Is the environment a barrier to infrastructure deployment?

This week, the Quello Center had the privilege of hosting Federal Communications Commission (FCC) Biologist, Dr. Joelle Gehring (event page) to discuss her work on reducing avian collisions with communications towers. Dr. Gehring’s work, which was recently profiled by NPR, presently involves collaborating with federal regulators such as the Federal Aviation Administration (FAA) and communication tower owners to adjust tower lighting in order to reduce migratory bird collisions.

Back of the envelope calculations suggest that the efforts of Dr. Gehring and her colleagues have the potential to reduce avian fatalities by 4-5 million per year in the U.S. and Canada alone. Moreover, as Dr. Gehring pointed out, the efforts that tower owners need to undertake are relatively minimal and result in reduced maintenance and energy costs. Dr. Gehring briefly outlines the steps that tower owners should undertake here (additional FCC guidance here) and a more complete set of guidelines is available from the FAA.

Dr. Gehring’s work reminded me of ongoing FCC developments concerning the broader topic of environmental compliance by tower owners, an issue dealt with by the FCC Wireless Telecommunications Bureau’s Competition & Infrastructure Policy Division (CIPD). In particular, as Bill Dutton, Mitch Shapiro and I discuss in our Wireless Regulatory Analysis (see Section 3.1), the FCC’s rules for environmental review ensure that licensees and registrants take appropriate measures to protect environmental and historic resources. In light of all the other major FCC related developments that are grabbing headlines (Susan Crawford tees up some of these here), one that may have been much less noticed is a soon to be released Notice of Proposed Rulemaking and Notice of Inquiry (NPRM and NOI) concerning the FCC’s environmental and historic review.

Specifically, the NPRM and NOI commence an FCC examination of the regulatory impediments to wireless network infrastructure investment and deployments in an effort to expedite wireless infrastructure deployment. Among the topics discussed by the NPRM are potential changes to the FCC’s approach to the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA). Presently, a new tower construction requires, among other things, approval from state or local governing authorities as well as compliance with FCC rules implementing NEPA and NHPA.

NEPA compliance requires three different levels of analysis depending on the potential environmental impact. Actions which do not have a significant effect on the (human) environment do not require an environmental assessment or impact statement and are categorically excluded. For actions that are not categorically excluded, a document presenting the reasons why the action will not have a significant effect on the environment must be prepared. A detailed written statement is required when an action is determined to significantly affect the quality of the environment.

Naturally, wireless providers seeking to enhance service and expand throughout the U.S. have raised concerns that the FCC’s environmental and historic preservation review processes increase the costs of deployment and pose lengthy delays. Issues that have been raised include the need to compensate Tribal Nations claiming large geographic areas (including several full states) within their geographic areas of interest for review of submissions, the burdens of dual reviews by local authorities and State Historic Preservation Officers (SHPO), and the expense of environmental compliance in cases where minimal likelihood of harms are alleged by wireless providers.

The NPRM seeks to mitigate some of the issues, asking stakeholders to weigh in when and what kind of Tribal Nation compensation is justified, how to deal with delays that may result from SHPO review broadly, and whether or not to include categorical exclusions for small cells and distributed antenna systems (DAS) facilities. These actions may all be well intended, well-reasoned, and ultimately in the public interest, but what concerns me is how one sided the FCC’s NPRM reads at the moment. The NPRM elaborates on and in some instances quantifies the cost of NEPA and NHPA review, but little attention is devoted to attempting to qualify or quantify the potential benefits of these additional review processes, or alternatively the potential costs of NOT undergoing NEPA and NHPA review.

Having learned about this NPRM quite late in the game myself, I noticed that the FCC’s Electronic Comment Filing System contains comments from stakeholders on both sides, including wireless service providers and infrastructure owners on one side along with Native Tribes and parties concerned with historic and environmental preservation on the other (the relevant Docket Numbers are 17-79 and 15-180). However, having searched for the word “comment” throughout the NPRM, I observed that the FCC has only cited the former in the NPRM (e.g., see footnotes 72 citing Sprint and Verizon, footnote 73 citing the Competitive Carrier Association, Crown Castle, and Verizon, and so on). Is this an indication that the FCC has already made its decision regarding what to do and simply unveiling the NPRM to indicate that it has thought about the issue before making a ruling? I sincerely hope not, but I am concerned.

Thus, in light of the lack of press concerning this issue I urge the following: If you are worried about the impact that the expansion of wireless infrastructure has on the environment, please make your voice heard. If you have an opinion regarding the extent to which wireless infrastructure developers and/or regulators should consider historic preservation, please tell regulators why you think historic preservation is important. If you are an expert in either of these issues, please try to quantify your response to the FCC. I can’t stress enough the last part: the FCC needs to perform a cost benefit analysis, or stated differently, compare the costs of delays to broadband expansion to those of degradation of environmental preservation standards. If the FCC can place a dollar amount on both issues, it makes it far more likely that a socially and economically sensible decision could be reached.

Dr. Gehring’s own work, which was started over a decade ago during her time as a Conservation Scientist with Michigan State University, highlights the importance of reaching and listening to stakeholders on all sides of the debate. Through her teams’ relentless efforts, regulators were able to come up with environmentally friendly approaches that also reduced costs—a win-win. I hope that regulators can learn from Dr. Gehring’s accomplishments.

Primary takeaways

Digital inequality shows larger impacts on youth academic performance as compared to time spent on screens.
Digital skills play a significant role in mediating unstructured online engagement (social media use, playing video games, browsing the web) and youth academic, social, and psychosocial development.
Unstructured online engagement and face-to-face social interaction are complementary and continuously interact to create and enhance youth capital outcomes.

A familiar story: concerns of screen time

Today’s discussions of adolescent well-being have coalesced around a clear narrative: teenagers spend too much time online, and their academic performance, mental health, and social lives are deteriorating as a result. A steady stream of academic papers, books, and op-eds, alongside a growing number of policy proposals––school phone bans, age-gated social media use, restrictive screen-time limits––rest on the same underlying claim, aligning with a contemporary, digitized version of the displacement hypothesis:

Screen time, particularly the unstructured, free-time spent on social media, gaming, watching video content, or browsing the web, is said to displace the productive face-to-face activities that build adolescents into capable adults.

The implied and often practiced solution is restriction. In response, this dissertation tested this claim directly, and placed it within the broader context of adolescence.

Across three years, I followed 653 Michigan adolescents from early through late adolescence: in grades 8 or 9 (survey one, 2019) to grades 11 or 12 (survey two, 2022). Notably, these students, studied over time, were part of a broader pooled sample of 5,825 students across the same eighteen highschools. The study window captured the year before and the year after the peak of the COVID-19 pandemic and related lockdown orders, functioning as an unprecedented stress test for theories of adolescent social, academic, and digital life and, importantly, as a benchmark to compare the effects of pandemic-related change and inequality to those effects from screen time alone.

Across four studies of adolescents, consisting of six cross-sectional and longitudinal analyses, findings are not consistent with the displacement narrative, nor the broader concerns about the time youth spend on screens.

Findings are, however, consistent with something the current public and (most) academic discussions have largely overlooked or ignored: the gaps and inequalities that determine whether adolescents can access and use the internet meaningfully in the first place.

What the displacement hypothesis overlooks

Displacement and related research and policy concerning the time young people spend online assumes a “zero-sum” model of adolescent day-to-day time. An hour online is an hour not spent studying, reading, sleeping, or interacting face-to-face (i.e., time spent on more productive or developmentally “better” activity).

Indeed, this makes sense logically. However, as an empirical claim, this model requires time spent online to behave differently from all other ways adolescents allocate time; it must produce uniquely negative outcomes and be inherently harmful across digital contexts, rather than the typical mix of trade-offs corresponding to, and often overlooked among any other social or developmental context.

Yet, online time does not differ from other youth activity. Instead, I find it has a mix of pros, cons, and even some “uniquely digital” benefits which youth utilize for social and academic gains. When I compared unstructured digital media use against traditional face-to-face interaction and activities, both produced similar patterns: some negative associations with academic outcomes, some null, and some positive.

Trade-offs within traditional face-to-face activity (for example, social time with friends and family, or time spent in after-school extracurriculars) are treated as ordinary developmental experiences that must be experienced for the betterment of development. The identical trade-offs involving digital time tend to be overlooked or ignored, and online engagement is perceived as altogether harmful.

A growing body of evidence, including this dissertation, do not support that distinction. Indeed, the developmental context is routinely misread, leaving out the context of the experiences and time spent on digital, as well as face-to-face activities, interactions, existing inequalities, and changes inherent to development. As such, I proposed a novel framework to understand these contexts:

Digital capital exchange

Rather than treating screen time as a unified harm, this dissertation advances an “exchange”-based framework, grounded in James Coleman’s theories of youth capital and digital inequality scholarship, particularly following Eszter Hargittai, Jan van Dijk, and Alexander van Deursen (see this list of all dissertation references for full works).

The core proposition is that adolescents’ online engagement is not an alternative to developmental activity but another, albiet modern domain through which young people accumulate and mobilize online resources––particularly digital skills––that work alongside existing social networks and experiences to be exchanged for human capital (measured as: academic achievement, aspirations, STEM interest) and social capital (peer networks, community participation, extracurricular involvement).

Online time is not the mechanism; instead, it is digital skills that I find to be the most vital component in youth capital exchange and enhancement. Unstructured online engagement contributes to online skills; those skills, accumulated and mobilized alongside existing peer, family, and community networks, translate into the outcomes researchers and parents care about, i.e., academic achievement, aspirations, and face-to-face interaction and social networks.

This digital capital framework treats online and in-person contexts as complementary rather than antagonistic, and it situates adolescents’ digital lives within the structural conditions––connectivity quality, device reliability, autonomy of use––that determine whether exchange can occur at all.

Methods (in brief)

Paper-and-pencil surveys were administered to students in classrooms at two time-points: spring 2019 (N=2,876) and spring 2022 (N=2,949), across the same eighteen predominantly rural Michigan schools, grades 8–12. Official, nationally-ranked standardized reading, writing, and math test scores (PSAT 8/9, PSAT 10, SAT; College Board) were then anonymously linked to students’ survey responses with the help of participating districts.

Cross-sectional path analyses modeled pooled and wave-specific samples (pooled N=5,825); two-wave cross-lagged panel models tested reciprocal, longitudinal relationships on the 653 students who completed both surveys. Multi-group analyses of the cross-lagged panel models compared relationships between girls (N=345) and boys (N=308). All longitudinal models included time-invariant socioeconomic covariates as well as time-varying covariates to reduce omitted-variable bias.

Key findings: an overview

To summarize, to the best of my ability, eight chapters across 376 pages, I present two primary findings:

First: digital inequality predicted larger and more consistent declines in human capital than screen time did.

Unreliable home internet and technology maintenance problems––experiencing and/or dealing with broken or outdated devices and software, restrictive school-issued hardware, issues with connecting to or maintaining internet access––decreased youth GPA and standardized test achievement. And, these effect sizes were substantially larger than any negative direct effect from unstructured digital media use.

Across all four empirical studies, digital inequality emerged as the most substantial predictor of academic and developmental decline.

Second: digital skills mediated the relationship between online time and adolescent academic and social outcomes.

Unstructured digital media use, particularly online gaming and web browsing, predicted higher internet and social media skills for adolescents, which in turn predicted stronger academic achievement and self-efficacy (human capital), and social interaction and extracurricular participation (social capital). The positive indirect effect of screen time through skills offset or exceeded any small negative direct effects across several outcomes (supporting our existing peer-reviewed work: Hales & Hampton, 2025, and which you can read more about here).

These exchange processes were amplified when peer and family networks were modeled alongside digital skills, consistent with the premise that online and offline contexts operate together rather than in competition. The effect was not universal: social media skills amplified rather than offset a negative association with consistency of interest, one of the two subscales of grit. The exchange framework describes a contextual and conditional, domain-specific mechanism, not a blanket defense of time spent online.

Implications

If digital inequality, and not screen time, is the primary predictor of adolescent academic and developmental decline, and still warrants concern regarding access quality and experience even with the broader adoption of digital devices across the United States, the current policy emphasis on restriction is pointed at the wrong target. The evidence supports a different set of priorities.

Stable, reliable home (fast) broadband should be treated as an educational prerequisite rather than a consumer amenity. Unreliable connectivity exerted larger downward pressure on human capital than any measure of screen time, and that pressure intensified during the pandemic-era reliance on digital infrastructure. Technology maintenance, device repair, replacement, technical support, and the flexibility to install software and explore the web autonomously, matters as much as initial access, and school-issued devices that restrict autonomous use appear to hinder skill accumulation rather than support it.

Restrictive parental mediation of internet use was negatively associated with grit and self-efficacy at magnitudes comparable to the positive contributions of face-to-face activity. This challenges the assumption that digital restriction functions protectively. Instructive mediation, teaching adolescents to verify information, navigate platforms critically, and mobilize online resources toward meaningful ends, is the posture the data supports.

Finally, the technical skill-building that occurs through gaming, self-directed exploration, and deep web use is skill-building, not wasted time. Closing the persistent gender gap in these domains likely requires legitimizing technical play for girls, rather than restricting it for everyone.

None of the above is an argument that screen time is benign. It is an argument that screen time is the wrong focus, particularly when studied mostly in isolation. Context matters substantially, whether that is time spent on other activities during adolescence, the period of adolescence itself, digital inequality, resources gained from such online use, and how all such factors interact. The factor that predicts whether a given adolescent can convert online engagement into capital outcomes is structural: access, infrastructure, skills, and the autonomy to use them. These factors are distributed unevenly, and its uneven distribution, not hours logged, is what separates adolescents who thrive from those who fall behind.

The full dissertation is available through Michigan State University’s ProQuest archive, or see the embedded full-text PDF below. I’m happy to share papers, preprints, or the underlying framework with anyone interested and working in this area––don’t hesitate to reach out via my contact form. Thanks for reading.

Tags: accelerating wireless broadband deployment FCC historic preservation Native Tribes NEPA NHPA wireless infrastructure

Is the environment a barrier to infrastructure deployment?