Support for Solutions to Expedite Broadband Permitting

September 17, 2025

The Honorable Brett Guthrie
Chairman
Committee on Energy and Commerce
2125 Rayburn House Office Bldg.
Washington, DC 20515

The Honorable Richard Hudson
Chairman
Subcommittee on Communications and Technology
Committee on Energy and Commerce
2112 Rayburn House Office Bldg.
Washington, DC 20515

The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
2165 Rayburn House Office Bldg.
Washington, DC 20515

The Honorable Doris Matsui
Ranking Member
Subcommittee on Energy and Commerce
Committee on Transportation and Infrastructure
2370 Rayburn House Office Bldg.
Washington, DC 20515

Dear Chairman Guthrie, Ranking Member Pallone, Chairman Hudson and Ranking Member Matsui:

The Damage Prevention Action Center (DPAC) is writing to encourage the committee to consider including damage prevention requirements as a fundamental component of its legislative efforts to expedite broadband permitting and deployment. As the committee examines solutions to accelerate critical communications infrastructure, there is an unprecedented opportunity to ensure that rapidly deployed broadband networks can function reliably and safely for American families and businesses.

DPAC is a coalition of energy, utility and construction industry leaders advocating for public policies and industry practices that protect America’s critical underground utility infrastructure and those who work and live near these important assets.[1] Our members understand that true infrastructure deployment success requires not just speed, but reliability.

The Cost of Deployment Without Damage Prevention Considerations

According to the Common Ground Alliance’s (CGA) Damage Information Reporting Tool (DIRT) Report,[2] damages to buried infrastructure in the U.S. costs our communities a staggering $30 billion every year. Each of the hundreds of thousands of dig-ins to underground utilities disrupts businesses and communities, cuts off essential utility service, and can result in injuries and fatalities.

The data reveals a particularly concerning trend: Telecommunications/cable TV work has emerged as a leading type of work involved in damages, accounting for 23% of reported infrastructure damage incidents in 2024. This means that as we accelerate broadband deployment, we must be cautious to not simultaneously create conditions that damage the very infrastructure—both communications and other critical utilities—that American communities depend on.

The Opportunity to Enhance Reliability

The legislative proposals under consideration—including regulatory streamlining, expedited permitting timelines and digital application processes—represent a transformative moment for infrastructure policy. However, these initiatives will achieve their fullest potential only if they incorporate damage prevention considerations from the outset.

CGA’s 2024 DIRT Report specifically recommends that policymakers “leverage permitting processes for telecommunications installers to include mandatory damage prevention protocols.” This recommendation is based on clear evidence: Telecommunications work consistently ranks among the highest contributors to infrastructure damage root causes, particularly in locating-related failures where telecom-related damages show significantly higher rates compared to other utility sectors.

Practical Solutions That Serve All Stakeholders

It is crucial to understand that broadband deployment affects far more than just broadband infrastructure. The 2024 DIRT Report shows that a significant percentage of damages involve facility operators (or their contractors) damaging each other’s infrastructure and their own facilities. This means that broadband deployment without proper damage prevention policies can disrupt natural gas delivery, other telecommunications networks, electric service and water/sewer operations.

Effective damage prevention requirements are an essential efficiency measure in infrastructure deployment. When broadband installers fail to follow proper damage prevention protocols, the results include:

• Service outages affecting multiple utility types, not just telecom
• Costly repairs and deployment delays
• Safety risks to workers and the public
• Liability issues that create long-term uncertainty for providers
• Community disruption that undermines public support for infrastructure projects

 

The legislative framework you are developing has the potential to achieve the best of both worlds: Rapid broadband deployment that strengthens rather than compromises our overall infrastructure reliability. By incorporating damage prevention protocols into your streamlined permitting processes, you can:

• Reduce long-term deployment costs by preventing expensive damage incidents
• Improve public safety and maintain community support for infrastructure projects
• Ensure that the billions of dollars invested in broadband infrastructure deliver sustained value

 

DPAC stands ready to work with this Committee and Congress to integrate practical, efficient damage prevention requirements into any broadband permitting legislation. We believe this approach will not slow deployment but instead will ensure that the infrastructure we build rapidly can serve Americans reliably for decades to come.

This opportunity extends beyond simply expediting permits—it encompasses creating a framework for infrastructure development that is fast, sustainable and safe. This is truly an opportunity to demonstrate that American infrastructure policy can achieve speed without sacrificing safety, reliability or the protection of existing critical systems.

 

Sincerely,

Sarah K. Magruder Lyle
Executive Director, Damage Prevention Action Center

[1] Damage Prevention Action Center members: https://damagepreventionactioncenter.com/members/

[2] Common Ground Alliance’s 2024 Damage Information Reporting Tool (DIRT) Report: https://dirt.commongroundalliance.com/