The Benton Institute for Broadband & Society recently looked at BEAD and the goal of getting broadband to all eligible locations. They have some advice for states as they finalize their Initial Proposals on how to ensure ubiquitous coverage:
Solicit interest from potential applicants before requesting applications: Some states like Michigan, Mississippi and North Dakota plan to ask prospective applicants to identify potential project areas of interest before formally opening the application process. One issue is whether service providers will indicate interest for all areas in the state, to preserve their options, thereby obscuring where they are most likely to seek funding.
Work to reduce the number of “unserved” broadband serviceable locations in the state: After the race earlier this year to get locations “added” to the Federal Communications Commission’s National Broadband Map, some states are beginning to realize that was a double-edged sword — because now they have to show NTIA they have a plan to get service to all of those locations. States aren’t allowed to remove those locations in their state-run challenge process: the only way they can get rid of any off-road, off-the-grid structures like hunting cabins in the woods is to challenge those locations at the FCC.
State-defined service areas: A number of states are planning to require applicants to bid on state-determined project areas, such as counties (Georgia), Zip Code Tabulation Areas (Virginia), or Unified School Districts (Kansas), with the expectation that applicants must commit to 100% coverage for the pre-defined project areas. While this approach obviates the need to address overlapping project boundaries, project areas based on governmental boundaries may or may not make sense for project economics. Those with existing plant in much of the pre-defined area presumably would have an inherent advantage in bidding for such areas. Smaller service providers that don’t want to serve the entirety of a larger pre-defined area will have to decide whether it’s worth it to bid on the whole area in order to get funding for the part they actually want to serve. Alternatively, smaller providers could seek partnerships with others interested in portions of the pre-defined area.
Some states like Oklahoma are planning to put their pre-defined project areas (“Network Expansion Territories”) out for public comment before finalizing so service providers can indicate whether the boundaries should be adjusted. Again, one concern is that prospective service providers do not necessarily have incentives to preview their intentions in a public process.
Multiple grant rounds: A number of states intend to solicit multiple rounds of applications, with the hope that successive rounds will elicit support for areas that fail to receive interest in the first round. Oklahoma intends to keep its underserved area awards tentative until the unserved area broadband coverage gap has been fully addressed.
Negotiation with service providers after applications are submitted: States must conduct a competitive grant process, but only one competitive round is required. If, after soliciting proposals, the state receives no proposals to serve particular locations or group of locations that are unserved, underserved, or a combination unserved and underserved, NTIA will allow them to reach out to existing providers and/or other prospective subgrantees to find providers willing to expand their existing or proposed service areas. The question remains, however, whether procurement requirements in some states will permit this sort of ad hoc negotiation.
Alternative technologies: NTIA will allow awards to entities that do not meet its definition of reliable broadband if there are no other options. Even the most pro-fiber states in the country are beginning to realize they can’t slam the door on alternative technologies to fill in the gaps. There’s a common assumption that for some limited subset of locations, satellite may be the answer, but what if satellite does not show up for the party? Will satellite providers like Starlink even apply for BEAD funding in states where they expect they’ll win funding to serve only a small number of locations? Will states be willing — or even legally permitted — to effectively serve as the middleman for a satellite bulk purchasing arrangement to lessen the transaction costs for satellite as an alternative? Would states instead prefer to use BEAD funding to provide vouchers to consumers that reside at locations that receive no bids to defray the cost of satellite installation and monthly service for a period of time?
Because Minnesota’s Office of Broadband Development has been distributing state funds for broadband grants for several years, I think they have already embrace a few of these recommendations, specifically:
- Solicit interest from potential applicants before requesting applications
- Multiple grant rounds
- Negotiation with service providers after applications are submitted
I have questions on the other recommendations:
Work to reduce the number of “unserved” broadband serviceable locations in the state. I think this is a little like saying “I want to lose 10 pounds,” when I really need/hope/expect to lose 20. Is the object to declare success or get ubiquitous coverage? Who’s to say today’s hunting shed won’t turn into tomorrow’s ski lodge? Or perhaps the land is farmed and without access to broadband in the field, precision agriculture becomes more difficult.
State-defined service areas. This may simply be a better approach for states that have not been working on broadband as long as Minnesota has. That being said, provider territories, commonalities of terrain and even community is not always defined by borders. Perhaps combining state-defined areas with negotiation is an approach that would help leverage the promise populated areas to get to lower population density spots.
Alternative technologies. I saw that the FCC recent found that the satellite provider, Starlink, was not eligible for RDOF money. That is telling.