Study Finds that BEAD May Cost Billions Less than Expected
Eligible BEAD locations may have declined 65 percent in two years.
Cameron Marx

WASHINGTON, June 26, 2025 – Implementing the Broadband, Equity, Access and Deployment program may cost taxpayers billions less than expected, according to one group.
A new analysis from the New York Law School’s Advanced Communications Law and Policy Institute found that the number of locations eligible for BEAD funding may have declined by upwards of 65 percent since June 2023.
According to ACLP estimates, published Wednesday, this would save the government anywhere from $3.2 billion to over $33.5 billion, depending on how costly it is to serve the remaining locations.
FROM SPEEDING BEAD SUMMIT
Panel 1: How Are States Thinking About Reasonable Costs Now?
Panel 2: Finding the State Versus Federal Balance in BEAD
Panel 3: Reacting to the New BEAD NOFO Guidance
Panel 4: Building, Maintaining and Adopting Digital Workforce Skills
Much of the decline in BEAD-eligible locations was attributed to either new deployments by internet service providers or deployment commitments from ISPs, as well as corrections made to BEAD maps. According to the ACLP, directed by Michael J. Santorelli, these commitments and changes resulted in BEAD-eligible locations declining by 59 percent since June 2023.
An additional decrease of as much as 15 percent was attributed by the group to new guidelines from the National Telecommunications and Information Administration making locations served by unlicensed fixed wireless networks with adequate speeds ineligible for funding.
Impact of Rural Digital Opportunity Fund locations?
This decrease was blunted somewhat by widespread defaults on Rural Digital Opportunity Fund locations (which the group estimated would add about 116,331, or 2.5 percent more, eligible locations to the BEAD program).
According to the ACLP, if the average per-location cost to deploy broadband today is the same as the estimated per-location cost in June 2023, the program would come just over $25 billion under budget, a spending reduction of more than half.
This scenario seems unlikely, as the analysis itself noted. “In practice, a reduction in eligible locations does not mean a state will spend a correspondingly lesser amount to achieve 100% broadband availability,” the study said.
Remaining BEAD-eligible locations among most expensive
“Indeed, the remaining BEAD-eligible locations will be among the most expensive to serve. Moreover, broadband deployment costs continue to tick up due to inflation in labor and other inputs. And with a BEAD eligibility map that will probably be much less cohesive than before due to the inclusion of ULFW, some incumbent ISPs might not be able to leverage their economies of scale to drive down project costs in some areas.”
Even if one assumes that the average per-location cost today will be double the estimates from June 2023, the BEAD program would still come $11 billion under budget, according to the ACLP. The group also estimated how much the government would save with different per-location average costs, ranging from $1,500-$12,000 per location.
These are only preliminary estimates, and as the report notes “we caution that these are top-end estimates [regarding the impact of ULFW on the number of eligible BEAD locations] and assume that all ULFW connections in Federal Communications Commission data that report 100 * 20 Mbps or faster speeds would both meet technical requirements and be recognized by states as they work to incorporate them into their location lists. This also assumes that all ULFW providers respond to state notices seeking data.”
Already, a wireless trade group has accused state broadband offices of making it purposefully difficult to disqualify locations receiving service from ULFWs.
The analysis does not include the tens of thousands of RDOF locations that Lumen defaulted on, as the latest FCC data does not include those defaults, according to Santorelli. Santorelli told Broadband Breakfast that “we are planning to update the analysis once that data is added.” In addition, data for West Virginia was unavailable, and was therefore not included in the analysis.
J. Randolph Luening, founder of BroadbandToolkit.com, conducted a separate analysis that showed that the inclusion of ULFWs would decrease the number of BEAD-eligible locations by 12.8 percent, rather than the roughly 15 percent decrease estimated by the ACLP.