States Report Few Valid Challenges Under BEAD’s Mapping Update
Fears of massive eligibility losses did not materialize
WASHINGTON, July 18, 2025 — A surprise broadband mapping update under the federal Broadband Equity, Access, and Deployment program did not trigger the mass disqualifications some state officials had feared.
A June 6 policy update from the National Telecommunications and Information Administration required states to reevaluate whether areas served by unlicensed fixed wireless providers qualified for BEAD funding. In late June, officials in Texas and Oklahoma warned that the change could disqualify up to 60,000 locations in Texas and more than half of Oklahoma’s eligible locations.
But those projections proved overstated. A Broadband Breakfast survey of officials in six states – including Texas, Oklahoma, Virginia, Maine, North Dakota, and Arkansas – found that most received no valid claims from ULFW providers. Only one of the surveyed states, Texas, removed any locations from its BEAD eligibility map, as a result.
“We had 11 ULFW providers who indicated intent to challenge their locations, but the BDO only received one successful challenge with 429 Broadband Serviceable Locations," Greg Conte, director of the Texas Broadband Development Office, told Broadband Breakfast. “Those locations were removed from eligibility.”
Broadband mapping expert J. Randolph Luening had projected much steeper cuts. In a June analysis, he estimated that 11 states could lose 25 percent or more of their BEAD-eligible locations due to reported ULFW coverage – including nearly 70,000 locations in Texas alone, or about 30 percent of the state’s remaining total unserved and underserved locations.
In Oklahoma, four providers submitted ULFW claims covering 582 locations, but none met the documentation threshold.
“Upon the OBO’s adjudication, no provider submitted location-based documentation which would support the ULFW claim which allowed the OBO to keep all ULFW locations on the BEAD eligible list,” said Edyn Rolls, chief strategic officer at the Oklahoma Broadband Office. “Our office looks forward to continuing the BEAD program, working with NTIA, partnering with providers, and making awards next month.”
Virginia received one challenge notice, but the provider ultimately did not submit evidence.
“We received one notice that an unlicensed fixed wireless provider intended to challenge,” said Chandler Vaughan, associate director in the Virginia Office of Broadband. “That one provider did not submit evidence of serviceability, so we did not have any changes to our eligibility maps on the basis of unlicensed fixed wireless coverage.”
In Maine, one provider initially expressed interest in defending 16 locations but ultimately did not submit documentation.
“As a result, no locations were removed from Maine’s final BEAD Eligible Locations list,” Jenna Ingram, communications manager for the Maine Connectivity Authority, confirmed.
Meanwhile, North Dakota reported receiving no ULFW submissions at all.
“We did not have any ULFW provider submit a claim related to our map,” Brian Newby, broadband program director for the state of North Dakota, told Broadband Breakfast.
And, Arkansas similarly reported, the state “was not impacted by the ULFW challenge process,” according to Arkansas state broadband director Glen Howie.
The limited impact of the surprise mapping challenge, prompted by the Trump administration’s new tech-neutral direction for the program, may be due in part to the short notice states and providers had to respond.
Under the June 6 BEAD restructuring policy notice, states were required to notify ULFW providers of potentially affected areas and give them seven days to respond. Providers then have another seven days to provide evidence they can mitigate interference and meet BEAD service requirements to deliver 100/20 Mbps service reliably for at least four years.
If the state accepted the provider’s documentation, the locations were deemed served and removed from the BEAD eligibility map. However, if the evidence was lacking or never submitted, the areas would remain eligible for funding, as was the case in most states surveyed.
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