Florida released a draft volume two of its Broadband Equity, Access and Deployment initial proposal on November 22.

It was the last in a wave of states and territories that began seeking public comment on their drafts in recent weeks, an effort to close the mandatory 30-day public comment period before the December 27 submission deadline. All 56 have now done so.

States will submit their proposals to the National Telecommunications and Information Administration, the agency tapped to oversee the program. 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.

The state released a draft volume one of its proposal on November 15.

Florida estimates it will have $200 million of its $1.16 billion BEAD allocation remaining after funding infrastructure projects. The state is planning to start awarding that money to workforce development projects at the same time as infrastructure builds.

Without an effort to train and hire more people, Florida’s proposal said, there will not be enough workers in the state with the necessary skills to complete those projects. The telecommunications industry as a whole is facing a workforce shortage, and Florida is planning to fund training and outreach efforts to address the shortfall.

The state said it may be requesting a waiver from the NTIA to make some Federal Communications Commission subsidy areas open to BEAD funds, citing “growing local and national concern over the economic viability of some RDOF awards coming to fruition.” Alabama has requested such a waiver.

The FCC’s Rural Digital Opportunity Fund awarded over $9 billion to expand broadband networks to unserved areas in 2020, over $2.8 billion of which has since gone into default.

Florida’s broadband office “reserves the option,” according to its volume two, to use the NTIA’s updated financing guidelines. Those updated guidelines allow for changes that tie up less cash than the original BEAD requirement, a 25 percent letter of credit from an accredited bank.

The public comment period for Florida’s volume two is open until December 22.

Massachusetts 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, an effort to close the mandatory 30-day public comment period before the December 27 submission deadline. All 56 have now done so.

States will submit their proposals to the National Telecommunications and Information Administration, the agency tapped to oversee the program. 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. 

The state is electing to accept speed tests as evidence in those challenges, provided they meet certain methodological requirements.

Massachusetts 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 have outlined plans to do so in their initial proposals.

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 being challenged.

Volume two

Massachusetts is planning to fund “non-deployment” projects immediately after approval of its initial proposal, rather than waiting to award infrastructure grants like most states. That’s because the state’s broadband office is “confident  that the remaining coverage gaps for mass market residential and commercial service can be closed” with its $147 million in BEAD funding.

In fact, thanks to the state’s Gap Networks program, funded by the Treasury Department’s Capital Projects Fund, there may be “few or no” BEAD-eligible locations remaining by the time subgrantee selection begins, according to the initial proposal. If necessary, Massachusetts is planning up to three rounds of funding to secure projects in eligible areas.

Non-deployment projects are those that aim to address gaps in broadband adoption in ways other than building new infrastructure, like efforts to increase affordability or improve digital literacy.

Among those projects the state is planning are state-run alternatives to the Affordable Connectivity Program, the $14 billion broadband subsidy for low-income households set to dry up in April 2024, and expanding a local partnership program that provides a variety of digital literacy and education services to more areas of the state.

For the deployment projects it does fund with BEAD, Massachusetts will be using the NTIA’s updated financing guidance, which gives states more options to ensure the financial viability of a project. Issued on November 1, the new guidance makes room for performance bonds and reimbursement milestones. Those tie up less cash than the original requirement, a letter of credit for 25 percent of the project cost.

The agency made the change after months of pushback from advocates and lawmakers, who warned small providers could be edged out by the original rules. 

The public comment period for Massachusetts’s BEAD initial proposal is open until December 15.

Missouri released a draft volume two of its Broadband Equity, Access and Deployment initial proposal on November 15.

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.

The Missouri Broadband Office is “not yet able to determine” whether it will have any of its $1.7 billion in BEAD money left over after funding infrastructure projects.

The state is planning to administer two rounds of funding, something the state’s broadband director BJ Tanksley has flagged as being potentially difficult given BEAD’s one year timeframe for grant awards. The MBO said in the proposal a “sub-round” might be necessary if some undeserved and underserved areas receive no applications, and the state might seek an extension from the NTIA.

Missouri is looking to release multiple “advisory figures” for its high-cost threshold, the price at which fiber becomes expensive enough for the state to consider other technologies not favored by BEAD. Cost modeling data will be used for an initial figure before the first round of grant applications, and the number will be updated based on the applications the state receives in each round.

The state 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.

The public comment period for Missouri’s volume two is open until December 15.