Beyond Mapping: What’s Next For Your State Broadband Office?

Mapping is the first step in your 1,000-step journey to deploy BEAD. Here’s a look ahead to what comes next

The $42.45 billion federal Broadband Equity, Access, and Deployment (BEAD) Program administered by the National Telecommunications and Information Administration (NTIA) is providing states, U.S. territories, and Native American tribes with unprecedented levels of broadband funding. (Note: state/territory/tribe will be used interchangeably from here on in this article).  

However, as state broadband offices move to accept the funds and deploy them, many have been left dwelling on the first task: mapping the current state of broadband connectivity throughout their borders.

It’s an important step, of course, as it will serve as the basis for all others to come, showing which areas and specific locations are unserved or underserved by broadband and should thus be eligible for funding.

But this is but one step among thousands states must complete to turn their federal (and state matching) dollars into actual, blazing fast broadband service needed to keep Americans connected in the modern world.

What’s next for your state’s broadband office? This piece frames the series ahead, and the state’s next set of challenges, and shows how Ready.net’s Broadband tools can help your state broadband office. 

Create an Initial Proposal and Final Proposal

No, this isn’t the “Request for Initial Planning Funds” your state submitted back in August 2022. The  “Initial Proposal” document is a distinct beast of its own, and is required to include a description of the “the competitive process” your state will “use to select subgrantees to construct broadband projects,” e.g. how is your state actually determining who gets the money, where it’s going, what it will be used for, and who it will help.

Before you send this document  to the the NTIA, your state broadband office must allow the public the opportunity to comment and include a record of the feedback in the submitted document.

The good news is that this document isn’t due until 180 days after your state received notice of how much money the NTIA planned to award you.

One year after the NTIA approves your state’s Initial Proposal, your office will need to submit a Final Proposal through the NTIA Grants Portal at “grants.ntia.gov.” The Final Proposal must include a detailed plan for allocating grant funds throughout your state to unserved and underserved locations, as well as a timeline for the start, various in-progress phases, and completion of each project.

Your state must also provide a description of the processes for oversight and accountability to ensure proper use of the grant funds, a certification of coordination with Tribal Governments, local community organizations, and unions and worker organizationsIt must also include a description of the results of the challenge process.

The Final Proposal should also include a description of how your state broadband office is getting the participation of non-traditional broadband providers. In addition, be sure it contains the implementation status of plans related to streamlined permitting processes and cost-effective access, labor and workforce activities, utilization of minority businesses and labor surplus area firms, low-cost plan requirements. Further, it needs to address how the projects are taking into account climate change and resilience.

The NTIA will provide technical assistance to states throughout to ensure their Final Proposals meet all requirements and goals of the program.

The Final Proposal must follow a standardized format in legible font on 8 ½ by 11” paper. Figures, graphs, images, and pictures may be presented in landscape orientation and should be of a size that is easily readable or viewable.

Launch, Manage, and Document Your State’s Broadband Challenge Process

Ok, so your state has been awarded some BEAD funding (at least its allocated minimum of 20%) — congratulations! And hopefully, more is on the way.

Now your state office will need to conduct and run your own transparent challenge process to allow members of the public, internet service providers (ISPs) and other organizations the chance to challenge the state’s maps and proposed funding allocations.

Specifically, state broadband offices must:

• Design a challenge process and get it approved by the NTIA. This was actually a necessary component of applying for funding beyond the minimum allocation, so state offices should have already taken care of this one. 
• Run the challenge for the public in their state, ensuring that it is (in the NTIA’s words) “transparent, evidence-based, and expeditious,”. This means opening up the state broadband Fabric and service maps to be challenged. Using a tool like Ready.net’s Challenge Process Coordinator can help. 
• Evaluate challenges and approve or disapprove of them based on the data provided by the challengers. 
• Then, the state broadband office/team “must notify NTIA of any modifications” to its initial funding proposal/challenge process proposal submitted earlier to qualify for funding awards, such as those “that are necessitated by successful challenges to its initial determinations.” Yet, the NTIA also reserves its own right to reject or confirm challenges. 
• Notify the NTIA of any changes in the state’s funding allocation plan at least 60 days prior to issuing the funding awards to subgrantees, including “the final classification of each unserved location, underserved location, or eligible community anchor institution within the jurisdiction” of the state/entity.

Sounds like a lot — and it is. Fortunately, states have an easy one-stop-shop to turn to: the Challenge Process Coordinator from Ready.net. Learn more about that here. 

Next Up: Handling Your State’s Subgrantee Applications

How is your state deciding where to allocate its BEAD funding and other sources of broadband funding (Capital Projects Fund, state matching grants, etc)?

Following the NTIA’s and Federal Communications Commission’s provisions that the initial 20% of the funding be distributed to areas “consisting of at least 80% unserved locations” and are “in  location in which the percentage of individuals with a household income at or below 150% of the poverty line applicable to a family of the size involved.”

After that, it’s up to the states to decide which “subgrantees,” or grant recipients, get the funds, but the process the state uses to award the money must be “fair, open, and competitive” according to the NTIA and clear to applications. Also, the state broadband office must describe their process in their initial proposal and final proposal documents sent to the NTIA. And, the grant award process must abide by a long list of NTIA-established principles see on pages 46-48 of this document.

The grant process may also be awarded to middle mile infrastructure projects to reach interconnection points and ensure technical feasibility and financial sustainability.

States can accept grant applications from companies aiming to serve unserved and underserved locations collectively or separately, but they must prioritize unserved areas and ensure their coverage in the final plan. Non-traditional providers such as cooperatives, nonprofits, and private companies may apply as subgrantees, and audited financial statements of publicly traded parent companies are acceptable. State broadband offices must evaluate grant applicants’ compliance with fair labor practices.

Using Ready.net’s Grant Application Management Engine, states can deploy enterprise BOSS (business support systems/operating support systems) tools to help states manage their relationship with grant-seeking applicants directly through a simple, clean, powerful, easy-to-use web app.

Create and Submit Your State’s Five-Year-Plan

According to the NTIA, the state broadband office must submit a “five-year-action plan” within 270 days of receiving its initial planning funds — less than one year. This five-year-plan must include:

• Details of the state’s existing broadband program or office
• Additional funding sources for broadband deployment.
• Existing broadband deployment efforts funded by the federal government 
• Identification of employees who will assist in implementing and administering the BEAD funds in the state
• What the state determines to be obstacles or barriers to the successful implementation of the BEAD Program.
• Asset inventory that catalogs broadband adoption, affordability, equity, access, and deployment activities in the plan.
• Incorporate available federal, state, or local broadband availability and adoption data 
• Local and regional broadband service needs and gaps
• Explain how the entire state will be able to get reliable, affordable, high-speed internet service by the end of the five years

Don’t Forget Your Reporting Requirements and Compliance!

As your state moves through the BEAD Program, your state broadband office will need to provide the NTIA with regular reports and updates on progress, making sure the state, subgrantees and everyone they're working with is following the rules and requirements. See pages 53-55 of this document for more in-depth reporting information from the NTIA.

Within 90 days of receiving BEAD grant funds, state broadband offices must submit an initial report to the NTIA’s Assistant Secretary that describes the planned and actual use of funds, the planned and actual subgrant process, the establishment of mechanisms to ensure subgrantees comply with eligible uses, and any other information required by the Assistant Secretary.

States must also submit semiannual reports to track progress against approved plans and describe how grant funds were expended, each service provided, the number of locations where broadband service was made available, and the demographics of those served. The semiannual report must include an SF-425 and a Federal Financial Report and meet the requirements described in the Department of Commerce Financial Assistance Standard Terms and Conditions.

Your state must obtain and review the information on how their grant recipients have complied with federal labor and employment laws, and related records of any other entities involved in the project (contractors and subcontractors), including how they complied (or not) when working on broadband deployment projects in the last three years.

Additionally, your state office may consider the subgrantee's historical use of contracting and subcontracting arrangements and examples of past performance in similar projects. The subgrantee's plan for ensuring compliance with fair labor practices should include how they will ensure compliance in their own labor and employment practices, as well as those of their contractors and subcontractors. It should also include information on applicable wage scales and payment practices and how workplace safety committees will be implemented.

Finally, within one year of expending all grant funds received, states must submit a Final Report that describes how the funds were expended, each service provided, the number of locations where broadband service was made available, and the demographics of those served. The Final Report must also include reports received from subgrantees, and certify that the state complied with all requirements and additional reporting requirements prescribed by the Assistant Secretary.

Ready.net’s new Ongoing Reporting and Compliance tool, coming in 2024, manages the state’s ongoing relationship with applicants and all of their reporting and compliance requirements with entities such as NTIA, FCC and others. 

Call to Action

As state broadband offices gear up to deploy the $42.45 billion federal BEAD program, they need to begin thinking beyond mapping. There are many other steps left ahead of them, including creating initial and final proposals, running a transparent challenge process, handling subgrantee applications, and providing regular reporting and ensuring compliance of all who participate. Ready.net offers tools to help state, territory, and tribal broadband offices throughout the entire process. Learn more.