establishing formal coordination
processes between state DOTs and local utility companies—but none required installation of
conduit as part of all roadway construction. These officials stated that planning and coordination
with local officials is a critical step to address a number of considerations that should be taken
into account during implementation—such as the location of access points and the appropriate
number and size of conduits—to make the conduit installed more useful for telecommunications
companies. In addition, officials from states and telecommunication companies stated that the
flexibility to take local needs into account in implementing a dig once policy on a project-by-
project basis is important and may help to address the potential disadvantages of a federal dig
once policy.

FCC regulates interstate and international communications by radio, television, wire, satellite,
and cable. According to FCC, communications infrastructure has played a critical role in
increasing opportunities for American innovation, industry, job growth, and international
competitiveness. As such, FCC works to promote competition, innovation, and investment in
broadband services and facilities. Broadband access in the U.S. has thus far been driven largely
by private investment and market innovations and has improved considerably in the last
decade, but there are critical problems that slow the progress of availability, adoption, and
utilization of broadband. Such problems include the high cost of deployment in some locations.
To encourage further broadband deployment, FCC’s National Broadband Plan recommends
that Congress consider enacting dig once legislation applying to all future federally funded
highway projects along rights-of-way and that the U.S. DOT make federal financing of highway,
road, and bridge projects contingent on states and localities allowing joint deployment of
conduits by qualified parties. 4

Federal funding for highways is provided to the states primarily through grant programs
collectively known as the Federal-Aid Highway Program. In a joint federal-state partnership,
FHWA, a division within the U.S. DOT, administers the Federal-Aid Highway Program and
distributes most of the funding to the states through annual apportionments established by
statutory formulas. Once apportioned, the funds are available for obligation for construction,
reconstruction, and improvement of highways on eligible routes. About 1 million of the nation’s 4
million miles of roads are eligible for federal aid—including the 161,000-mile National Highway
System. The responsibility for selecting specific highway projects generally rests with state
DOTs and local planning organizations, which have discretion in determining how to allocate
available federal funds among various eligible projects.

 FCC, Connecting America: The National Broadband Plan (Washington, D.C.; Mar. 16, 2010). Also see, GAO,
Telecommunications: National Broadband Plan Reflects the Experiences of Leading Countries, but Implementation
Will Be Challenging, GAO-10-825 (Washington, D.C.; Sept. 14, 2010) and GAO, Telecommunications: Broadband
Deployment Plan Should Include Performance Goals and Measures to Guide Federal Investment, GAO-09-924
(Washington, D.C.; May 12, 2009).

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Fiber optic cables provide extremely fast data transmission speeds and are commonly used for
long haul transmissions, such as the Internet backbone and middle mile. 5 Fiber optic technology
converts electronic signals carrying data to light, sends the light through transparent glass or
plastic fibers about the diameter of a human hair, and converts the light back to electronic form
for delivery. These fibers are combined into cable of various size diameters, and these cables
are then commonly buried inside an underground conduit where they are better protected from
the elements or natural disasters. Depending on traffic demand, fiber optic technology may be
deployed from the provider’s facilities to a customer’s home or business. In many instances, the
part of the connection to the customer’s premises, commonly called “the last mile,” may be
provided over coaxial cable, copper loop, or wireless technology, which may be more cost-
effective than a total fiber connection. Industry documentation estimates that the expected
useful life of fiber cables is between 20 and 25 years and that the expected useful life of
underground conduit is between 25 and 50 years. Current dig once policy proposals are
focused on increasing middle-mile and backbone broadband infrastructure rather than last-mile
fiber infrastructure to homes and businesses.

A Federal Dig Once Policy Has Several Potential Advantages and Disadvantages
Federal and state officials and industry representatives we spoke with described the potential
advantages and disadvantages associated with federal dig once policies (see figure 1). While
the potential advantages apply to dig once policies in general, some potential disadvantages
may be more or less applicable depending on the specific elements of a federal dig once policy.

Figure 1: Federal and State Officials’ Views about Potential Advantages and Disadvantages of a Federal
Dig Once Policy

 “Long haul transmissions” are transmissions of data over long distances. The infrastructure used for these long haul
transmissions includes what are commonly called the Internet “backbone” and “middle mile” fiber, and does not
typically provide broadband service to end users.

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Potential Advantages
•   Decrease frequency of construction on major highways. Combining broadband conduit
    installation with highway construction, rather than installing the conduit at a later date, might
    result in fewer construction-related disturbances on federal-aid highways. Decreasing the
    number of times a roadway is under construction should decrease construction-related
    traffic congestion and could potentially increase the life-span of roadways, as frequent
    construction can reduce the integrity of road materials.

•   Decrease installation costs. The cost to install underground conduit for broadband deployment
    varies, but installation costs could decrease in some cases if conduit is installed during road
    construction projects because of the ability to share those costs with others involved in the
    road project. One industry official stated that cost savings would depend on the type of work
    being completed for the principal highway project. If the highway project includes, for example,
    digging trenches for water mains or other facilities, then trenching equipment will be on site
    and available and the costs for that equipment would be shared among the broadband, water,
    and other portions of the project. Officials we spoke with noted that the amount of cost savings
    also depends on the type of terrain in which the conduit is installed and the installation method
    required. For example, for a 2011 broadband deployment project through portions of California
    and Nevada, the average contractor bid was $2.18 per linear foot for “plowing” 6 in dirt and
    $10.86 per linear foot for “trenching” 7 in dirt. For the same project, the average contractor bid
    for installing conduit by “boring” 8 was about $22 per linear foot in dirt but about $108 per linear
    foot in areas with solid rock. Taking these factors into consideration, some of the state officials
    we spoke with reported that coordinating road work and underground conduit deployment in
    their states had resulted in cost savings. For instance, officials from one state DOT as well as
    an engineering assessment commissioned for the city of San Francisco estimate that when
    conduit and fiber installation is coordinated with a road or utility project, savings range from
    25-33 percent and are greatest in densely populated areas where the complexity and cost of
    construction is highest. Similarly, Utah DOT, in comparing two rural broadband deployment
    projects, estimated cost savings of roughly 15.5 percent per mile when conduit and fiber were
    installed during a road project rather than being installed independent of a road project.

•   Increase access to and reliability of broadband networks. Officials stated that dig once
    policies could increase access to and reliability of broadband networks at a faster rate than
    current deployment efforts. For example, dig once policies could provide
    telecommunications companies with access to lower cost state-owned conduit in rural areas,
    thus encouraging them to build out their networks in those areas. Further, installing
    additional conduit in areas that already have broadband access could improve network
    reliability by providing redundancy in cases of damage by natural disasters, sabotage, or
    construction. Additionally, officials stated that dig once policies can provide an opportunity to

 “Plowing” is a method of installing underground conduit using a plow blade (pulled by a tractor) to provide an
opening in the ground. The conduit is then placed at the required depth through a feed tube located on the blade. The
dirt is then placed back over the opening to cover the conduit. Plastics Pipe Institute, Second Edition Handbook of PE
Pipe, Chapter 14 http://plasticpipe.org/pdf/chapter14.pdf.
 “Trenching” is a method of installing underground conduit by which a trench is made using specialized trenching
equipment. The conduit is then placed in the ground and the trench is backfilled. Plastics Pipe Institute, Second
Edition Handbook of PE Pipe, Chapter 14 http://plasticpipe.org/pdf/chapter14.pdf.
 “Boring” (directional boring) is a trenchless method of installing underground conduit using a steerable horizontal drill
underneath existing obstacles such as rivers or highways. Plastics Pipe Institute, Second Edition Handbook of PE
Pipe, Chapter 14 http://plasticpipe.org/pdf/chapter14.pdf.

Page 5                                                                     GAO- 12-687R Broadband Conduit Deployment
    replace aging or aerial infrastructure (such as underground copper infrastructure or fiber
    attached to telephone poles) with underground conduit, which is less susceptible to damage.

•   Provide public and economic benefits. Officials we spoke with stated that a dig once or
    similar policy could lead to various public and economic benefits. First, officials from some
    state DOTs, local governments, and industry organizations stated that a dig once policy
    could assist states and localities in developing intelligent transportation 9 and public safety
    systems by making conduit available for state and local use. Officials in some localities also
    stated that access to locally owned conduit has reduced local government
    telecommunications costs. Second, some officials stated that a dig once policy might lead to
    decreases in broadband prices and/or increased broadband performance for consumers
    because of potentially increased competition resulting from the availability of conduit open to
    all broadband providers. Third, officials in some localities as well as industry stakeholders
    stated that increased access to broadband benefits existing businesses and could draw new
    businesses to the area, both of which could increase local economic activity.

•   Decrease time needed to deploy fiber. Some officials we spoke to stated that, depending on
    implementation, a dig once policy has the potential to decrease the time it takes to deploy
    fiber by reducing the legal and regulatory steps associated with activities such as
    environmental impact studies and obtaining permits in multiple jurisdictions. For instance, if
    companies have access to state-owned conduit, they may be able to deploy fiber through
    that conduit without completing steps such as environmental impact studies, which would
    have been completed at the time of conduit installation.

Potential Disadvantages
•   Result in unused conduit. Most officials we spoke with stated that a dig once policy that
    included a federal mandate to install conduit could result in miles of unused conduit and
    wasted funds. For example, while installing conduit for Virginia DOT use in 1998, the agency
    installed spare conduit in a major highway interchange with the intent to lease it to generate
    revenue and to avoid additional construction by telecommunications companies. Officials
    told us that local telecommunications companies were not interested in leasing the conduit
    because their customer base in the area—largely U.S. government agencies and
    contractors—often requires carriers to own their infrastructure rather than lease
    infrastructure. According to Virginia DOT officials, it took 10 years for the agency to generate
    revenue from the extra conduit by selling portions of the conduit system in 2008 and 2011.
    Officials at Caltrans, California’s DOT, told us that the agency had a similar experience with
    conduit installed in the 1990s that remains unused. Further, while some officials stated that
    short pieces of installed conduit can prove to be useful, others were concerned that many
    current highway projects are completed over distances of 1 or 2 miles. A mandate to install
    conduit with federal highway projects could result in small segments of conduit across the
    country that do not connect to other broadband infrastructure. Additionally, industry and
    other officials stated that it may take many years for companies to develop a need for the
    conduit installed as a result of dig once policies. With no active fiber inside the conduit to
    provide incentive for states and companies to protect conduit from road work and other
    hazards, officials were concerned that the conduit might become damaged and unusable.

 Intelligent transportation systems use communications, electronics, sensors, and computer hardware and software
to improve the performance or safety of freeway and transit systems that are designed to improve traffic flow. GAO,
Intelligent Transportation Systems: Improved DOT Collaboration and Communication Could Enhance the Use of
Technology to Manage Congestion, GAO-12-308 (Washington, D.C.: Mar. 19, 2012).

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•     Reduce funding available for highway projects. While the costs of conduit installation are
      small relative to the costs of most highway projects, a dig once policy could reduce funding
      available for highway projects at a time when most state DOTs are struggling financially. For
      example, according to Utah DOT officials, broadband conduit and fiber installation
      comprised approximately 7 percent of the total budget for a 19.36-mile road construction
      project in Utah. Unless an alternative funding source were established, the incremental
      costs of conduit installation and conduit management would be borne by either state DOT
      budgets or federal-aid highway funding, thus reducing the amount of funding available for
      the principal mission of the project: highway construction. While leasing programs may help
      states recover these costs, states will be responsible for the costs of conduit installation and
      administration until the conduit becomes used by telecommunications companies.
      Additionally, state DOT and U.S. DOT officials stated that broadband conduit design and
      construction could delay the design and completion of highway projects.

•     Increase administrative costs for state DOTs and local governments due to maintenance and
      leasing programs. In addition to the costs of installation, some officials expressed concern
      about the costs to maintain the conduit, maintain a conduit inventory, and administer a leasing
      program, all of which may require additional personnel. In states and localities we spoke to,
      additional personnel have been hired in order to manage leasing programs and maintenance,
      such as might be required under a federal dig once policy. For instance, Utah DOT employs
      one full-time employee in addition to contract support to manage the agency’s fiber optic
      program. Similarly, the city of Santa Monica, California, employs three full time employees to
      manage the technical and marketing aspects of its broadband program, and has begun
      working with a contractor to assist with administering the network.

•     Conflict with state and local broadband deployment policies. State and local officials raised
      concerns about a federal dig once policy and cost-based rate requirement affecting states’
      ability to continue current broadband deployment programs. For example, Utah DOT officials
      expressed concern that a requirement to install conduit and lease it at a cost-based rate
      would prohibit Utah’s current broadband deployment efforts in which the state trades the use
      of excess state-owned conduit and fiber for access to conduit owned by telecommunications
      companies. 10 Similarly, Massachusetts DOT (MassDOT) officials stated concerns that a
      requirement to lease conduit at a cost-based rate would prohibit the state’s current practice
      of charging market-based leasing fees to companies that place fiber infrastructure in the
      state’s right-of-way, resulting in the loss of a revenue stream. U.S. DOT officials also noted
      that some states restrict the use of transportation funding for utilities infrastructure, a
      restriction that may conflict with a federal dig once policy.

FCC officials stated that the agency has not conducted any studies on dig once policies or
implemented policies similar to dig once, but that the agency generally supports a federal dig
once policy. FCC officials further stated that they would support a dig once policy that requires
an evaluation of the feasibility and need for broadband conduit as a part of the highway
construction process, rather than a mandate to install conduit in all covered projects. While DOT
does not currently have any programs or policies that promote dig once or similar broadband
deployment strategies, DOT has expressed support for developing a dig once policy and noted
that current regulations allow for fiber optic cable to be run lengthwise along highway rights-of-
way. 11 However, if a federal dig once policy were implemented, DOT officials expressed

    Additional information about this arrangement is provided below.
    23 C.F.R. § 1.23(b),(c).

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concern that the agency would be making decisions and setting policy outside of its scope of
expertise, which is focused on transportation, rather than broadband deployment. Additionally,
DOT officials stated that a dig once policy applying to federally funded new construction and
expansion highway projects would likely affect a very small percentage of the nation’s
roadways. While approximately 30 percent of all federal-aid highway program funding is
allocated annually toward reconstruction and widening improvement projects, this funding is
spent on about 4 percent of the National Highway System, or approximately .01 percent of the
nation’s roads open to public travel. 12

Some state DOT officials we contacted suggested that, rather than a federal dig once policy,
U.S. DOT and FCC should act as facilitators to assist states in creating broadband deployment
policies. For instance, officials in one state suggested that US DOT facilitate a workshop in
which state DOTs with established broadband policies share best practices and ideas with other
states. The U.S. DOT officials we spoke with expressed support for this type of facilitation,
rather than legislation linking federal highway funding to deployment of broadband conduit. On
June 14, 2012, the President issued Executive Order 13616, 13 “Accelerating Broadband
Infrastructure Deployment,” that, among other activities, requires that the U.S. DOT do the

•     Implement a flexible set of best practices that can accommodate changes in broadband
      technology and minimize excavations consistent with competitive broadband deployment.

•     Work with state and local governments to help them develop and implement best practices
      on establishing dig once requirements, effectively using private investment in state
      intelligent transportation infrastructure, and other related activities.

Broadband Deployment Experiences Illustrate the Benefits of
Planning and Flexibility
Officials from states and localities we spoke with have had a variety of broadband deployment
experiences and have adopted various strategies to promote broadband deployment and
infrastructure. Some have implemented dig once policies that encourage coordination between
transportation agencies and utility companies to prevent additional road construction, but we did
not identify any states or localities that have dig once policies that require installation of conduit
as part of any road construction project. State and local strategies include formal coordination
policies between state DOTs and utility companies, a system of trading the use of state-owned
conduit for use of conduit owned by telecommunications companies, and city-owned fiber optic
networks, among others. For example:

•     Michigan DOT has implemented a formal coordination process in which the DOT provides
      its future road work plans to local utility companies, giving the companies an opportunity to
      complete work while the DOT has roads under construction.

  DOT also noted that, when possible, state and local agencies allow utilities to install facilities, such as conduit,
outside of the roadway, which would negate most of the cost savings of installing conduit at the same time as road
     77 Fed. Reg. 36903 (June 20, 2012).

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•   Similarly, the city of San Francisco coordinates with local utility companies through its joint
    trenching policy, which allows utility companies to install conduit or perform maintenance
    either prior to or during roadway reconstruction and restoration. The policy includes a 5-year
    moratorium on excavating streets that have been reconstructed, repaved, or resurfaced.

•   Utah DOT and Virginia DOT leverage private companies’ assets to decrease the cost of
    expanding their state-owned fiber optic networks, which support their intelligent
    transportation systems, through a fiber optic resource sharing program and conduit trade
    system. Virginia’s DOT allows private companies to install conduit and/or fiber in its limited
    access right-of-way, where it does not typically allow utility installations, in exchange for the
    use of company-owned conduit and/or fiber in areas where the state does not have
    broadband infrastructure. Utah DOT installs conduit for its own network—sometimes
    coordinating conduit installation with road construction—and allows private companies to
    use excess state-owned conduit in exchange for the use of company-owned conduit in
    areas where the state does not have broadband infrastructure.

•   MassDOT views its highway right-of-way as an asset developed by the state and,
    correspondingly, charges telecommunications companies leasing fees for using it.
    Companies with underground fiber networks provide MassDOT with fiber or conduit space,
    and then the value of the fiber or conduit space is deducted from the company’s leasing fee.

•   Both Santa Monica and Burbank have city-owned fiber optic networks. The city of Burbank
    has deployed its network primarily through existing electrical conduit and generates nominal
    revenue for Burbank Water and Power by leasing excess capacity to local businesses.
    Santa Monica built its fiber optic network to reduce the city’s costs associated with buying
    Internet service from a telecommunications company, enhance telecommunications
    services, and promote economic development. The city generates revenue through leasing
    services to local businesses to support network operations and fund community programs.

Planning and Flexibility Are Key to Successfully Implementing Dig Once Policies
State, local, and industry officials we contacted who have experience deploying broadband
networks stated that planning is an important aspect of ensuring that a broadband deployment
project is successful. For example, officials planned Digital 395, a 583-mile broadband
deployment project located primarily along highway 395 in California and Nevada, for more than
2 years prior to breaking ground to install conduit. Planning steps included identifying levels of
broadband service in the deployment area and the number of households and businesses
located in the proposed service area. Additionally, recent federal programs that promote
broadband deployment 14 have required grant and loan applicants to demonstrate planning and
goal setting, including how the project will create sustainable broadband adoption in the target
area, a project timeline that establishes key milestones for the implementation of the project,
and potential challenges that could pose delays, among other information.

Officials stated that coordination between states and local communities is an important part of
planning the deployment of broadband networks because local communities have a better

  The American Recovery and Reinvestment Act of 2009 established the Broadband Technology Opportunities
Program, administered by the Department of Commerce’s National Telecommunications and Information
Administration to facilitate broadband access to unserved and underserved areas in the United States. Pub. L. No.
111-5, § 6001 (Feb. 17, 2009). Additionally, the Department of Agriculture’s Rural Utilities Service established the
Broadband Initiatives Program to make loans and award grants for broadband infrastructure projects in rural areas.

Page 9                                                                   GAO- 12-687R Broadband Conduit Deployment
understanding of their broadband needs than states or the federal government and working with
local officials helps ensure that local requirements are met by the state. 15 Additionally, a better
understanding of the broadband needs in an area should help state DOTs determine which
highway projects should include conduit. For example, some officials stated that interstate
highways in the northeast U.S. typically have enough fiber optic infrastructure and that more
conduit is not needed. Additionally, some areas may not need new conduit because there are
alternative deployment methods. For example, Google officials stated that in a recent fiber
deployment project in Kansas City, Kansas, Google deployed fiber optic cables through existing
municipally owned utility conduit, so there was little need for additional conduit during the
deployment process.

Officials stated that planning, including coordination with local officials, may help address several
implementation considerations that should be taken into account for conduit installed under a dig
once policy to be useful and appealing to telecommunications companies. Leaving these
considerations unaddressed may result in conduit that is poorly designed or managed. State DOT
and other officials stated that if officials were tasked with implementation of a dig once policy, they
should consider conduit access, installation, management, maintenance, and cost issues,

•    The location of access points along the conduit. To allow for maintenance and the
     connection of customers to the fiber optic cable, there should be points along conduit at
     which fiber optic cable can be installed in the conduit and accessed in the future.

•    The number and size of conduits. The number of conduits and size of conduit affect the
     number and strand count of fiber optic cables that can be installed in a single conduit or a
     bank of conduit. For example, if a state installs four 1-inch conduits, it likely means that the
     maximum amount of fiber optic cable the conduits can house is four half-inch fiber optic

•    Security of conduit and access points. Telecommunications officials stated that companies
     may not want to share conduit and access points with other companies because of security
     and safety concerns about their fiber optic cables being damaged by another party.
     Additionally, an official suggested that the creation of a qualified vendor list is needed to
     control who can access the conduit to pull fiber optic cable, perform maintenance, and
     prevent damage as a result of negligence.

•    The conduit allocation process. The allocation of conduit between public and private entities
     needs to be managed to effectively give companies access to the conduit and to prevent
     misuse of the conduit. For example, some officials were concerned that large companies
     might be allowed to lease all excess conduit space in order to eliminate competition.

•    A conduit map. A high-quality map or database displaying the location, number, and size of
     conduits is necessary for telecommunications companies to efficiently locate and access the

  U.S. DOT also noted that local agencies currently have the responsibility for determining when, where, and under
which conditions utilities are allowed to occupy all public rights-of-way, including those on roadways. As such, these
local agencies have the controls and authority to require funding and installation of conduit for broadband services if
they determine there is a need.

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•   The management of right-of-way access. Depending on how a policy is implemented, state-
    owned conduit could make the permitting and coordination process for accessing rights-of-
    way in different jurisdictions easier—by requiring that companies only coordinate with the
    state DOT—or more difficult—by requiring that companies coordinate with all the
    jurisdictions the conduit crosses through.

•   The designation of conduit maintenance responsibilities. The clear designation of
    maintenance responsibilities is important because maintenance can become complicated if
    conduit or fiber is damaged by an outside party, natural disaster, or another
    telecommunications company.

•   Setting conduit access rates. The cost to lease conduit from the state must be reasonable
    and, if the conduit is leased at a cost-based rate, states should clearly delineate how costs
    would be allocated among users. For example, states should decide if the access rates will
    differ depending on the number of companies that are colocated in conduit. If one company
    has to bear all of the costs because it is the only company using the conduit, versus three
    companies sharing the cost of the conduit, telecommunications companies may be hesitant
    to be the first to lease conduit.

In addition to planning, state and telecommunications company officials stated that a dig once
policy should allow for flexibility based on the needs of states and localities. Officials stated that
flexibility is beneficial when deploying broadband infrastructure because different areas of the
country have different needs, so conduit installation should be considered on a project-by-project
basis. For example, some officials stated that it does not make sense to install conduit in a 5-mile
stretch of road that is not close to other telecommunications infrastructure or if no work is planned
on successive lengths of road in the near future. Additionally, it may be cost prohibitive to install
conduit in some areas of the country where terrain is challenging. For example, the average
contractor bid for boring in areas of solid rock was about five times the cost of directional boring in
areas with mostly dirt for a 2011 broadband deployment project through portions of California and
Nevada. Similarly, in rural areas, aerial installation allows for more flexibility to connect newly built
homes to fiber optic cables than underground conduit, according to an official at a
telecommunications company that specializes in providing broadband to rural areas. However,
officials told us that certain areas or projects would benefit greatly from pre-installed conduit,
including bridges, interstate highway crossings, and highway interchanges. Officials stated that
such projects can be difficult, costly, and even dangerous places to install conduit so preexisting
conduit could facilitate broadband deployment to areas surrounding such projects.

According to some state, local, and telecommunications officials, planning and flexibility in a dig
once policy may help address potential disadvantages by, for example, accommodating states’
and localities’ existing broadband deployment programs, decreasing the likelihood of installing
conduit that will never be used, and giving states the ability to set their own conduit access
rates. For example, officials in one locality said they would like to continue to generate revenue
from leasing excess capacity from the city-owned network to private businesses, but they are
unsure how a national policy would affect local policy. Flexibility in a federal policy could also
give states the ability to set their own conduit-leasing rates, within reason. According to some
state and industry officials, state DOTs should be able to charge an amount greater than a cost-
based rate to fund future conduit expansion and to ensure that costs associated with conduit
installation and administration are fully recovered.

Page 11                                                          GAO- 12-687R Broadband Conduit Deployment
Agency Comments
We provided a draft of this report to FCC and U.S. DOT for comment. DOT had no comments.
FCC provided technical comments, which we incorporated as appropriate.

We are sending copies of this report to the Federal Communications Commission, the U.S.
Department of Transportation, and other interested parties. In addition, this report will be
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
flemings@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. Additionally, Sara Vermillion, Assistant Director;
Laura Erion; Colin Fallon; Katie Hamer; and Crystal Wesco made key contributions to this

Susan Fleming
Physical Infrastructure Issues


Page 12                                                     GAO- 12-687R Broadband Conduit Deployment
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