Important Steps to Follow New NTIA BEAD Guidance

The NTIA's June 6 BEAD Restructuring Policy Notice has given state broadband offices a Sisyphean task. We've all been up this mountain already, but below we try to provide a few quick tips to get the boulder moving before your 90 days are up!

Revisions to Eligibility Lists

Final Proposal Guidance v1.2 allows Eligible Entities to identify locations that should not be funded due to existing services or errors in the CostQuest fabric (rocks, barns, enterprise customers and the like).

The new notice is not terribly clear on how the NTIA will be verifying that this work is complete, but explicitly states, the "NTIA will validate that these reason codes have been exercised when reviewing Final Proposals"

This suggests that the NTIA will be using the newest version of the fabric to remove locations no longer in the fabric and locations with active service records at 100/20 or better from eligibility.

The NTIA now requires that Eligible Entities undertake this exercise, and there's little time to do it.

To get started:

Identify eligible broadband serviceable locations (BSLs) that do not require service
Identify all locations that are no longer in the fabric and apply reason code 3. You may have already done this, but remember, version 7 of the fabric will be out sometime near the end of June and could significantly impact the number of locations being bid on in the new round of subgrantee selection. It’s also worth checking if there are any locations that were moved to a new location id.
Update funding information (pending NTIA updates for program defaults by 6/20)
Remove locations currently served in the fabric
a. Identify eligible locations with unlicensed fixed wireless service and provide a public notice to all providers asking for evidence of service and mitigation of key service issues (Appendix A). This number can be significant (20-30% in larger midwestern and western states) and may require time to adjudicate, so start this process now.
b. If you haven’t yet, give providers who report serving eligible locations with fiber, cable, or LFW the chance to prove they really do serve those locations. We suggest you do this in parallel with the above.
c. For both tasks, be EXTREMELY EXPLICIT about the type and format of evidence you require – we recommend spatial datasets (service lines, subscriber counts, and/or speed tests). Eligible Entities will have to review this data very quickly!

Sanborn’s automated MBSL analysis across seven states identified an average of 16.3% of BEAD eligible BSLs as not requiring funding (a total of nearly 170,000 locations that, at a subsidy of $6,000 per BSL, would save over $1 billion.

Subgrantee Selection

The restructuring notice also renders all final proposal approvals and preliminary or provisional subgrantee selections moot, so states will have to resdesign and rerun their subgrantee selection process. States can work on pre-qualification and the revision of questions and scoring criteria while they are revising their eligibility list but will need a revised eligibility list to start subgrantee selection. The ONLY accepted primary scoring criteria is now cost, but states may create additional scoring criteria that will be applied when a second application is within 15% of the cost.

Given the time frame, it is more important than ever to rely on automated processing and evaluation of applications. Optimally, you should be able to run a single process to:

Create data pipelines that calculate cost, subsidy, and match per location based on application submissions and new application lists
Identify applications with minimal BEAD outlay and any cases where additional applications are within 15% of the lowest cost application and apply secondary scoring criteria
Develop preliminary awarded locations lists for review with subgrantees along with nearby unawarded locations for potential negotiations
Output draft fp_locations.csv, fp_no_bead_locations.csv, fp_deployment_projects.csv, fp_cai.csv

The final versions of these tables will need to be revised after negotiations, but you’ll save hours, if not days, building a process that develops these datasets concurrently.

Final Proposal

Once you’re ready to give the boulder one last push, compile all the final proposal documentation (using the same automated process as before where possible!). The timeline for this process is remarkably tight and the number of moving pieces makes it difficult to chart a direct path forward. Sanborn is happy to help states talk through their options for getting through Tarturus as quickly as possible.