Funding
BEAD Director Says NTIA is Working on Changes to Letter of Credit
Evan Feinman, speaking at the BEAD Implementation Summit, said the agency will also issue guidance on project auditing.

WASHINGTON, September 22, 2023 – The National Telecommunications and Information Administration is working on changes to the letter of credit requirements for its flagship broadband grant program, according to the program’s director Evan Feinman.
The letter of credit requirement in the $42.5 billion Broadband Equity, Access and Deployment program requires providers receiving grants to expand infrastructure to obtain a letter of credit from a bank for 25 percent of the project cost.
That means awardees will have to back the letters with cash, which many in the broadband industry have said will push small and community providers out of BEAD projects.
Feinman said the letter of credit requirement accomplishes two goals for the NTIA: it promises some recovery if a project fails, and offers a chance for third-party financial analysis of projects.
“What we did not do was offer a menu of options to do that. We are hard at work on that now,” he said. “You’re going to hear more from us about the letter of credit requirement in the relatively near future.”
The discussion was part of a question and answer session with the broadband community at the Broadband Breakfast BEAD Implementation Summit on Thursday.
The summit also featured state broadband leaders, other federal grant program officials, investors, and service providers in conversations about key focuses as states work to allocate and deploy BEAD funds.
When asked about a provision in the program allowing for internet service providers accepting grant money to conduct self-audits, Feinman said the NTIA, the agency responsible for administering the program, will be issuing more guidance to states on how to monitor BEAD projects.
That guidance will not be created in the next three months, though.
“We have deep financial resources in the bank, but our human capital is not as thick as you might like,” he said. “We got to do initial proposals,” he added, referencing grant procedures which states will be submitting to the agency until December 27.
A new model for broadband expansion
Feinman repeatedly drew comparisons to the effort to bring electricity to rural America in the 1930s, but said that BEAD is different from other federal grant programs.
“This is not a normal grants program. This is in fact, not a grants program at all,” he said. “This is a universal coverage broadband infrastructure program. The tools that are being used to get there are grants.”
He said the program is a departure from previous broadband funding efforts because so much of its goal – universal broadband coverage in the U.S. – hinges on working partnerships, both between federal and state officials and between local governments, providers, co-operatives, and communities. That’s because of the complexity of the task and the sheer number of people who need to understand that task to accomplish it.
“This room, we have our hands on the pen. We are writing the next chapter of the great American infrastructure story,” he said at the event. “But this is going to require a true whole-of-society effort.”
If you missed the BEAD Implementation Summit, sign up for Broadband Breakfast’s BEAD Starter Pack for $35/month (cancel anytime). You’ll get access to all the videos and each of the three Breakfast Club reports prepared for the BEAD Implementation Summit:
- July 2023 – A Deep Dive into Allocations Under the Broadband Equity, Access and Deployment Program
- August 2023 – Precursors to BEAD Implementation: A Deep Dive Into Prior Broadband Programs
- September 2023 – A Deep Dive into the BEAD Program’s Matching Funds
Already a Broadband Breakfast Club member? Watch the videos!
Funding
House Democrat Introduces Bill to Add Local Parks to E-Rate Program
The Technology in the Parks Act would also put parks in line for used computers and equipment from federal agencies.

WASHINGTON, December 1, 2023 – A House Democrat announced on Friday a bill that would fund broadband internet and devices for public parks.
The Technology in the Parks Act would expand the Federal Communications Commission’s E-Rate program to include local parks. That program currently provides approximately $4 billion in yearly broadband subsidies for schools and libraries through the FCC’s Universal Service Fund. Adding public parks would allow them to request government money toward the cost of internet each month.
The move is “crucial to bringing broadband access to these community spaces,” said the bill’s sponsor, Rep. Danny Davis, D-Illinois, in a statement.
In an effort to provide devices on the subsidized connection, the bill would also put parks in the U.S. General Services Administration’s Computers for Learning program. That would give parks access to computer equipment no longer being used by federal agencies.
The bill would also tap the Department of Labor to implement a grant program for “technology training programs” in local parks.
Similar programs aimed at helping people navigate and participate in online spaces are drawing funds from other federal agencies. The Commerce Department’s $42.5 billion broadband expansion program makes room for states to fund digital literacy trainings, and its $2.75 billion Digital Equity Act programs are targeted at such efforts.
Funding
North Carolina Releases Final Guidance on $100 Million Pole Replacement Program
Providers may receive up to $10,000 for each utility pole they replace in unserved areas.

WASHINGTON, November 27, 2023 – North Carolina’s broadband office released on Monday final guidance for its $100 million pole replacement program.
The program, funded by the American Rescue Plan Act, will reimburse broadband providers for utility pole replacement costs. Expanding networks can involve attaching equipment to those utility poles. When a pole needs to be replaced to accommodate more equipment, pole owners typically pass the cost on to attachers.
Telecommunications companies have cited this extra cost as a barrier to quick broadband deployments, something utility companies dispute. The two industries have been in conflict on the issue for years, with both continuing to push the FCC to weigh in on a cost sharing regime.
North Carolina’s plan is an effort to smooth over the issue for future broadband expansion efforts, Nate Denny, the state department of information technology’s deputy secretary for broadband and digital equity, said in a statement.
“It addresses a significant barrier to closing the digital divide in remote parts of our state,” he said.
Under the program, broadband providers can apply for 50 percent of the replacement cost for each pole replaced, up to $10,000 per pole. Pole replacement costs in unserved areas after June 1, 2021 are eligible for reimbursement.
The program will kick off in February 2024 and accept applications from qualified providers.
The FCC has authority in 26 states over the terms of agreements between investor-owned utilities and telecom companies, which does not include publicly owned utilities or broadband providers that solely provide internet. The agency is set to vote on updated pole attachment rules at its December meeting.
Expert Opinion
Kate Forscey: National Security and Global Success Depend Upon Prioritizing Telecom Funding
The Affordable Connectivity Program and the Rip-and-Replace program are both central funding needs for the industry.

With the government now funded into the new year, it’s time for Congress to take another look at its broader priorities, especially when it comes to the race with China for dominance in next-generation technologies. Whether it’s AI or cloud computing or virtual reality, if the United States is to remain competitive, we need to make secure and effective communications a priority. This means finally connecting all Americans to high-speed broadband and ensuring that our connectivity cannot be undermined by foreign adversaries.
Two popular programs are central to this goal: the Affordable Connectivity Program and the Rip-and-Replace program. Both of these programs have tremendous bipartisan, bicameral support; but both have been underfunded and now risk dying on the vine. Congress has the opportunity to fully fund these programs if it has the will to do so.
Let’s break it down.
The Affordable Connectivity Program provides low-income American families and veterans with discounts on Internet service and connectivity equipment, including higher discounts for those living on Tribal lands. With affordable broadband, more Americans can get online and be a part of the digital economy.
The ACP has been wildly successful, connecting over 21 million households to essential broadband they could otherwise not afford. And it continues to garner widespread support, with the vast majority of voters (78%) calling for its extension, including 64% of Republicans, 70% of Independents, and 95% of Democrats.
Congress provided the ACP with $14.2 billion in 2021—but funding is now running low and is projected to be fully exhausted by spring 2024. Governors, lawmakers on both sides of the aisle, public interest groups, and Internet service providers are all raising the alarm about its imminent depletion. That’s why the Biden Administration in October called on Congress to replenish the program’s coffers with an additional $6 billion.
A good start, but not the whole story. Our foreign adversaries are well known for their espionage, and while a spy balloon might get the attention, a far more insidious problem lurks in our communications networks: equipment designed and produced by Chinese suppliers Huawei and ZTE. A bipartisan Congress passed the Secure and Trusted Networks Act to eradicate national security threats such as these, but sufficient funding for the Rip and Replace program has never materialized.
Again, the Biden Administration has stepped up and identified a need for $3.1 billion to fully fund the program as a “key national security priority” in its emergency supplemental funding request. It’s a narrative we can all get on-board with: that broadband falls under the umbrella of national security as a whole. American consumers and institutions both benefit from American-built networks and increased protection at home. But communications providers can’t live up to these needs on their own.
As it stands, the responsibility to get affordable, secure connectivity programs across the finish line rests with Congress. Even with a consensus of support for these two programs, the devil is in the details of how to make the price tags palatable to enough policymakers on Capitol Hill. The key is ensuring that any changes preserve the widespread efficacy of the program that has made it popular so far.
For example, Congress could cut the cost of the ACP by limiting the additional Tribal funding to rural Tribal lands. Any such change should be grounded in an evaluation of existing need in urban areas, but could be an opportunity to ensure funds are being directed to areas of greatest need. And Congress should consider indexing the ACP to inflation. The high inflation of recent years has wreaked havoc on the budgets of consumers—and inflation-proofing the program would ensure that broadband remains affordable for all Americans even should inflation come back.
As for Rip-and-Replace, those of us urging for more funds could concede putting safeguards in place to ensure the money is being used for its intended purpose – the kind of compromise needed to get such policies across the finish line
These are just some ideas as we head into the final funding fight. Not everyone is going to be on the same page on what is and isn’t working best, but shared success starts by recognizing that we all have the same endgame. Congress must ensure that adequate funding for the ACP and Rip and Replace program are included in any year-end spending package. We have an all-too-rare opportunity to win the race for high-tech dominance—we just need to provide the resources.
Kate Forscey is a contributing fellow for the Digital Progress Institute and principal and founder of KRF Strategies LLC. She has served as senior technology policy advisor for Congresswoman Anna G. Eshoo and policy counsel at Public Knowledge. This piece is exclusive to Broadband Breakfast.
Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.
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