I finally took a deep dive into the Draft of Minnesota’s Final Proposal. It is a series of answers to very specific questions that help NTIA decide whether Minnesota (Office of Broadband Development (OBD) and subgrantees) will be able to adhere to the application requirements – despite changes made to the original requirements. OBD has been distributing finds for many years. In some ways, I’m sure that made it easier for them to create a proposal compared to other states.  In some ways, the requirements do not assume the experience and expertise of local team, especially in understanding the needs and expectations of residents, communities and providers and that had to be frustrating. Below, I’ve selected lines in the proposals that jumped out for me. (I have also highlighted these sections in a PDF of the full draft proposal.

The attachments from the proposal were more interesting in terms of what we could see on the ground here once the application is approved. I’ve look at this further below.

Comments on the changes made to comply with NTIA’.., (Just a helpful reminder of what the proposal needed to address.)

• The NTIA’s Benefit of the Bargain grant application round took a technology neutral approach and prioritized the lowest cost technology. Minnesota conducted a technology neutral, transparent, and competitive Benefit of the Bargain grant application round that minimized BEAD outlay while prioritizing the lowest cost technology.
• 14 applicants submitted letters of interest including three new applicants.
• Minnesota only completed one round of subgrantee selection prior to the restructuring of the program which was focused on fiber projects only but estimates the restructured round lowered costs per BSL by at least $2,000 per BSL. Additionally, all awards included a 10% contingency to ensure all projects can complete should any barriers or delays occur. Reimbursement payment will be based on actual costs incurred and match requirements must meet a minimum 25% requirement (unless a match waiver is in place) or the amount proposed in its application if higher.

Info on Priority Broadband Projects… (Helpful again to get a reminder of definitions and see the impact of changes.)

• OBD applied the BEAD June 6 Restructuring Policy Notice definition of Priority Broadband Project: one that provides broadband service at speeds of no less than 100 megabits per second for downloads and 20 megabits per second for uploads, has a latency less than or equal to 100 milliseconds, and can easily scale speeds over time to meet the evolving connectivity needs of households and businesses and support the deployment of 5G, successor wireless technologies, and other advanced services. The above applied was in accordance with the Infrastructure Investment and Jobs Act and the BEAD Restructuring Policy Notice. This definition required Minnesota to embrace technology neutrality and fully realize the benefit of the bargain.
• In partnership with its engineering consultants, OBD applied a principled evaluation process— assessing applications on speed, latency, and scalability—to certify the Restructured BEAD Round supports current and future connectivity needs of Minnesotans.
  As a result of the Restructured BEAD Round, Minnesota benefited from:
  • Over $200 million reduction in original estimated deployment costs
  • All Minnesota BSLs served using all available technologies and recommended awards including fiber-optic, LEO satellite services, hybrid fiber-coaxial, and terrestrial fixed wireless technology.
  • Projects with capacity to meet today’s demand challenges as well as easily scale for future needs of residents, thriving businesses and tourism.
  • Technology-neutral solutions that perform at the required speeds across diverse terrain, including dense tree coverage, undulating slopes, and varying altitudes, to meet unique needs of each BSL.

On Scalability… (Shows OBD’s experiential learning with 10+ years of distributing funds.)

• Minnesota’s technical review team also took into consideration the applicant’s track record of meeting comparable levels of demand relative to the number of BSLs applied to. If a direct example could not be reviewed, OBD looked for examples of the applicants scaling their technology at the required pace.
  Finally, if the performance history did not have an example of the level of scale needed for the BEAD program, Minnesota considered if future scalability would depend on emerging technologies. Emerging technology could require additional regulatory approvals, such as zoning, spectrum, or orbital clearances, which may introduce uncertainty. Additionally, technologies with shorter operational lifespans may pose replacement risks that could impact long-term reliability and cost-effectiveness.

On reliability… (Explains to folks in other states some of the challenges unique to MN.)

• Additionally, Minnesota evaluated reliability of projects to apply the Priority Broadband Project definition based on the geography. Minnesota’s project areas span from bluffs and hills to farmland to glacier formed topography. Minnesota is also home to 60 dense state forest lands and two national forests with over 14.7 billion trees on 18 million acres of forest in eligible areas. These areas represent over 35% of the state.
  Through the Minnesota Office of Broadband Development’s over 12 years of experience in broadband infrastructure projects, past grant-funded implementations revealed that tree canopy, rugged terrain, and slope can complicate installation and/or obstruct line-of-sight (LOS) paths. Broadband technologies with obstructed line-of-sight, specifically wireless and LEO technologies, can have signal degradation, increased latency, and reduced reliability.
  To apply a Priority Broadband Project definition from a reliability perspective, OBD looked at topography by evaluating the change in elevation between neighboring areas (i.e., calculated an average slope). A higher average slope indicates that there are various changes of terrain impacting technologies needing line-of-sight. Average slope was calculated using elevation models from the US Geological Survey averaged per application area. Specifically, OBD applied analysis of average slope when reviewing wireless projects given past experience with State projects where varying slope impacted line-of-sight and service levels.
  Besides elevation change, other common line-of-sight barriers are trees. Given approximately 63% of Minnesota is forest, and applications referenced tree canopy coverage, OBD factored tree canopy coverage in the Priority Broadband Project application and reliability of wireless and LEO proposed projects. Tree canopy impacts the deployment of broadband technology requiring direct line-of-sight. LEO performance is more reliable with an unobstructed sky view, while fixed wireless signals degrade when traveling through vegetation. As discovered through OBD’s
  For over 12 years of experience in broadband infrastructure projects, past infrastructure projects using state grant funds have struggled due to these line-of- sight limitations.

As I mentioned above, the attachments were even more interesting:

• Draft BEAD Program Monitoring Plan Summary (PDF)
• Attachment 1 – Final Proposal Subgrantees (CSV)
• Attachment 2 – Final Proposal Deployment Projects* (XLSX)
• Attachment 3 – Final Proposal Locations* (CSV)
• Attachment 4 – Final Proposal No BEAD Locations (CSV)
• Attachment 14.1 EHP PEIS Memo Minnesota (PDF)
• Attachment 14.1 EHP Requirements (PDF)

In recent presentations, OBD had given some very high, interesting stats:

I’ve pulled out a few details from the spreadsheets on the providers and projects to dive on layer down. It sounds like information will be available by county soon.