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National Broadband Plan: A Look at Chapter 6 and Infrastructure

WASHINGTON, April 23, 2010 – Chapter Six of the National Broadband Plan tackles one of the most basic issues with broadband expansion by focusing on infrastructure. This chapter deals with the physical act of laying cables and erecting antennae.

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Editor’s Note: This is the seventh in a series of articles written by BroadbandBreakfast.com staff summarizing each chapter of the FCC’s National Broadband Plan.

WASHINGTON, April 23, 2010 – Chapter Six of the National Broadband Plan tackles one of the most basic issues with broadband expansion by focusing on infrastructure. This chapter deals with the physical act of laying cables and erecting antennae.

One of the telecommunications’ companies biggest complaints is the very high cost of laying cables on poles, and they say that the wide range in pricing makes it difficult to plan long distance projects.

According to the FCC’s plan, the variability in cost ranges from $7 per foot to as much as $20. Additionally, the prices also vary depending on the type of service provided.

Currently, the price for cable is cheaper than telecom with incumbent local exchanges generally paying the highest price. The difference in price for essentially the same service leads to market inaccuracies and should be rectified, according to the plan. The FCC recommends that it begin rule-making proceedings to help decrease the costs and to ensure that the costs are uniform, based on service.

In order to decrease the costs for expansion, a “make ready” process should be enacted for poles. This make-ready process would allow for poles to be set up in such a manner that new attachments could be added more quickly and simply.

Another issue that the chapter addresses is infrastructure disputes. There currently is a mechanism for dealing with these disputes, but it’s very limited. Under the current system, a utility must respond within 45 days of the initial complaint. However after this is done, there is no limit on the time for the subsequent steps. Some states already have set limits on how quickly utilities must respond, and the plan suggests that a new federal time limit should be put in place.

The plan also describes how the federal government can play a direct role in the assistance of expansion through actions taken by the General Services Administration and the Department of Transportation.

The plan suggests that when Transportation is laying down roads it should also allow fiber providers to lay cables along the trenches it creates. This multiple uses of road trenches already occur in Amsterdam and both Chicago and Akron, Ohio, have begun to do this with success.

To expand wireless access the plan suggests that the GSA should create a “master contract” for the placement of wireless towers. This streamlined process would allow for the expedited installation of wireless towers. The GSA owns buildings in almost every major city, which would allow for a faster expansion.

Rahul Gaitonde has been writing for BroadbandBreakfast.com since the fall of 2009, and in May of 2010 he became Deputy Editor. He was a fellow at George Mason University’s Long Term Governance Project, a researcher at the International Center for Applied Studies in Information Technology and worked at the National Telecommunications and Information Administration. He holds a Masters of Public Policy from George Mason University, where his research focused on the economic and social benefits of broadband expansion. He has written extensively about Universal Service Fund reform, the Broadband Technology Opportunities Program and the Broadband Data Improvement Act

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Alabama’s BEAD Initial Proposal, Volumes One and Two

The state is asking for a waiver to open up RDOF areas to BEAD applications.

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Photo of an Alabama field, used with permission.

Alabama released a draft of its Broadband Equity, Access and Deployment initial proposal on November 14.

It was part of a wave of states and territories that began seeking public comment on their drafts in recent weeks. All 56 have now done so.

After a 30-day comment period, states and territories are required to submit their proposals to the National Telecommunications and Information Administration by December 27. The proposals come in two volumes: volume one details how states will ground-truth broadband coverage data, and volume two outlines states’ plans for administering grant programs with their BEAD funds.

Volume one

The state is planning to adopt the NTIA’s model challenge process to accept and adjudicate claims of incorrect broadband data. The Federal Communications Commission’s largely provider-reported coverage map was used to allocate BEAD money, but is not considered accurate enough to determine which specific locations lack broadband.

Local governments, nonprofits, and broadband providers are able to submit those challenges on behalf of consumers under the model process. 

Alabama is also electing to use one of the NTIA’s optional modifications to the model process. The state’s broadband office will designate all homes and businesses receiving broadband from copper telephone lines as “underserved” – and thus eligible for BEAD-funded infrastructure. The move is an effort to replace older technology with the higher speed fiber-optic cable favored by the program.

The state will administer two optional challenge types the NTIA laid out: area and MDU challenges. States are not required to use these, but most are planning to do so.

An area challenge is initiated if six or more locations in a census block group challenge the same technology from the same provider with sufficient evidence. The provider is then required to show evidence they provide the reported service to every location in the census block group, or the entire area will be opened up to BEAD funds.

An MDU, or multiple dwelling unit, challenge is triggered when three units or 10 percent of the total units in an apartment building challenge a provider’s service. It again flips the burden of proof, requiring providers to prove they give the reported service for the entire building, not just units that submit challenges.

Alabama’s broadband office is requesting a waiver from the NTIA’s rule around enforceable commitments from other funding programs. The state wants areas set to get broadband from the FCC’s Rural Digital Opportunity Fund to be considered unserved for the purposes of BEAD.

That fund, the state argues, has a deployment deadline too far in the future – six to eight years to BEAD’s four years – and is too prone to defaults to be a reliable alternative to BEAD.

Volume two

Alabama does not expect to have any of its $1.4 billion BEAD allocation left over after funding broadband infrastructure.

The state is planning to award that money in a single round of grant applications, but may administer a second, according to its proposal.

Like most states, Alabama won’t be setting a high-cost threshold before looking over all BEAD grant applications. That’s the price point at which the state will look to non-fiber technologies to serve the most expensive, hardest to reach areas.

Alabama’s broadband office is seeking comment on using the NTIA’s updated financing guidance, but plans on implementing it.

That updated guidance allows options which tie up less capital, like performance bonds. BEAD rules initially required a 25 percent letter of credit, which advocates and lawmakers warned could prevent small providers from participating in the program. 

The public comment period for Alabama’s initial proposal is open until December 14.

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Arkansas’s BEAD Initial Proposal, Volume Two

The state is planning to expand its fiber technician training program after funding infrastructure projects.

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Photo of the Arkansas River by Robert Thigpen.

Arkansas released a draft volume two of its Broadband Equity, Access and Deployment initial proposal on November 14.

It was part of a wave of states and territories that began seeking public comment on drafts in recent weeks. All 56 have now done so.

After a 30 day comment period, states and territories are required to submit their proposals to the National Telecommunications and Information Administration by December 27. The proposals come in two volumes: volume one details how states will ground-truth broadband coverage data, and volume two outlines states’ plans for administering grant programs with their BEAD funds.

Arkansas expects its roughly $1 billion BEAD allocation will be enough to serve the estimated 190,000 homes and businesses in the state without adequate internet. 

The state is planning to have at least $20 million left over after funding infrastructure projects. The bulk of that will be used to expand the Arkansas Fiber Academy, a state-run fiber technician training program. The state said in its proposal the expansion will help address a shortage of the skilled workers necessary for deploying fiber-optic cable.  

The Arkansas broadband office will be soliciting two rounds of BEAD grant bids from broadband providers. The first round will be used to identify “Buy It Now” bids, applications that score enough points on the BEAD rubric to be tentatively granted over competing bids, and a minimum point threshold, above which applications will be tentatively granted in the absence of competing bids.

Arkansas will also be using the NTIA’s updated financing guidance, which gives states more options to ensure the financial viability of a project. The new guidance makes room for performance bonds and reimbursement milestones, which tie up less money than the 25 percent letter of credit required by initial BEAD rules.

The agency made the change on November 1 after months of pushback from advocates and lawmakers, who warned small providers could be edged out by the letter of credit.

Like most states, Arkansas will only set a high-cost threshold after both tranches of BEAD applications. That’s the cost of fiber at which the state will start accepting projects using other technologies. The state says it only plans to create such a threshold if it’s necessary to reach all unserved and underserved areas. 

The public comment period for Arkansas’s volume two is open until December 14.

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New Hampshire’s BEAD Initial Proposal, Volumes One and Two

The state expects to get broadband to all its unserved and underserved locations.

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Photo of a church in Eaton, New Hampshire by Peter Lewis.

New Hampshire released a draft of its Broadband Equity, Access and Deployment initial proposal on November 13.

It was part of a wave of states and territories that began seeking public comment on their drafts in recent weeks. All 56 have now done so.

After a 30 day comment period, states and territories are required to submit their proposals to the National Telecommunications and Information Administration by December 27. The proposals come in two volumes: volume one details how states will ground-truth broadband coverage data, and volume two outlines states’ plans for administering grant programs with their BEAD funds.

New Hampshire’s broadband office expects its $196 million in BEAD funds will be enough to get broadband to every home and business in the state. Roughly 36,000 locations still lack reliable internet and are slated to be served by the program, according to the proposal.

Volume one

The state is planning to adopt the NTIA’s model challenge process to accept and adjudicate claims of incorrect broadband data. The Federal Communications Commission’s largely provider-reported coverage map was used to allocate BEAD money, but is not considered accurate enough to determine which specific locations lack broadband.

Local governments, nonprofits, and broadband providers are able to submit those challenges on behalf of consumers under the model process.

New Hampshire is also electing to use one of the NTIA’s optional modifications to the model process. The state’s broadband office will designate all homes and businesses receiving broadband from copper telephone lines as “underserved” – and thus eligible for BEAD-funded infrastructure. The move is an effort to replace older technology with the higher speed fiber-optic cable favored by the program.

New Hampshire will also administer two optional challenge types the NTIA laid out: area and MDU challenges. States are not required to use these, but most are planning to do so.

An area challenge is initiated if six or more locations in a census block group challenge the same technology from the same provider with sufficient evidence. The provider is then required to show evidence they provide the reported service to every location in the census block group, or the entire area will be opened up to BEAD funds.

An MDU, or multiple dwelling unit, challenge is triggered when three units or 10 percent of the total units in an apartment building challenge a provider’s service. It again flips the burden of proof, requiring providers to prove they give the reported service for the entire building, not just units that submit challenges.

Volume two

While New Hampshire is planning to get broadband to all its remaining unserved and underserved locations, the state’s broadband office does not expect to have money left over for non-deployment activities like affordability plans and digital literacy training.

The state is looking to disburse its money in a single funding round. If no providers submit grant applications for a given location in that round, the state intends to negotiate directly with applicants to expand their project areas.

Like most states, New Hampshire won’t be setting a high-cost threshold before looking over all BEAD grant applications. That’s the cost at which the state will start accepting projects using cheaper non-fiber technologies.

The state’s funding may be sufficient to avoid setting such a threshold at all, it said in the proposal.

New Hampshire said its financing requirements may be adjusted by the NTIA’s updated guidance, but did not specify specific parts of the waiver it would use. 

BEAD rules initially required a 25 percent letter of credit, which advocates and lawmakers warned could prevent small providers from participating in the program. The NTIA issued a waiver on November 1 that allows other options which tie up less capital, like performance bonds.

The public comment period for New Hampshire’s volume two is open until December 13.

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