Comment on FR Doc # 2026-09374
Jamial BlackSupportIndividual
Summary: Jamial Black, a community educator and policy practitioner, supports the proposed information collection but urges the Department to ensure the waiver process is accessible and equitable. The commenter emphasizes that the Department should provide clear guidance, technical assistance, and streamlined reporting to prevent administrative complexity from disadvantaging small, rural, and under-resourced organizations.
My name is Jamial Black, and I submit this comment as a community educator, literacy advocate, and policy practitioner with nearly two decades of experience working across education, workforce development, youth engagement, and community-based advocacy.<br/><br/>I appreciate the opportunity to comment on the Department’s proposed information collection related to the Build America, Buy America Act waiver process. While this proposal concerns administrative and reporting procedures, the practical consequences extend far beyond paperwork. The structure and accessibility of federal procurement systems directly influence whether historically under-resourced communities are able to fully benefit from federal educational investments.<br/><br/>Educational infrastructure policy is equity policy.<br/><br/>Communities experience procurement decisions through the condition of school buildings, access to broadband and technology, transportation reliability, environmental safety, workforce opportunities, and the availability of modern educational resources. Administrative systems that appear neutral on paper can still create unequal outcomes when they fail to account for disparities in staffing capacity, technical expertise, institutional resources, and organizational scale.<br/><br/>I urge the Department to ensure that the waiver request process does not unintentionally disadvantage:<br/><br/>• Rural and under-resourced school districts<br/>• Small and community-based educational organizations<br/>• Minority-led nonprofit organizations<br/>• Institutions serving high-poverty student populations<br/>• First-generation and historically marginalized communities<br/><br/>Many smaller organizations and educational entities operate with limited administrative capacity while simultaneously serving communities with the greatest levels of need. Excessive procedural complexity, unclear guidance, duplicative reporting requirements, or lengthy approval timelines may create barriers that disproportionately affect organizations already navigating significant resource constraints.<br/><br/>I encourage the Department to prioritize the following as part of its information collection and implementation process:<br/><br/>• Clear, accessible, and publicly understandable guidance<br/>• Streamlined reporting requirements that minimize unnecessary administrative burden<br/>• Technical assistance for small and under-resourced applicants<br/>• Transparency regarding waiver approvals and denials<br/>• Consideration of equity impacts during waiver evaluation<br/>• Opportunities for minority-owned and community-based vendors to participate in federally funded projects<br/><br/>The Department should also recognize that educational infrastructure disparities remain deeply connected to broader inequities involving race, geography, disability access, and economic opportunity. Delays or barriers in procurement processes can slow urgently needed improvements involving HVAC systems, broadband access, accessibility accommodations, instructional technology, and school facility modernization.<br/><br/>Federal investment should strengthen community trust and expand equitable access—not create systems that only the largest or most well-resourced institutions can effectively navigate.<br/><br/>As someone who has worked directly within educational and community spaces for many years, I have observed how administrative complexity often becomes an invisible barrier to opportunity. Well-intentioned policies can fail communities if implementation systems are not designed with equity, accessibility, and practical usability in mind.<br/><br/>I respectfully urge the Department to ensure that this waiver and information collection process remains transparent, efficient, equitable, and accessible to the full range of educational institutions and community-serving organizations impacted by federal investment decisions.<br/><br/>Thank you for the opportunity to submit comment and for considering the long-term educational and community impacts associated with this process.