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

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.