What Local Governments and Community Organizations Can Do Right Now to Prepare for BEAD Funding

The 2021 Infrastructure Investment and Jobs Act (IIJA) created significant new broadband funding opportunities for state, local, and Tribal governments. The largest of these programs is the Broadband Equity, Access, and Deployment (BEAD) Program, which will be administered by the Department of Commerce’s National Telecommunications and Information Administration (NTIA). The program allocates $42.45 billion to states and territories primarily to fund the construction of broadband infrastructure to unserved and underserved communities. To ensure that your community is prepared to make the best possible use of these funds, we’re sharing some tips for how you can plan ahead for BEAD grant awards.

States will decide how to distribute their BEAD funding

The BEAD Program departs from the typical broadband funding structure in that states are the only “eligible entities” to receive funding directly from NTIA. The statute that codified the program specifies that states that choose to participate will each receive a minimum of $100 million, with additional funding allocated based on the relative number of unserved and underserved high-cost locations in that state. For the purposes of the BEAD Program, unserved locations are defined as those with no access to 25/3 Mbps service, and underserved locations are defined as those with no access to 100/20 Mbps service.

States will develop their own broadband funding strategies and programs, funded by the NTIA allocations, and eligible subgrantees will then apply directly to their state for project funding.

While states will have some level of discretion for determining project eligibility, the statute identifies the following as eligible for funding under BEAD:

• Broadband deployment to unserved or underserved areas
• Connecting eligible anchor institutions (a defined term that includes schools, libraries, health clinics, hospitals, public safety entities, public housing organizations, and more)
• Broadband data collection, mapping, and planning
• Installing broadband infrastructure or delivering reduced-cost broadband in multi-family residential buildings
• Broadband adoption efforts, including device distribution programs
• Any other NTIA-approved use

The majority of BEAD funding is expected to be used for broadband infrastructure initiatives. NTIA has set funding priorities as: unserved locations, underserved locations, and community anchor institutions, in that order.

NTIA is expected to publish the program’s notice of funding opportunity (NOFO) in May; the NOFO will include further detail and clarification on eligibility, project prioritization, and the application process for states. States will then be able to submit initial proposals to NTIA for up to 20 percent of their funding allocation. This initial funding may go largely toward staffing and other administrative costs as states prepare to administer the rest of the funds — while simultaneously developing their funding rules and administrative mechanisms for distributing the remaining 80 percent of funding to localities and other subgrantees.

What localities can do to prepare

While there remain several steps before BEAD project funding will be available to subgrantees, local governments can still take important steps now to start preparing for BEAD funding from their state:

1. Engage with your state broadband leadership: States will have significant latitude over funding requirements, and localities can benefit from communicating their priorities before state rules are finalized.
2. Collect data: Having information about connectivity in your community means that you can write a stronger application and make a solid case for why your project is needed.
3. Develop partnerships: Partners are often an essential part of the application and implementation process. Exploring potential partnerships and making sure your team is ready to be a good partner will set you up for success.
4. Identify sources of matching funds: Federal funding opportunities often require financial matching. Doing work now to identify sources of match will help move a project along later.

1. Engage with your state broadband leadership

States will play a critical role in this program as grant makers, and will have a significant level of latitude in how they set project requirements and administer funding. Because of this, it is critical for localities to establish a relationship with their state’s broadband leadership as soon as possible. This will be a two-way process: Both the language in the IIJA and preliminary guidance from NTIA place emphasis on states’ engagement with stakeholders as they develop their programs, and localities and community organizations will have opportunities to comment on state plans once released. Localities should work to proactively communicate their priorities in hopes of having them reflected in the state’s funding design. Localities can also engage further downstream with local and community-based organizations and then communicate feedback up to the state level to ensure that those groups’ perspectives are also taken into account in the state’s plan (see #3 below for more on this point).

For example, localities could press their state to require — or give strong preference to, via scoring mechanisms — applications submitted by subgrantees that have a Tribal or local government partner, or at the very least, a letter of support from such an entity. Localities can also communicate a desire to see strong affordability requirements attached to infrastructure projects. While BEAD requires that eligible subgrantees will need to offer low-cost broadband plans to all subscribers, states will have some degree of flexibility in setting those requirements. Localities can push at the outset for strong affordability requirements.

2. Collect data

Collecting relevant broadband data is a resource-intensive process that can make future grant applications easier to put together — and that data will make the applications stronger when put in front of evaluators. Localities should consider getting an early start on collecting both broadband availability data and various demographic data that can help to demonstrate community need.

For infrastructure projects in particular, documenting served and unserved areas with accurate data is central to making a case for funding. While flawed, federal broadband data is often the starting point for determining local broadband availability. The Federal Communications Commission was recently charged with updating its National Broadband Map, which is the primary source of federal broadband data, but these updates are not expected for several months, if not longer. NTIA’s Indicators of Broadband Need Map includes Ookla speed test data, American Community Survey adoption data, and FCC service availability data. Localities should consider collecting community-specific data that more reliably describe the actual broadband environment in the proposed area — for example, through online speed tests, resident and business surveys, ISP information requests, or field inspections of existing broadband infrastructure.

Localities can also collect or identify various types of demographic data, including socioeconomic status, broadband adoption, enrollment in the Affordable Connectivity Program, or any other metric that might demonstrate need in a grant application. Some entities might already be collecting such data that can be used in an application, or a survey process could be used to gather new information.

3. Develop partnerships

Localities can also start identifying potential partners for infrastructure projects, even before states open direct funding opportunities. This could include beginning a preliminary procurement process, which can be an effective way to communicate goals and identify complementary partners.

Project applications will likely benefit from demonstrating support from local, regional, and non-profit stakeholders. Localities can get a head start on this process by reaching out to contacts at local school districts, community-serving non-profits, economic development agencies, metropolitan planning organizations (MPOs), councils of governments (COGs), workforce development programs, and similar entities with a vested interest in ensuring the communities they serve have access to affordable broadband.

4. Identify sources of matching funds

Finally, it’s never too early to address a project’s budget and funding sources. The IIJA specifies that subgrantees will need to provide a 25 percent match for broadband infrastructure projects. Localities can engage with potential private sector partners — as well as non-profits and philanthropies — to develop an approach to pooling match contributions. Matches can include in-kind contributions and cash.

Typically the match for federal grants (and federal funding distributed through a state) cannot come from other federal funding — but BEAD is an important exception. The IIJA notes that funds obtained via the American Rescue Plan Act (ARPA), the Families First Coronavirus Response Act, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, or the Consolidated Appropriations Act of 2021 are acceptable sources of match funding for IIJA broadband programs. This allowance should help to make projects more accessible for many.

How the National Broadband Resource Hub can help

The National Broadband Resource Hub was created with the specific intention of providing government and community broadband leaders with the resources and tools needed to effectively and equitably make use of available federal broadband funding. As BEAD and other federal programs progress, we will continue to produce and curate online content to support project planning and implementation, as well as online events on topics of interest. Make sure to subscribe to our email newsletter so you can stay in the loop as new resources are made available.