The National Telecommunications and Information Administration (NTIA) has released a guidance document for subgrantees in the Broadband Equity, Access, and Deployment (BEAD) Program.
The document, “Obligations for Subgrantees Deploying Network Projects,” is designed to help entities building these networks be as compliant and efficient as possible.
The guidance has been issued in the wake of the revised BEAD Program guidelines released in June. It says subgrantees must incorporate best practices as defined by the Assistant Secretary and establish “comprehensive risk management plans” that focus on their contributions’ reliability and resilience.
Plans should address natural disasters such as wildfires, flooding, tornadoes, and hurricanes. Both physical and digital disruption should be addressed.
Schedules are important as well. The guidance says that subgrantees must follow deployment schedules to ensure projects are finished on time. They should regularly report progress to their respective Eligible Entity in a way that is consistent with the monitoring requirements in their subgrantee agreements.
The Eligible Entity may request waivers to the four-year deployment deadline, as described in the Notice of Funding Opportunity. They may or may not be granted.
A best practice for fiber deployment is for the subgrantee to report measurable milestones to the Eligible Entity, including the total number or percentage of broadband serviceable locations (BSLs) served in a project area. Milestones may include time-consuming gating items such as submitting local permits to the appropriate offices, locating underground utilities, and receiving final approval of permitting requirements at the start of the project.
Best practices for fixed wireless deployment might include a report by a subgrantee to the Eligible Entity noting the number of new towers, base stations, and sectors completed, or endpoints completed in a coverage zone.
A low Earth orbit (LEO) subgrantee may certify to the Eligible Entity that service is available to a percentage of BSLs in the project area, or once the subscription rate reaches a set percentage of locations in the project area.
The new BEAD guidance says that subgrantees must propose at least one low-cost broadband option that meets NTIA approval. This service option must be available to eligible subscribers for the useful life of the network asset, which is the federal interest period (10 years after the year in which the subgrant for a project has been closed out, or, in the case of LEOs, a 10-year period of performance).
The subgrantee’s definition of a low-cost service option must detail:
- All recurring charges to the subscriber, as well as any non-recurring costs or fees to the subscriber.
- The plan’s basic service characteristics (download and upload speeds and latency; the LCSO must be at least 100/20 Mbps and <100ms latency).
- The plan’s price and, as applicable, how the price will change over time.
- Whether the subgrantee will define an Eligible Subscriber more broadly than the Restructuring Policy Notice (RPN).
