ON behalf of Micronesian Telecommunication Corporation, dba, IT&E, a proud telecommunications provider serving the people, businesses, and public offices of the Commonwealth of the Northern Mariana Islands (CNMI) for the past 20 years, I am writing to express our strong support for the Broadband Equity Access and Deployment Program (BEAD), administered under the leadership and guidance of the Trump Commerce Department’s National Telecommunications and Information Administration (NTIA). Additionally, we wholeheartedly support the provisional decision made by the NTIA to recognize the critical need for buried infrastructure throughout the CNMI.
The BEAD program represents a historic federal investment in broadband infrastructure, and NTIA’s policy framework was instrumental in shaping a strategic, inclusive, and forward-looking approach to closing the digital divide. Through its clear guidance, technical assistance, and emphasis on reliability, NTIA allowed states and territories — including the CNMI — to develop broadband plans that reflect local needs while adhering to national standards of excellence. While NTIA had to approve and ultimately dictated the scoring requirements that determined who won and lost, the CNMI was still able to ensure 100% buried fiber deployment to all eligible households, businesses, and community anchor institutions (CAI) under the BEAD program — the only eligible entity in the entire United States with this accomplishment.
The inclusive and transparent approach of the BEAD program — marked by stakeholder engagement, community consultations, and an incredible commitment to buried fiber for disaster resiliency and recovery — laid a solid foundation for transformative change. The BEAD program reflects a disciplined, tech-neutral, provider-neutral, and results-driven strategy that prioritized low-cost deployments, resiliency, and long-term sustainability to ensure the residents of our islands have connectivity during the best and worst of times.
We particularly applaud NTIA’s efforts to align broadband expansion with the unique needs of our island communities, through their acknowledgement in the June 6, 2025 BEAD Restructuring Policy Notice (see page 10) that “the United States is topographically diverse and the most effective broadband technology for one part of the country may not be the best fit for another.”
The emphasis on milestone-based accountability, environmental compliance, emergency preparedness, and fiber- based networks demonstrated a forward-thinking vision that benefits education, healthcare, public safety, national defense, and economic development. Every resident of the CNMI will benefit.
The CNMI BPD, under the Governor’s office has been very active with the BEAD program. They understand the need to adhere to the requirements cited by statute in the Infrastructure Investment and Jobs Act (IIJA, November 2021), the BEAD Notice of Funding Opportunity (NOFO) from May 2022, and the June 2025 BEAD Restructuring Policy Notice (RPN).
For the CNMI, the recognition that the CNMI is a typhoon-prone region that justified classifying a buried service as the Priority Broadband service for the region was a very insightful approach to the topographically diverse option that the NTIA cited in the June 2025 BEAD RPN.
As residents of the region, we understand that the Marianas region has tropical storms and typhoons. After Soudelor in 2015, Yutu in 2018, and Mawar in 2023, the CUC and Docomo both experienced extended network outages with their pole-mounted, aerial services.
Correspondingly, IT&E, the other communications carrier in the CNMI, was able to maintain their wireline services without any service disruptions using their buried wired networks during and after these typhoons.
In Guam, after Mawar, the Guam Power Authority and Docomo had network outages that extended for six or more months.
For networks that do use aerial networks for their service delivery, the risk management strategies for mitigating risks for natural disasters like typhoons are difficult and, as the Soudelor, Yutu, and Mawar have established, ineffective to date.
The CNMI BEAD process has selected the proposal that delivers the desired speed and latency with the least amount of BEAD funding. Over the last three typhoons, aerial networks have had network outages and buried broadband networks have not.
Aerial networks are not a proven and reliable solution for areas that are typhoon prone. For example, on September 18, 2023, the FCC approved the Docomo Petition for Waiver with the FCC to request a delay in the submission of a required filing due to the fact that 71% of their fixed network in Guam is aerial and over 60% of that was damaged during Mawar. (Broeckaert, 2023)
A cost of $31 million out of a budget of over $80M to provide reliable, survivable broadband to households, businesses, and CAIs is not unconscionable. It is a fundamental requirement of a utility that provides lifeline services to the households, business, and public agencies that receive service. Reliable and survivable broadband services are a basic need for all customers.
IT&E’s cost for a buried network to all of the locations in the CNMI was approximately $31M plus a large match by IT&E. The other two applications for a buried network were for $60 and $90M, respectively, plus a match. IT&E’s bid embodies the intent behind the “Benefit of the Bargain” process. IT&E has had buried plant for over twenty years. We understand the benefits of buried networks, and we know how to install and manage those networks.
Based on the current NTIA direction, the CNMI will be returning up to $49M to the federal government of their BEAD deployment funding. Unlike the original process, the Trump administration’s “Benefit of the Bargain” process outlined in the June 6, 2025 RPN does NOT allow grantees to keep unused monies for other projects.
IT&E would suggest that a household or business with limited access to commercial power or a building, home, or CAI damaged following a typhoon is entitled to survivable, reliable broadband to support basic broadband communications like access to information, distance learning and telehealth, among other services. Docomo has not publicly disclosed that their cable-based DOCSIS4 solution is highly reliant on reliable commercial power throughout the network. Fiber-based passive optical networks do not require commercial power. The IT&E solution includes options when commercial power is not available.
After Yutu, it is estimated that the CNMI received $130 to $140M in federal support. Following the Soudelor, Yutu, and Mawar typhoons, IT&E did not require any federal funding for the buried, wired broadband network.
The CNMI broadband office was addressing the deployment of a survivable, reliable broadband network, regardless of the underlying technology. The issue is the reliability and survivability of an aerial versus a buried network.
There have been questions or comments that have cited confusion or “difficulty” in following some of the CNMI proposal requirements. It should be noted that since the June 6, 2025 BEAD Restructuring Policy Notice, the NTIA has issued a total of six updates to the BEAD Frequently Asked Questions from V9 to V14 on August 8, 2025, all over a period of less than nine weeks. The process has been very dynamic and IT&E, in lieu of criticizing the CNMI BPD, would like to complement the CNMI BPD team and the NTIA for their aggressive approach to addressing changes or updates required for the BEAD program.
To ensure that my team was informed throughout this process, I dedicated additional resources within the company to monitor, analyze, and report on the frequent updates to the program. While a challenge, IT&E understood the requirements as cited by the NTIA and the CNMI for BEAD.
Upon reviewing some of the “technical” statements provided by the Docomo team in their letter, my team is questioning the technical concerns cited in the Docomo submission. Of primary concern is that Docomo has cited that “no independent professional and certified engineers or consultants were employed to undertake the evaluation and analysis of the submissions.” IT&E does not support that statement. The NTIA was quite clear that specific submissions required certification by a PE licensed in one of the 56 Eligible Entities. The CNMI had a more detailed requirement. In their attestation letter that all applicants were required to sign and submit, each applicant organization was required to attest that they are technically qualified to complete and operate the project, including attestation that the network design, diagram, project costs, build-out timeline and milestones schedule are all certified by a professional engineer (PE), who:
i. is licensed by the CNMI Board of Professional Licensing with active status,
ii. has demonstrated experience in broadband and/or telecommunications engineering on projects of similar scope to the proposed project, and
iii. states that the proposed network can deliver broadband service that meets the requisite performance requirements to all locations served by the project.
The required certification by a PE who meets the CNMI requirements was designed to be the certification of the technical viability of an application, as cited by the NTIA and further defined by the CNMI BPD for the BEAD application process.
Finally, IT&E would like to address some of the statements made by the previous CEO of Docomo, Mr. Roderick (Rod) Boss following the Mawar typhoon. I have provided references to the articles that reference the quotes by Mr. Boss.
The first set of quotes are from the July 11, 2023 publication of the Marianas Variety:
i. in response to a question from his wife about underground cables: “if I put everything, every part of my network underground in Saipan, I wouldn’t make money there for the next 20 or 30 years,” he said. (Taitano, 2023)
IT&E has been burying their wireline network for over the last twenty years. IT&E has made the commitment to a buried network.
A month later, in the August 19, 2023 issue of the Marianas Variety, Mr. Boss cited the following:
i. “Storms like Mawar are on the rise, and it seems unlikely that it will be another 20 years until the next one,”
ii. “We will also be accelerating the deployment of fiber, which is more resilient than other transmission lines and provides the highest speeds and quality available today.”
iii. He also affirmed in the article that Docomo would be increasing their percentage of underground network. (Cagurangan, 2023)
I concur with these statements by Mr. Boss.
Based on his statements, Mr. Boss appears to have acknowledged the benefits of buried fiber networks; particularly in topographically diverse, typhoon-prone areas like Guam and the CNMI.
As the residences, businesses, and CAIs of the CNMI who were in the CNMI in one or more of the last three typhoons in 2015 (Soudelor), 2018 (Yutu), and 2023 (Mawar) experienced, the IT&E wired network continued to provide service throughout the CNMI while the Docomo wired network and the CNMI commercial power options were compromised in many areas. IT&E began the burial of their wired network in the CNMI over 20 years ago. They are continuing that approach with their proposal for fiber-to-the-home or fiber-to-the-business with their BEAD proposal. IT&E has a buried wired network that is typhoon-proven in a typhoon-prone region.
The IT&E team is ready to begin the deployment of the BEAD program with the hiring and training of new teams of outside plant (OSP) staff to deploy and test the network. Following the completion of the BEAD network upgrades, IT&E is hopeful that many of the new BEAD staff will consider staying in the OSP or moving to different positions within IT&E.
IT&E is ready to support the next phase of a reliable, survivable high-speed, scalable broadband network that will support new opportunities for the businesses and households of the CNMI.
The former CEO of Docomo acknowledged the need for fiber and buried plant in quotes in local publications after Mawar. Docomo even submitted its own buried fiber proposal of 90 plus million for the CNMI BEAD. By virtue of the Benefit of the Bargain Round and following the presentation to the NTIA, both NTIA and the CNMI broadband office recognized the outstanding value proposition of IT&E’s proposal for a 100% buried fiber solution for 1/3 of Docomo’s proposed price. There can be no better example of the “Benefit of Bargain” and rationality to support the award to IT&E
Respectfully submitted,
DAVID H. GIBSON
IT&E Chief Executive Officer
References:
(Broeckaert, 2023). Federal Communications Commission. (Sept. 18, 2023). Granted Docomo Waiver Request for Additional Time to File Form 320. https://www.fcc.gov/document/granted-docomo-waiver-request-additional- time-file-form-320
(Taitano, 2023). Marianas Variety. (July 11. 2023). Telecommunications companies look to put resilient infrastructure underground. https://stupefied-booth.160-153-177-131.plesk.page/news/regional_world/telecommunications-companies-look-to-put-resilientinfrastructureunderground/article_efb3f824-1f94-11ee-8fc8-af7497102e09.html
(Cagurangan, 2023). Pacific Island Times. (August 19, 2023). Docomo confronts PR crisis, vows to upgrade network before the next storm. https://www.pacificislandtimes.com/post/docomo-confronts-pr-crisis-vows-to-upgrade- network-before-the-next-storm
