Funding
South Carolina and Georgia Release Volume Two of BEAD Initial Proposals
Unlike most states, South Carolina released both volume one and two together.

WASHINGTON, November 8, 2023 – Two more states have released drafts of volume two of their initial proposals for the Broadband Equity, Access and Deployment program.
South Carolina released both volumes one and two on October 30, followed closely by Georgia, which released its volume two on November 1. Volume one details how states will accept challenges to broadband mapping data, while volume two outlines the states process for administering grants under the $42.5 billion program.
The public comment period for draft versions lasts 30 days, with South Carolina accepting comments until November 30, and Georgia’s window closing December 1. A total of 32 states have now released volume two of their proposals for public comment.
States must submit both volumes to the National Telecommunication and Information Administration by December 27, but the agency is approving proposals submitted earlier. Virginia and Louisiana have received approval for their volume ones and are getting their challenge processes underway.
South Carolina
In volume one of its proposal, South Carolina said it plans to adopt the model challenge process set up by the NTIA. That’s the process for ground-truthing broadband data to determine which homes and businesses need coverage.
The state is making optional modifications outlined in the model process. It will designate any area served only by DSL – digital subscriber line – technology as “underserved,” and thus eligible for BEAD funded projects, regardless of what speed the provider advertises. The option was included in the model to phase out copper telephone wires in favor of more future-proof broadband technologies like fiber-optic cable.
It will do the same with fixed wireless broadband, citing bad experiences using fixed wireless service for online learning efforts in 2020.
Eligible entities like nonprofits, local governments, and broadband providers, will be able submit challenges to state broadband data over a 30 day period. The process is ultimately slated to last 90 days, with 30 days each reserved for challenge rebuttals and adjudication.
In its volume two, South Carolina declined to set an extremely high cost threshold, the price at which the state will start to consider non-fiber technologies. Instead, the state’s broadband office is planning to compile a list of locations that are left off its round of grant applications and negotiate directly with providers on getting them service.
The state is also asking the NTIA for a waiver of its letter of credit rules in certain circumstances, such as small projects and companies the state has previously found to be trustworthy. The agency typically requires a 25 percent letter of credit from an accredited bank, which advocates and broadband companies have said could edge out smaller providers.
NTIA released a slate of acceptable alternatives to its letter of credit rule on November 1.
Georgia
Georgia released for public comment volume two of its BEAD initial proposal, a 242-page document detailing its plans for administering grants under the program.
The state will be following the NTIA’s updated letter of credit guidance, letting grant applicants choose performance bonds instead. Those are only paid out if the project fails outright, tying up less grant money than letters of credit.
Like South Carolina, Georgia did not set a high-cost threshold outright, opting to accept a round of grant applications first.
But unlike many other states, Georgia is planning to oversee multiple rounds of funding. BEAD rules give states one year to disburse their entire allocation, which some state broadband offices have flagged as too little time.
The state said in its draft volume two that it plans to use all of its $1.3 billion in getting service to areas its challenge process reveals to be unserved – having less than 25 * 3 Mbps broadband – and underserved – less than 100 * 20 Mbps, with no money left over for non-deployment efforts.
As such, the state is seeking comment on potentially changing its grant application scoring criteria to favor unserved locations, as underserved will generally be less expensive to build to.
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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