By Brian Hurley, ACA Connects Chief Regulatory Counsel
This is from ACA Connects
As States and Territories develop their Initial Proposals for the BEAD program, one of their most consequential decisions is determining how project service areas will be defined. States and Territories may allow applicants to design their own project areas – which is the standard practice for unsubsidized network builds – or they may solicit applications at a geographic level of their choosing, such by county, census tract or census block.
In a White Paper released today, ACA Connects and its partner, the business consulting firm Cartesian, explain that defining the minimum biddable area at a granular level – preferably by individual location, but if not, then by census block (with very high cost locations removed) – is the most cost-effective approach because it will maximize competition for funds, especially from smaller providers who may be deterred from participating if that meant agreeing to serve all of the eligible locations in an entire census tract or county. While smaller biddable units may increase the chances that applicants will submit partially overlapping applications, States have demonstrated they can resolve such overlaps. In addition, if project areas leave out higher-cost individual locations, the program gives State and Territories leeway to find solutions to connect them.
The White Paper also touches on a related issue – setting and applying the extremely high-cost per-location threshold. As the White Paper explains, the threshold should be set and applied at a granular geographic level. If too large an area is used – such as a county – the threshold would be set too low and many “fiber-viable” locations are likely to fall above the threshold if they happen to be located in the same county as very high cost locations.
ACA Connects urges State and Territory Broadband Offices to use this White Paper as a resource as they finalize their Initial Proposals. We stand ready to discuss the White Paper in detail and answer any questions.