October 31, 2023

Ms. Susan Corbin

Director

Department of Labor and Economic Opportunity

105 West Allegan Street Lansing, MI 48933

Dear Director Corbin,

On behalf of the 55,547 members and supporters of Citizens Against Government Waste (CAGW) in Michigan, I respectfully urge you to amend the Broadband Equity, Access, and Deployment (BEAD) Initial Proposal Volume I draft submitted in September 2023 by the Department of Labor and Economic Opportunity (LEO) Michigan High-Speed Internet Office (MIHI) to the National Telecommunications and Information Administration (NTIA) governing how MIHI will administer the $1.559 billion Michigan will receive in broadband funding as a result of the Infrastructure Investment and Jobs Act of 2021.

The MIHI draft proposal, on pages six through nine, addresses BEAD Requirement 6 regarding Community Anchor Institutions (CAIs) that are eligible for BEAD funding to achieve 1 Gbps symmetrical broadband. The BEAD guidance states that eligible CAIs in the “community support organizations” category, “may include any organization that facilitate [sic] greater use of broadband service by vulnerable populations, including low-income individuals, unemployed individuals, and aged individuals.” The guidance suggests that senior centers and job training centers fall into the category of “community support organizations.” The MIHI draft stretches this category to expand eligibility for BEAD funding well beyond the letter or intent of BEAD guidance by permitting 118 entities sub-categorized as stadiums, zoos, aquariums, wildlife centers, and convention centers, including many privately owned, for-profit businesses, to qualify as CAIs. The MIHI states that these entities are included because the Michigan State Police lists them as part of its Critical Incident Management System. The list includes 75 stadiums and sporting facilities, 33 convention centers, and 10 zoos and wildlife centers.

Misusing public funds to subsidize private sports facilities or zoos amounts to little more than corporate welfare. These businesses can and have funded their own broadband expenses without taxpayer support. Taxpayers should not have to subsidize these private, for-profit businesses, diverting public funds away from government priorities like education, healthcare, and infrastructure. Likewise, Michigan should not prioritize funding for non-critical entities like ice rinks that could instead help connect unserved households. Several of the eligible recipients in these sub-categories have caused public controversy before they were included in the MIHI proposal.

For example, the DeYoung Family Zoo, a private, for-profit zoo in Mellen, Michigan has received multiple allegations of animal abuse and neglect. Of the 10 zoos included on the list of eligible CAIs, only five are accredited by the Association of Zoos and Aquariums which “evaluates every zoo or aquarium to make sure it meets… standards for animal welfare, care, and management, including living environments, social groupings, health, and nutrition.” The other five eligible recipients, however, fail to meet the criteria for accreditation. Poorly managed private zoos, especially those that have come under public scrutiny for cases of alleged animal abuse, should not rely on the state to bail them out, and taxpaying Michiganders should not be forced to fund alleged animal abusers. Unfortunately, the draft also mis-categorizes two worthy charities and one public entity with the word “Kalamazoo” in their name as “zoos.” While I urge MIHI to eliminate the subcategory of “zoos, aquariums, and wildlife centers,” these three miscategorized entities should not fall through the cracks.

The owners of private stadiums, racetracks, and convention centers should foot their own bill to provide broadband connections for their customers. The list of 75 stadiums and sports centers includes eight that are no longer in operation, six of which have been demolished. The 67 sports facilities still in operation include 42 that are privately-owned, including a trampoline park, a monster truck rally center, a Hell-themed paintball facility, and 13 NASCAR or drag-racing speedways. The privately-owned facilities also include major league venues like Ford Field, Comerica Park, and Little Caesars Arena. These facilities have long offered free Wi-Fi at their own expense. The Detroit Lions and Verizon announced on February 23, 2017, that the upgraded network at Ford Field would provide free Wi-Fi service for 65,000 concurrent users, regardless of which carrier they use. Comerica Park, home of the Detroit Tigers, began providing free Wi-Fi in April 2015, as part of an initiative by Major League Baseball to provide such service in all ballparks across the country. Little Caesars Arena, home of the Detroit Red Wings and Pistons, has offered free Wi-Fi since it opened in 2017.

To correct the draft’s misplaced and wasteful funding designations and make more money available for unserved households and businesses throughout Michigan, I respectfully urge you to direct the Michigan High-Speed Internet Office to exclude from eligibility as Community Anchor Institutions all entities in the draft proposal that are properly categorized as “Stadiums,” “Convention Centers,” and “Zoos, Aquariums, and Wildlife Centers.”

Thank you for your consideration of these comments.

Sincerely,

Tom Schatz

President

CAGW