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Broadband Providers Should Prepare Now for BEAD Applications

The WISPAPALOOZA panel outlined key BEAD rules for small providers and WISPs to be familiar with.



Photo of the panel by Jake Neenan

LAS VEGAS, October 11, 2023 – Experts urged small broadband providers on Wednesday to start preparing now for BEAD grant applications.

The Biden administration’s $42.5 billion Broadband Equity, Access and Deployment program is still in its early stages. States have until December 27 to submit initial proposals for implementing the program to the National Telecommunications and Information Administration. Only Louisiana has started accepting challenges to broadband map data, the next step in the process.

Even so, providers considering applying for funds should familiarize themselves with BEAD requirements and their state’s proposals, said Lori Adams, Nokia’s vice president of broadband policy and funding strategy.

“Start that process now. Don’t wait until next year, because then it will be too late,” she said here at WISPAPALOOZA, the annual conference of small and fixed wireless broadband providers.

Adams and other panelists highlighted key requirements from the National Telecommunications and Information Administration that potential applicants should familiarize themselves with.

Letter of credit

The NTIA requires that providers awarded BEAD grants obtain a letter of credit from an eligible bank for at least 25 percent of their project costs. 

Banks with a Weiss credit rating of B- or higher are considered eligible. There are some large banks that do not meet this requirement, noted Steve Coran, WISPA’s counsel and an attorney at Lerman Senter.

“The supply of banks is probably lower” than applicants realize, he said.

Letters of credit often require cash collateral, meaning BEAD subgrantees will have to set aside 25% of their project costs. The collateral must be held for the duration of the project, meaning that money can’t be accessed until builds are complete.

The broadband industry has expressed concern about the requirement. The NTIA said on September 22 it is working on updates to the letter of credit rules.

Build America, Buy America

The Build America, Buy America provision of the 2021 Infrastructure Act requires that all federally funded projects allocate 55 percent of their component cost to American suppliers and use equipment manufactured in America.

“That’s a very difficult proposition for some items because we have global supply chains,” Adams said.

The NTIA released in August a draft waiver that would, if adopted, exempt most broadband electronics from the American supplier requirement – including all technology necessary for fixed wireless providers. The four categories not covered by the waiver are used for fiber-optic deployments.

Adams noted applicants planning to deploy fiber cannot circumvent the BABA requirements by absorbing the cost of components themselves and not including them in grant applications.

“If you’re deploying it in the field as part of the program, it has to be BABA compliant,” she said.

Subgrantees will not have to replace existing equipment that would not have complied with the rule.

Matching funds

The NTIA also requires subgrantees to produce matching funds totalling at least 25 percent of BEAD project costs. That can come in the form of cash or in-kind donations, like easements and rights of way from municipalities or donated equipment and labor.<

States are also looking into using unallocated funds from other federal sources like the Capital Projects Fund and the American Rescue Plan Act as sources of matching funds, said Gregory Guice, chief policy officer at lobbying firm Vernonburg Group.

Some of those funds will have different requirements for projects. The CPF has a higher minimum speed requirement than the BEAD program, for example.

Applicants might need to exceed the 25 percent minimum if they are bidding against many other providers, Adams noted.

“You might need as much as 40% to be competitive,” she said.

High cost per location threshold

BEAD rules require states to prioritize fiber infrastructure. But when fiber becomes too expensive, states can consider other technologies like fixed wireless to serve hard-to-reach areas for less money.

States can choose at what price per location they will start looking at non-fiber grant applications. Knowing that threshold for states providers are looking to apply in will be ket for WISPs, the panel said.

The NTIA’s rules currently leave unlicensed fixed wireless out of the definition of adequate broadband. Coran said it’s possible states could ask for waivers. In volume two of Louisiana’s initial proposal, the state said it will seek NTIA approval on allowing funds for fixed wireless service using unlicensed spectrum in some cases.

Reporter Jake Neenan, who covers broadband infrastructure and broadband funding, is a recent graduate of the Columbia Journalism School. Previously, he reported on state prison conditions in New York and Massachusetts. He is also a devoted cat parent.

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Broadband's Impact

Missouri’s BEAD Initial Proposal, Volume Two

The state is unsure if any of its $1.7 billion allocation will be left over after funding new infrastructure.



Photo of the Missouri River by Robert Stinnett.

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.

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Broadband Updates

Alabama’s BEAD Initial Proposal, Volumes One and Two

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



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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Broadband Mapping & Data

Connect20 Summit: Data-Driven Approach Needed for Digital Navigation

The NTIA’s Internet Use Survey doesn’t delve deeply enough into why people choose not to adopt broadband.



WASHINGTON, November 20, 2023 – Better data about broadband adoption is necessary to closing the digital divide in the U.S., a broadband expert said during a panel at the Connect20 Summit here.

Speaking on a panel about “The Power of Navigation Services,” the expert, Jessica Dine of the Information Technology and Innovation Foundation, said states lack comprehensive data on why some residents remain offline. This information is essential for digital navigator programs to succeed, she said.

She highlighted the need for standardized national metrics on digital literacy and inclusion, and said that federal surveys – including the Census Bureau’s American Community Survey – provide insights on barriers to technology adoption. But more granular data is required.

She also said that the National Telecommunications and Information Administration’s Internet Use Survey doesn’t delve deeply enough into why people choose not to adopt the internet. For instance, understanding the nuances behind the ‘not interested’ response category could unveil targeted intervention strategies.

In particular, Dine praised Louisiana and Delaware for surveying communities on their connectivity needs, including overlaying socio-economic indicators with broadband deployment data. But she said more work is required to quantify the precise challenges different populations face.

Other panelists at the session, including Michelle Thornton of the State University of New York at Oswego, emphasized the importance of tracking on-the-ground efforts by navigators themselves.

Bringing in her experience from the field of healthcare navigation, Thornton underscored the value of tracking navigator activities and outcomes. She suggested a collaborative model where state-level data collection is supplemented by detailed, community-level insights from digital navigators.

The panel was part of the Connect20 Summit held in Washington and organized by Network On, the National Digital Inclusion Alliance, and Broadband Breakfast.

The session was moderated by Comcast’s Kate Allison, executive director of research and digital equity at Comcast.

To stay involved with the Digital Navigator movement, sign up at the Connect20 Summit.

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