18 Jun 2025

The New 2025 BEAD Restructuring Policy Notice: What Missouri Community Stakeholders Need to Know

by | | 0

The long-delayed effort to begin spending nearly $42.5 billion in broadband infrastructure funding authorized by Congress nearly four years ago is still unfolding. This blog is intended to help community stakeholders—including local government officials, chambers of commerce, nonprofits, and engaged citizens—understand the current situation and work productively to ensure the best possible broadband service is deployed as quickly as possible in their community.

The latest chapter in the BEAD funding saga is the release of a newly revised set of requirements that states must follow to access their share of available BEAD funds. This policy—titled the “Broadband Equity, Access, and Deployment (BEAD) Program: BEAD Restructuring Policy Notice”(the “Policy Notice”) was released June 6, 2025, and it represents a significant shift in federal broadband funding priorities, eliminating or revising many of the earlier requirements imposed by the Biden administration in the original BEAD NOFO, published three years ago, and supplemented with various updates that states had been working to fulfill up until a few weeks ago.

The new Policy Notice emphasizes swift action and sets an aggressive timeline for implementation. Much of the work previously completed by Missouri’s Office of Broadband Development (OBD), including the state’s Initial Proposal and the implementation efforts described in an earlier blog, will now need to be revised to comply with the new requirements outlined in the Policy Notice.

The number of Broadband Serviceable Locations (BSLs) that remain eligible for BEAD funding also may be reduced, because the Policy Notice now permits Unlicensed Fixed Wireless (ULFW) providers to assert they are now providing the broadband service at the level required by the BEAD Act. A new challenge process enabling ULFW providers to provide evidence to OBD is now underway and it should be completed within a few weeks.

All this comes against the backdrop of OBD’s highly successful first round of funding under the prior BEAD NOFO guidance. While specific winners of round one and its sub rounds were not announced, approximately 90% of the eligible locations received proposals and OBD did release information identifying the BSLs where a proposal had been preliminarily accepted. All those results will have to be thrown out. OBD and the ISPs that decide they still want to participate in the BEAD funding program will need to quickly adjust to a new set of rules and priorities and resubmit under a new set of scoring criteria. All this must happen in time for OBD to include the results in its revised final proposal to NTIA in early September.

The new required “Benefit of the Bargain” funding round (described below) is necessary because the Policy Notice, eliminates or substantially modifies criteria for awarding BEAD funding, and it opens up the process to a wider group of internet providers.

Here are some of the most significant changes:

New Definition of a “Priority Broadband Project.” The BEAD statute allowed states to prioritize certain projects over other types of technologies. These are referred to as “Priority Broadband Projects.” The Biden administration’s BEAD NOFO limited this definition to end to end fiber internet (fiber to the premises or FTTP). FTTP was favored over lower cost technologies so long as the amount of BEAD funding requested did not exceed the state’s Extreme High Cost Per Location Target (EHCPLT) for the location. The EHCPLT limit was imposed to make sure that all locations that were not adequately served could receive BEAD funding.

The Policy Notice broadens Priority Broadband Project definition to include any technology that the state (OBD in Missouri) determines can provide broadband service at speeds of no less than 100/20 Mbps with latency less than or equal to 100 ms., and that can easily scale speeds over time to meet the evolving connectivity needs of households and businesses and support the deployment of 5G, successor wireless technologies, and other advanced services.

This definition is important, because all Priority Broadband Projects will compete for BEAD funding using the same scoring matrix in the Benefit of the Bargain funding described below. (Policy Notice §3.1; pp.8-9).

ULFW Potentially Qualifies as a “Priority Project.” To qualify as a Priority Broadband Project, unlicensed fixed wireless (ULFW) must deliver reliable internet to all covered BSLs at speeds at 100/20 Mbps with latency under 100 ms. The BEAD Policy states that a ULFW provider’s network will be considered capable of reliably delivering service at the minimum levels required by the statute if it can demonstrate the ability to deliver download speeds of at least 5 Mbps assuming simultaneous connection at all locations. The BEAD Policy leaves the requirements and standards necessary for a ULFW provider to show its project is easily scalable over time to meet future needs to the discretion of each state. However, NTIA does reserve to itself the right to overrule the state’s determination in cases where it disagrees. (Policy Notice § 3.2; p.10; Appendix A)

LEO Satellite Potentially Qualifies as a “Priority Project.”  Low earth orbit satellite internet providers (LEO Satellite), such as Starlink, also could qualify as a Priority Broadband Project as well, if the provider commits to make sufficient bandwidth available on the network to serve all locations for a period of at least 10 years. States may adopt enforcement mechanisms—such as claw backs of BEAD grants—to ensure compliance; however, they may not take any ownership or security interest in the provider’s network equipment. (Policy Notice § 3.2; p.10; Appendix B)

New “Lowest Cost to the Government” Scoring Matrix Required. Generally, OBD is required to use a scoring matrix for all Priority Broadband Projects that favors the proposal or combination of proposals resulting in the lowest dollar outlay of BEAD funding.

However, so long as the EHCPLT is not exceeded, a higher-cost Priority Broadband Project proposal may be selected if it is within 15% of the amount requested by the lowest Priority Broadband Project  proposal.

In this case OBD may select among the Priority Broadband Project proposals based on a scoring matrix that takes only the following criteria into account:

  • The speed at which the project will be completed (with preference for faster deployment)
  • The technical capabilities and scalability of the proposed technology (for example, fiber’s ability to easily upgrade speeds in the future)
  • The reliability of the service, especially in challenging environments
  • Whether the applicant was previously a provisional subgrantee under the old rules (though this is only a minor consideration)

If all Priority Broadband Projects exceed the EHCPLT, OBD may accept a lower cost non-priority option if it meets the 100/20 Mbps and 100 ms. service level, even though it is not able to easily scale to meet future needs.(Policy Notice §§ 3.3–3.4; pp.10-13 )

NTIA Specific Oversight on Project Selection. While states retain broad authority over project selection, the BEAD Policy cautions states against setting EHCPLT at an unrealistically high level to preserve the possibility of fiber deployment. NTIA also reserves the right to disapprove project selections that it believes are inconsistent with BEAD program goals.
(Policy Notice p.9 and §3.4; pp.9 and 11-13)

Project Area Proposals Can Exclude BSLs. OBD must accept proposals that exclude one or more BSLs or provides for different delivery technologies where the provider determines the cost of deployment for a specific technology is too high. In such cases, OBD may solicit alternative solutions from other providers or consider a provider’s proposal to use different technologies for those BSLs.(Policy Notice §3.3; p.11)

Affordability Rules. OBD can no longer impose a specific Low-Cost Service Option (LCSO) that BEAD-funded projects must offer. Instead, providers must propose their own affordable plans, which must be made available to households eligible under the FCC’s Lifeline Program, rather than the broader criteria previously allowed under the Affordable Connectivity Program.
(Policy Notice §§ 2.6; 2.7; pp.6-9)

Open Access/Net Neutrality. Prohibitions on data caps and requirements to provide wholesale or open-access connections to BEAD-funded networks have been abolished. NTIA concluded these mandates discouraged participation and increased project costs.
(Policy Notice §2.3; p.5)

DEI, Workforce and Labor Requirements. Prior BEAD NOFO mandates concerning diversity, equity, and inclusion (DEI), fair labor practices, and related reporting have been eliminated. Instead, subgrantees are only required to certify compliance with applicable federal labor laws.(Policy Notice § 2.1; p.4)

Climate Resilience Factors.  The requirement that BEAD proposals be scored based on their contribution to climate resilience has been eliminated. Project participants will satisfy this statutory requirement by establishing risk management plans that account for technology infrastructure reliability and resilience to natural disasters (e.g., wildfires, flooding, tornadoes, hurricanes, etc.) as well as cybersecurity best practices..
(Policy Notice § 2.2; pp. 4-5)

No Credit for Community Input. OBD may no longer award scoring points or preference based on stakeholder engagement, demographic targeting, or other forms of community input. Public comment is still required for the Final Proposal, but it cannot affect project scoring.(Policy Notice § 2.4; pp. 5-6)

Where Do We Go From Here?

Admittedly more guidance will be issued in the coming weeks from OBD as it moves forward to implement the Policy Notice, and likely from NTIA as well. There also is the possibility that certain aspects of the Policy Notice will be challenged in court and the process will be further delayed based on a claim that it strays too far from BEAD’s statutory mandates.

However, it seems more likely that OBD will publish a new BSL map reflecting a revised set of BEAD funding eligible sites in a few weeks and a revised invitation for proposals under the Benefit of the Bargain funding round. That invitation also may provide further guidance (consistent with both the statute and the Policy Notice) detailing how ULFW and LEO Satellite proposals can qualify as a Priority Broadband Project.

For community stakeholders, the greatest risk may be that the providers that won preliminary allocations of BEAD funding under the BEAD NOFO process will simply give up, because they believe their FTTP proposal cannot overcome the construction and installation cost advantage of a ULFW solution. Even though many of these ISPs already have spent thousands of dollars on developing their proposals, after years of work, preparation and waiting, they may be at the point where they view further participation in the BEAD program as throwing good money after bad.

Yet the perceived cost advantage of these wireless technologies when compared to FTTP or hybrid fixed wired solutions may be illusory, depending on how OBD (and NTIA) hold UFLW, LEO Satellite or other technologies to the statute’s mandates for service that is easily scalable and future-proof. Much of Missouri’s unserved and underserved locations are in areas where terrain makes deployment of reliable wireless service challenging, and these challenges increase as future needs for higher connection speeds and lower latency require towers to be located closer to the end user and backhaul capacity to increase.

This is illustrated by the independent study commissioned by OBD in 2022. It is worth remembering that this study found that the overall cost of deploying wireless internet statewide was approximately the same as a 100% FTTP solution. While there likely are areas in Missouri, and throughout the United States, where wireless technologies have a substantially lower deployment cost and also can be easily scaled it meet future needs, the 2022 study appears to show that for many Missouri locations, if they are engineered properly to meet specific conditions and terrain challenges, wireless may cost more to deploy than FTTP.

The point here is that community stakeholders who want more than the minimum level of broadband service required by BEAD in their community, need to reach out to the local ISPs that participated in the aborted NOFO BEAD funding round, and urge them to move forward with a new proposal in the Benefit of the Bargain round this summer. They also should be receptive and at least consider joining with a provider in ways that allow them to reduce their  BEAD funding request, so it can fall within the limit of the new 15% rule imposed by the Policy Notice. For example, a local community might agree to fund a fixed a portion of a FTTP network provider’s cost to expand service to a few critical high cost BSLs in exchange for the provider’s agreement to reduce its BEAD funding request by a like amount. Since it is the amount of BEAD funding requested (rather than the cost of the network) that governs, the FTTP bid might be reduced to a point that it did not exceed 15% of a competing ULFW or LEO Satellite Priority Broadband Project proposal.

As the BEAD program enters this critical phase, efforts made by local leaders and  stakeholders still could help determine whether their community secures broadband infrastructure that just meets minimum federal thresholds, or instead infrastructure that is far more durable and future-proof. Now more than ever, communities need to support and encourage ISPs that have already submitted proposals that can meet this long-term vision.

10 Jun 2025

BEAD Restructuring and Updated NOFO Information

by | | 0

Updated information about the restructuring of the BEAD program is now available on the Missouri Office of Broadband Development website: https://ded.mo.gov/programs/community/broadband-equity-access-and-deployment-bead-program#BEADNotices

From the Missouri Office of Broadband Development:

BEAD Restructuring: UFLW and BEAD Location Eligibility

Unlicensed fixed wireless providers in the state of Missouri are notified that they have seven calendar days (until Friday, June 13) to indicate that they intend to submit evidence that BEAD funding is not required for the locations they serve in line with major federal revisions to the BEAD program in the BEAD Restructuring Policy Notice published June 6, 2025 (see Section 4: Optimizing BEAD Locations and Appendix A).

Providers may wish to reference materials prepared and submitted to the state in compliance with Missouri’s BEAD Alternative Technology Policy in identifying locations where they wish to assert service availability and preparing supporting evidence. OBD stresses, however, that providers must submit a new notice of intent to submit evidence and new evidence to remove locations they claim to serve from BEAD eligibility, regardless of whether they participated in the process under Missouri’s BEAD Alternative Technology Policy. The NTIA policy notice OBD’s policy was based on (the “Alternative Broadband Technology Policy Notice”) have been rescinded by NTIA. Among other differences, this new process will have implications for a location’s eligibility for funding of projects using any technology under the BEAD program, not just funding using satellite or unlicensed fixed wireless service.

ULFW providers will have seven calendar days from their notice to NTIA to submit documentation supporting the claim that that the existing ULFW services meet the same technical and service standards required for a BEAD subgrant (see Appendix A of the Restructuring BEAD Policy Notice). If a ULFW service provider demonstrates that it meets the requirements specified by this Policy Notice, the served locations will be ineligible for BEAD Program funding.

Providers should review the technical criteria in Appendix A and be prepared to submit appropriate documentation as well as a list of locations for which they intend to assert service in the seven-day window following their notification of intent to claim service. Only locations where the FCC National Broadband Map indicates potentially qualifying unlicensed fixed wireless service is currently available will be considered in terms of determining BEAD eligibility. (June 6, 2025)

From the United States Department of Commerce:

Broadband Equity, Access, and Deployment (BEAD) Program: BEAD Restructuring
Policy Notice

BEAD 2025 NOFO SUMMARYDownload
6.2025 NOFODownload
28 May 2025

Breaking Barriers: The Availability of Accessibility Tools

by | | 0

In a world increasingly reliant on technology, accessibility is no longer an option, it’s a necessity. Built-in tools on major platforms like iOS, macOS, Windows, and Android are transforming the way people with disabilities interact with their devices. These features are not just about usability; they embody empowerment, inclusivity, and independence. Let’s dive deeper into the accessibility options available across these platforms, technologies that work across platforms, and why they matter.

What are Accessibility tools?

Accessibility tools are technologies or features designed to assist people with disabilities or unique needs to interact with and navigate the world more easily. These tools can be physical devices, software, or built-in features within existing technology. Some examples include:

  • Screen readers for individuals with visual impairments, which read text aloud or convert it into braille.
  • Speech-to-text software, which helps those with mobility or hearing challenges by converting spoken words into written text.
  • Closed captioning for videos to assist people who are deaf or hard of hearing.
  • Alternative input devices, like eye-tracking systems or adaptive keyboards, for people with limited motor control.
  • Color contrast options and magnifiers, aiding individuals with low vision.

Why are they important?

Accessibility tools level the playing field by empowering individuals with disabilities to work, communicate, and participate fully in society. They ensure inclusivity, enhance independence, and foster equality by reducing barriers, whether in education, workspaces, entertainment, or daily life.

Let’s take a look at the various tools available in Apple iOS, MacOS, Microsoft, and Android operating systems and applications. These tools are built into the operating system in most cases and have to be activated to be used.

Accessibility tools in iOS and macOS

  • VoiceOver: This tool supports gestures, voice commands, and even Braille displays, allowing users with visual impairments to navigate their devices. VoiceOver also reads contextual information, giving users a more nuanced understanding of their interactions. To learn more about using VoiceOver on iOS and mac OS, check out these articles for the iPhone and Mac computer.
  • Magnifier and Display Accommodations: Whether it’s zooming in on fine print or adjusting colors to cater to light sensitivity, these tools provide more control over how materials are viewed on the screen
  • Sound Recognition: For individuals who are hard of hearing, iOS can listen for specific sounds, like a doorbell or fire alarm, and send alerts.
  • AssistiveTouch: This feature enables on-screen gestures, custom actions, and device control without requiring traditional physical input.

Accessibility tools in Windows

  • Narrator: Narrator is a screen reader tool that continues to evolve with natural-sounding voices, support for new languages, and integration with apps like Microsoft Office.
  • Windows Voice Access: For those who cannot use a keyboard, Windows allows control of the entire device through voice commands. It’s beneficial for users with mobility challenges.
  • Live Captions: Catch every word from any audio in Windows 11. Live Captions automatically transcribes spoken content from any audio, even the microphone. Captioning can be provided for apps and even an in-person conversation.
  • Eye Control: Navigate your PC and apps with your eyes, using Windows 11 eye control and eye-tracking-enabled cameras and a simple launch pad.
  • Focus Assistance: Beyond traditional accessibility, Windows addresses modern challenges like digital distractions. This tool allows users to customize notification settings for better focus.
  • Immersive Reader: Built into Microsoft Edge, reading aids like text spacing, syllable splitting, and line focus are available to support users with dyslexia or ADHD.

Accessibility tools in Android

  • Live Transcribe and Live Caption:  Provide real-time transcription of conversations and captions for media, to assist individuals with hearing impairments.
  • Select to Speak: With a simple tap, users can hear text from the screen read aloud. This is a great feature for users with vision challenges or literacy difficulties.
  • Action Blocks: A unique tool designed for users with cognitive disabilities, Action Blocks allow the creation of customizable shortcuts for frequent actions like calling a loved one or playing a song.

Beyond What’s Built-in

Aside from those built into phones and computers, there are numerous assistive technologies designed to support individuals with disabilities. Here are some examples:

Vision Assistance

  • Screen Readers: Tools like Job Access With Speech (JAWS) and NonVisual Desktop Access (NVDA) convert on-screen text into speech or Braille.
  • Screen Magnification Software: Programs like ZoomText enlarge text and images for users with low vision.
  • OrCam MyEye: A wearable device that reads text aloud and recognizes faces.

Hearing Assistance

  • Hearing Aids with Bluetooth: Devices that connect to smartphones for streaming audio directly.
  • Speech-to-Text Apps: Apps like Ava and Otter.ai transcribe spoken words in real-time.
  • Vibrating Alert Systems: Devices that vibrate to notify users of alarms, doorbells, or phone calls.

Mobility Assistance

  • Adaptive Switches: Devices that allow users with limited mobility to control technology with simple movements.
  • Foot Mouse: Enables users to control a computer using their feet.
  • Wheelchair-Mounted Devices: Tablets or communication boards attached to wheelchairs for easier access.

Cognitive and Learning Assistance

  • Text-to-Speech Software: Tools like Kurzweil 3000 help users with dyslexia or other learning disabilities by reading text aloud.
  • Graphic Organizers: Apps like Inspiration or MindMeister assist with organizing thoughts visually.
  • Reminder and Scheduling Apps: Tools like Google Keep or Todoist help users with memory challenges stay organized.

These tools, combined with the built-in features of operating systems, create a more inclusive environment for individuals of all abilities.

Why Accessibility Tools Matter

Accessibility shouldn’t be an afterthought; it should be by design. It ensures that people of all abilities can participate fully in our digital world. For users with disabilities, these tools aren’t optional; they’re lifelines, facilitating education, communication, and independence.

Moreover, accessibility features often end up benefiting everyone. Think about closed captions in a noisy café or voice commands while driving. By designing for inclusiveness, we create solutions that enhance usability for all.

Looking Ahead

The future of accessibility is exciting, with emerging technologies like artificial intelligence and augmented reality promising even more groundbreaking innovations. However, there’s still work to be done. Collaboration between tech companies, developers, and users will drive progress, ensuring that no one is left behind in this digital age.

Built-in accessibility tools are proof that technology is at its best when it bridges gaps rather than creating them. By exploring and utilizing these features, we can all play a part in building a more inclusive world.

10 May 2024

Broadband Across Missouri StoryMap

by | | 0
Missouri Broadband Focus Group Study participant areas

Recently, the Community Innovation and Action Center at the University of Missouri-St. Louis conducted the Missouri Digital Asset Mapping Focus Group Study. In the study, they hosted 20 focus groups around the state to learn more about the realities of broadband access for Missourians.

To help illustrate their findings, the Center for Applied Research and Engagement Systems created a StoryMap. Explore the StoryMap to read selected quotes from the focus group participants alongside data to demonstrate the barriers and opportunities for reliable high-speed internet in Missouri.

Learn more about the Missouri Digital Asset Mapping Focus Group Study and StoryMap in a recent highlight by MU Extension.

8 Feb 2024

Broadband for All — Let’s Not “Throw Away Our Shot!”

by | | 0

Part 1 – Why the Next Few Months Are Critical

“I am not throwin’ away my shot!” This line, from the musical Hamilton keeps playing in my head as I think about our “once in a generation” opportunity to finally provide everyone in our state high speed internet – broadband.

This is the first of several blogs designed to alert and call on Public Organizations to help make universal access to broadband a reality.  This is particularly true now, as $1.7 billion of federal government funding is about to become available through the Broadband Equity Access and Deployment Act (BEAD) program.

“Public Organizations” include local government, such as county commissions, city councils and boards of aldermen, and school district boards; as well as their partners, chambers of commerce; regional economic development planning commissions and regional councils of government; and civic nonprofits, such as Rotary and Lions Clubs.

While most of the money for broadband infrastructure will be directed to private for-profit internet service providers (ISPs), Local Public Organizations can help ISPs create economically sustainable infrastructure and help communities use this new asset to improve the health, education and economic opportunity, for all residents.

Why Now? Haven’t We Closed the Digital Divide?

As the COVID pandemic set in during 2020, skepticism over whether there was a need for broadband quickly gave way to an understanding that, like electricity and running water, a stable high-speed internet connection provided an essential “utility” for businesses and families. This led to a dramatic increase in promised state and federal  government funding for broadband infrastructure. While some of that government funding has been awarded to ISPs much, much more is only now becoming available.

In late 2021, Congress passed the bipartization “Infrastructure Investment and Jobs Act” (IIJA). That Act authorized over $60 billion of federal funding for broadband access, adoption, and affordability programs. $42.5 billions of that amount is dedicated to broadband access through the Broadband Equity Access and Deployment Act (BEAD) grant program. These laws (and others) have been summarized in several blogs already [here], [here] and [here] When combined with continued support provided by the Federal Communications Commission’s (FCC) RDOF Program and the USDA’s Reconnect Program, the federal government’s promised investment in broadband over the next decade  totals more than $100 billion!

So, “problem solved!” you might think, and certainly this federal funding could go a long way toward providing reliable broadband access to all unserved and underserved locations in Missouri and across the United States. Yet, there is still much more to be done. For example, the nearly $200 million awarded by the State of Missouri during the fiscal year ending June 2023, will provide access to only 8% of Missouri locations that need service.

The largest single federal program enacted in 2021 — BEAD — promises Missouri $1.7 billion of grants to provide reliable and affordable broadband service to every unserved location, and potentially every underserved location in Missouri. However after more than two years, only a small fraction of BEAD funding has been distributed to states.

Although slow, progress, is being made. At the end of last year Missouri’s Office of Broadband Development (OBD) submitted its “Initial Proposal” to the National Telecommunication and Information Agency (NTIA) for approval. The Initial Proposal includes OBD’s processes for identifying projects and distributing BEAD funds. OBD hopes to receive approval of the Initial Proposal by February 18th. Assuming this happens, OBD expects to begin accepting requests for grants this summer and possibly award the first grants this fall.

The timeline depends on NTIA’s approval of the Initial Proposal, and certainly, that timing could “slip.” It is also possible that NTIA may modify some of the details of the Missouri proposal, but the fact remains that after years of waiting, the next few weeks and months likely will determine what locations will receive a share of the BEAD money, and what broadband infrastructure technology will be built over the next five years.

In other words, for communities across the state that lack adequate broadband access, now is the time to become engaged in efforts to finally bridge the digital divide.

What to Expect

The state’s Initial Proposal calls for action to commence immediately following NTIA approval. This will involve two preliminary steps – (1) finalize the locations eligible for BEAD funding and (2) prequalify ISPs that will be eligible to participate in the BEAD proposal and funding process. Following the first two steps, OBD will begin accepting specific proposals for the first of at least two funding rounds. Proposals for round one will ideally be accepted between June 1 – July 31, 2024, with the first awards made by October 2024.

The first round of funding will be designed to favor proposals that connect locations using the fastest and most robust broadband infrastructure — fiber optic cable to the premises (FTTP). The second round of funding will target locations not funded in the first round because they are harder to reach and less economically viable. Other forms of reliable infrastructure, such as cable and wireless connections, likely will be used more for this round of funding. Both funding rounds will be numerically scored, and in each case the amount of BEAD grant funds requested will be a very important, but certainly not the only, factor in determining whether a proposal will be funded.

Identify BEAD Eligible Locations

When NTIA approves the Initial Proposal, OBD will publish its proposed set of eligible BEAD funding locations. Generally funding is available for unserved and underserved locations, determined by the download and upload data speeds, with minimum requirements for latency (the time it takes for a signal to be transmitted and received). This eliminates satellite internet providers. In addition, locations served only by DSL are considered “underserved” regardless of the stated connection speed. Finally, locations already awarded funding under most federal and state programs or otherwise subject to a “binding commitment” to provide broadband service within the next 12 months will not be eligible for BEAD funding.

Last month OBD released its preliminary map of unserved and underserved locations in Missouri. This map, based on the FCC’s FABRIC, is the most comprehensive effort yet to accurately identify locations (homes, businesses and institutions) that should have access to broadband service, locations where ISPs claim to be providing service, and finally the advertised speed of the connection at the location. The preliminary map will be modified by OBD, based on criteria set out in its Initial Proposal (as previously described).

ISPs and Public Organizations will then have at least 45 days to “challenge” the status of a particular location or group of locations based on one of several criteria. These challenges can result in locations being found ineligible for BEAD funding or be reclassified as unserved or underserved. While it is hoped that most of the inaccuracies that plagued earlier FCC maps have been corrected, there likely still will be errors, and this makes participation in the process very important to the overall success of the BEAD program.

ISP Prequalification

Experience has taught OBD the importance of carefully vetting ISPs through a prequalification process before allowing them to submit proposals for BEAD funding. The FCC’s Rural Digital Opportunity Fund (RDOF) Program illustrated the folly of failing to adequately vet participants prior to the competitive bidding process. Many months after preliminary grant recipients were publicly announced, the FCC disqualified two of the largest “winners” of the competitive bidding process because they lacked the technology and/or the financial wherewithal to actually complete the promised projects.

To avoid repeating this result, OBD’s Initial Proposal requires ISPs to prequalify before they can participate in the BEAD funding program. Assuming the Initial Proposal is approved as expected, the Prequalification Process for the first round of BEAD funding is expected to begin on April 17 and close by May 31.

The BEAD Award Process

After establishing eligible funding locations and prequalifying ISPs, OBD will proceed to “round one” of the BEAD awards. During the month of April, OBD will amend its maps to create areas that will be eligible for BEAD funding. These areas will be selected by OBD based on factors such as the location of nearby qualified ISPs and the feasibility of connecting unserved and underserved locations to existing networks.

Approved ISPs will then be able to submit proposals for BEAD funding for any one or combination of these areas, but they must agree to serve every location in the area or areas they have selected. Further, in this first funding round only, proposals that offer FTTP for all locations, will be awarded BEAD funds even if other technologies could provide service at a lower cost, so long as the amount of BEAD funds requested does not exceed a maximum BEAD outlay amount established by OBD.

In the case of multiple proposals for a given area, awards will be based on a numeric scoring matrix, that takes many factors into account. However, three of those factors seem likely to be most relevant. First, the amount of BEAD funds requested (the BEAD Outlay) likely will be very important in determining which ISP receives a BEAD grant. The scoring matrix will favor proposals that request a lower BEAD Outlay. Second, while the BEAD Outlay is important, proposals that offer FTTP rather than other alternate technologies and proposals with shorter deployment times will receive more points. Finally, a substantial number of points will be awarded for proposals that have public support, and this is especially true for proposals where Public Organizations are providing some level of financial support.

What is the Strategy for Public Organizations?

This is a multipart blog, and future articles will focus on specific ways Public Organizations can help make the BEAD program a success in their communities. However, it’s clear Public Organizations can take steps now to set the stage. OBD’s preliminary map enables every community to see each home, business and structure that needs a broadband connection and to identify the ISPs that claim to be able to provide service to that location – and the maximum level of service they can provide.

Local Public Organizations are uniquely able to verify that data because they are a part of the local community. This is especially important because individuals cannot challenge the FCC data or OBD’s map directly. This means that Public Organizations will need to play a critical role in developing challenges to the map when that is necessary. Equally important, local Public Organizations can serve a vital role in assessing, and if necessary, rebutting challenges to the map that are raised by ISPs in the area.

In addition, the data in the preliminary map gives Public Organizations a list of the providers serving each location – both in the community and in surrounding areas. In all likelihood, these ISPs will be making the business decision regarding whether they will participate in BEAD funding, and if so, the specific locations where they will extend service, and the type of technology (fiber, cable or fixed wireless) they will use.

These decisions will not be made in a vacuum. Among other considerations, ISPs will assess the ease of obtaining permits, right of way, and easements to construct the improvements, and the level of customer subscriptions they can expect in the new service area. As will become evident in later blogs, Public Organizations can do much to help and encourage ISPs as the grapple with these issues. However, the first step (and perhaps the most important one), is for Public Organizations in the community to reach out to each local ISP to let them know they are interested in participating and assisting them in the process of developing a BEAD proposal.

*** BEAD offers communities across the state an historic opportunity to finally become connected to the internet in ways that will improve the health, education and economic opportunity for everyone. For our state, this truly is “our shot” .. and we must not throw it away.

16 Jan 2024

The Affordable Connectivity Program May “Go Away” Just When it is Needed Most

by | | 0

They say timing is everything, and that certainly likely will be the case as we move forward this year to implement major components of the 2021 Federal Infrastructure legislation (the Infrastructure Act). You may recall that the Infrastructure Act appropriated $65 billion with the objective of providing every residence, business and institution in the United States a high-speed internet connection – broadband, and the skills to use it. Read more…