Key Takeaways

• Most locations near the proposed corridors already have service. Within three miles of a priority corridor, 87.4% of the 129,023 broadband serviceable locations can already get service of at least 100 Mbps download and 20 Mbps upload, excluding satellite and unlicensed fixed wireless.
• Counting BEAD, that share rises to 90.4%. Adding locations included in a future BEAD project, again excluding satellite and unlicensed fixed wireless, nine in ten locations within three miles of a corridor either have service today or are due to be served.
• The result holds at every distance tested. 89.5% already served at one mile, 87.4% at three, 86.8% at five, and 85.8% at ten. Widening the buffer does not surface a materially less-served population.

Colorado’s Draft Middle-Mile Plan

The Colorado Broadband Office has released a draft plan for building new middle-mile fiber in rural parts of the state. Middle mile is the long-haul fiber that carries traffic between local networks and the wider internet. It does not reach homes and businesses directly, but the networks that do depend on it. The draft plan focuses on three regions in western and southwestern Colorado, identifies stretches of state and federal highway where new fiber could be laid, and scores them to select a smaller set for construction. Five corridor groups are carried through to a cost estimate of roughly $31.6 million. This post measures the extent to which broadband service already exists along these priority corridors. Our goal is to highlight areas of potential overbuild, which is wasteful, and offer decision-makers opportunities to better target available funding to address real needs.

Corridor Map

The Colorado Broadband Office’s draft middle-mile report identifies a set of priority corridors: stretches of state and federal highway where new middle-mile fiber could be built. Appendix B of the draft presents these corridors as a map, over a shaded background showing the three regions the study covers.

The map was reproduced from public data: CDOT’s published highway centerlines for the corridors, CDOT’s published record of which highways carry state fiber and between which mile markers for the fiber network, and Census county boundaries for the three regions. The corridor codes used in the draft are CDOT route identifiers, so each corridor maps directly to a published highway.

Proximity to Existing Service

For each priority corridor, every broadband serviceable location within a set distance of the route was identified, and the share where service of at least 100 Mbps download and 20 Mbps upload is already available was measured. Satellite and unlicensed fixed wireless are excluded. A second measure adds locations which are included in a future BEAD project (again excluding satellite and unlicensed fixed wireless). Locations come from the FCC’s location fabric, service from the FCC’s Broadband Data Collection as of December 2025, and awards from Colorado’s published BEAD data. Corridors are measured only within Regions 9, 10 and 12.

The table below gives the share of nearby locations where service is already available, at four distances. Within three miles of a corridor, 87.4% of locations already have service and 90.4% either have it or are included in a BEAD project.

The next table gives the same measures for all locations in each region, whether or not they are near a corridor. Across the three regions 84.8% of locations already have service. Region 9 is the least served at 79.6% and Region 12 the most at 88.3%.

The following table compares the five corridors selected for funding with the twenty that were not. Selected corridors are slightly less served today, 87.1% against 89.5%. Counting locations included in BEAD projects, the two groups are the same at 91.2%.

The final table breaks the three-mile figures out by corridor. Three of the five selected corridors are among the better served: 145A at 86.7%, 160A at 89.8% and 550B at 92.2%. The other two are the least served of the group, 149A at 40.3% and 062A at 59.3%. Several corridors that were not selected fall below most of those that were, including 151A at 52.5% and 131B at 73.9%.

Key Takeaways

• BEAD-funded broadband builds face a broad, multi-jurisdictional permitting burden. Across the 6,933 terrestrial projects, the analysis identifies 86,402 distinct permits. Over half of projects require more than 10, and 1 in 7 require more than 20.
• Every project encounters county permitting. Beyond that, 95% require federal environmental review, 76% state permits (chiefly highway right-of-way), 71% private or third-party agreements, and 62% municipal permits. The typical build engages a median of 8 authorities, each a separate process that can delay a build.
• The exposure is geographically vast. BEAD projects overlap 2,449 counties and 12,146 municipalities nationwide, each a distinct government with its own permitting process.
• Water and infrastructure crossings are the two biggest permitting drivers. Wetlands and floodplains reach the most projects, but thousands more must cross or attach to existing infrastructure: roads and highways (4,964 projects), railroads (3,072 projects), and transmission and pipeline corridors. Together, these transportation and utility crossings will drive a significant share of BEAD permitting.
• These figures are a lower bound. Each permit is counted only once per project, even though a single county or municipality typically issues several distinct permits per build, and the analysis does not count features reached only by infrastructure running between premises.

Overview

The BEAD program will fund construction of broadband infrastructure to unserved and underserved locations across the United States. But before construction can begin, ISPs must first clear federal environmental and historic-preservation review, including NEPA, and then navigate a broader thicket of environmental, cultural, land-use, right-of-way, easement, and jurisdictional permitting requirements. These include reviews of wetland and floodplain crossings, air-quality clearances, authorization to cross or attach to federal, state, and tribal land, railroad and utility crossing agreements, and county- and municipal-level construction permitting.

Each permitting requirement triggers its own review process by separate authorities that take place over discrete timelines. These processes can quickly become burdensome for ISPs, especially on projects with firm deployment deadlines, as in the case of BEAD.

To quantify the breadth of this exposure, in the context of BEAD, we overlaid 2,942,440 funded locations across 3,783 terrestrial projects in the 50 states against 126 federal, state, and local permitting layers, and recorded, for every location, which triggers it sits inside or near. To make exposure comparable across states that define projects differently, we divide each project by county and report on the resulting project area, a project’s footprint within one county, yielding 6,933 project areas. Satellite-served locations are excluded throughout, because they require no physical plant and therefore no construction permits.

This is a conservative estimate of permitting exposure, not an engineering permitting plan. It counts the permits a build is likely to encounter; it does not estimate the cost, duration, or outcome of any individual permit, and the figures are likely a lower-bound estimate.

Number of Permits Required

Permitting exposure is not confined to a handful of complex builds. Beyond the federal environmental review (including NEPA) that most projects face, every project requires at least the county permit, over half face more than 10 permits, and about 1 in 7 require more than 20. The chart below shows how projects distribute by the number of distinct permits they face.

Permits by Level of Government

The same 86,402 permits can be reorganized by who administers each. One view is reach: how many projects each level touches, where a project can appear under several levels.

Projects reached, by administering level

The other view is share: each level’s slice of all permits.

Share of all permits, by administering level

Federal authorities are the largest single source: 95% of projects engage at least one, and federal permits account for 48% of all permits. State permitting reaches 76% of projects, driven by state departments of transportation, which administer the right-of-way and encroachment permits required along the interstate, US, and state highways near 72% of projects. County and municipal permitting is local: the county permit applies to every project, and municipal permitting to 62%. Approximately 2,449 counties and 12,146 municipalities will see BEAD deployments within their borders. The private / third-party row captures crossing and attachment arrangements with railroads, pipeline operators, and electric utilities, which 71% of projects engage.

Most Common Permits

The chart below groups the permits into thematic categories by the number of projects each reaches. County permitting is universal by construction; beyond it, water-related features (wetlands, floodplains, and impaired waters) are the most widespread environmental theme. Energy infrastructure (transmission lines, pipelines, and coal) and the interstate, US, and state highways that projects must cross or attach to follow close behind, and railroads reach a distinct tier of their own.

Why This Matters & How We Move Forward

In the spirit of the recently released movie version of The Odyssey, the preceding analysis can be seen as our attempt to detail the scale and scope of the next set of challenges facing ISPs in their journey towards finally leveraging BEAD funds to build their networks. Previously, ISPs had to navigate a storm of onerous Biden-era rules and requirements; a jarring though necessary course correction by the Trump NTIA as part of the Benefit of the Bargain round; continued battles over pole attachments; the mirage that is guidance about how non-deployment funds can be used; and the turbulence of a continuously shifting BEAD map. Now, ISPs face a thicket of byzantine permitting processes at the local, state, and federal levels that could slow or derail progress towards meeting BEAD’s goals at scale. And because this analysis counts each permitting requirement only once per project, the figures are likely a lower-bound estimate of the true burden.

Permitting issues in the broadband space are not new. Indeed, complaints about the lengthy timelines and high costs of securing permissions to build from relevant federal, state, and local actors have long been made by ISPs. However, the compressed timelines and tight budgets associated with BEAD projects make these complaints even more relevant and underscore the urgency of prioritizing reforms aimed at streamlining these processes. If the status quo remains, it is probable that NEPA/EHP review, federal land authorizations, state and local construction permits, railroad and utility crossings, easements, and other approvals will overlap, compound, and create uncertainty against BEAD’s deployment deadlines. At the same time, many localities remain ill-equipped to manage the large influx of permits and agreements they will have to handle for BEAD.

What is being done to address these issues?

As part of the BEAD Terms and Conditions, NTIA requires states to “establish Permitting Roundtables and/or working groups of relevant federal, state, local, and tribal authorities and representatives of impacted industries—including utility pole owners, railroads, communications providers, and BEAD subgrantees—that will:

1. Meet regularly to identify and facilitate resolution of any delays or disputes related to deploying BEAD-funded facilities.

2. Collect complaints (and supporting information) from Subgrantees that are not timely resolved through this process and escalate such complaints through the appropriate Permitting Roundtable or working group.”

Even so, it remains to be seen whether these efforts will yield impactful results. Numerous ISPs continue to grapple with, among other things, seemingly open-ended permitting review processes at every level and arbitrarily high costs to secure permits imposed mostly by local governments. Taken together, ISPs still face significant uncertainty as they move from planning to execution in their pursuit of deploying new networks with BEAD funds.

To date, progress towards comprehensive permitting reform has been piecemeal:

• Several states have proactively deployed resources to assist ISPs in navigating permitting processes. Arizona and New Mexico, for example, have launched permit finder tools to help their subgrantees. Other states have developed similar tools and resources, but it is unclear whether these tools will positively impact broadband deployments.
• The FCC is actively exploring how it might reform its rules to provide more clarity and consistency vis-à-vis some permitting processes. It has also been asked to consider preempting allegedly onerous permitting fees and processes.
• Ideally, state legislatures would have addressed these issues prior to BEAD awards being made, but that has not been the case. Nor has Congress acted, though several bills have been introduced that, if enacted, would address some permitting issues.
• Localities remain steadfastly opposed to efforts by Congress and state legislatures to do anything that might impede their ability to unilaterally set the terms, conditions, and fees associated with broadband permitting.

This leaves NTIA, which has taken a mostly hands-off approach to dictating permitting reforms at the state and local levels. Instead, it has required coordination among stakeholders in states (via roundtables) and provided stakeholders with resources detailing how they might go about reforming their permitting processes. As such, this means that much of the responsibility for embracing reforms aimed at streamlining the permitting process to facilitate timely and cost-efficient builds is squarely in the hands of states and their localities.

NTIA, though, could choose to be more active on these issues. For example, it could allow states to use leftover BEAD funds to improve local permitting processes. Municipalities that lack the resources to review and approve BEAD-related permits could benefit from a short-term infusion of funds to hire additional staff or outsource these functions. States that have yet to do so could invest these funds in building digital tools to assist with BEAD deployments and future builds.

In sum, the costs and delays stemming from a fragmented permitting landscape continue to burden ISPs. Policymakers at every level seem to appreciate that there is room to improve permitting processes, but progress towards comprehensive reforms is haphazard. With permitting issues holding back investment in an array of sectors, including broadband, BEAD could prove to be the tipping point toward comprehensive reforms that unlock investment and make it easier to build things in the U.S.

Two Kinds of Bias

Most people expect their representatives in local government to make informed decisions when considering how best to invest taxpayer resources. But what if city officials failed to do their due diligence before committing to a project that would require the assumption of tens of millions of dollars in debt? What if they locked in on a particular outcome from the very start, overlooking warning signs and failing to consider all perspectives on the issue?

This dynamic has long been evident in the context of municipal broadband planning. Indeed, a defining characteristic of deliberations involving these projects is that they tend to be influenced by two kinds of bias: survivor bias and confirmation bias.

Survivor bias arises when decision-making processes are informed only by the “winners.” Omitted from these deliberations are examples of “losers” or failed attempts at achieving what is being considered. In the municipal broadband context, this manifests when local officials give more weight to examples of government-owned broadband networks that have not failed and give less weight or dismiss examples of struggling or failed municipal broadband projects.

This feeds into confirmation bias, which is when decision-makers seek information that supports a particular outcome. This might happen when a city itself or a particular official or staffer stakes a lot on a municipal broadband project and, consciously or not, becomes all-in on the project. As a result, they are more likely to seek information and data that support that outcome, and skeptical or dismissive of indications it may not be a good idea.

The result is a survivor/confirmation bias feedback loop that yields an incomplete and analytically flawed view of how municipal broadband projects generally fare.

Over the next few months, the ACLP will comprehensively examine and offer ideas for countering bias in the context of municipal broadband decision-making. Our goal is to ensure that local decision-making is as informed, comprehensive, and unbiased as possible. In the meantime, we wanted to offer a timely and illustrative example of these dynamics at work.

Willmar, MN: Welcome to the “Monkey House”

In mid-May, city officials in Willmar, MN, marked the “groundbreaking for Willmar Connect — a city-owned, citywide broadband network.” This $8.2 million initiative, Phase 1 of a multi-phase plan, represented the culmination of several years of discussion about whether the city should invest in building its own broadband network.

Ahead of a key vote in the lead-up to the groundbreaking, one city councilor voiced his objection to certain cost elements of the project by saying, “we’re so deep in the monkey house that we don’t know what stinks anymore.” This reflected his frustration with constant changes to the underlying financial requirements and estimates of the project, as well as staff coming back to the council multiple times asking for additional funds for consultants and other vendors.

In other words, the council had spent so much time in the “monkey house” that it didn’t know what fresh air smelled like anymore. Instead, they had become inured to living with and inhaling a smell that would otherwise cause them to recoil.

How did this happen? A closer look at the city’s discussions about whether to pursue the broadband project, which began in 2022, reveals numerous instances of the survivor/confirmation bias feedback loop described above, influencing and pushing the decision-making process toward a favored outcome.

The Stories We Tell

Throughout the decision-making process in Willmar, much of the research, data, and support for the proposed open access fiber network was sourced from entities that advocate for or profit from municipal broadband. Many of the resources provided by these entities are highly curated, providing local officials with a sanitized view of the track record municipal broadband. For example, a widely cited map of community broadband networks in the U.S. omits the dozens of muni broadband projects that have failed over the last few decades. In other words, the map only includes “winners,” feeding into the survivor bias that tends to skew these decision-making processes.

Important parameters of the project also changed. For example, the city shifted from using revenue bonds for the proposed project to general obligation tax abatement bonds (GOBs). Initially, officials framed revenue bonds as the optimal route for the city because it would insulate taxpayers from financial risk in the case of financial struggle or failure. Now, the city will use GOBs, which are ultimately backstopped by local property taxes. If the network struggles or fails, property taxes will go up.

In addition, the city passed on several opportunities to partner with private ISPs to achieve its connectivity goals. It could have partnered with Charter to serve the Industrial Park; it voted against the proposal. Another ISP, a new entrant to the local market, would have served almost the entire city and could have reached everyone with the support of the city; it passed on the proposal.

At the same time, key elements of the financial projections surrounding the project – from estimated break-even dates to needed take-rates – have shifted in fundamental ways.

In sum, it appears that the city has been locked in on a particular outcome – building and owning a municipal open access fiber network – from the very beginning, yielding a skewed decision-making framework and highlighting the many ways that the survivor/confirmation bias feedback loop can help officials reach a pre-determined or preferred outcome.

Reports of Reduction in Satellite BEAD Awards

Broadband Breakfast recently reported that, according to NTIA officials, “states are being asked to remove as many as half the locations they awarded to satellite ISPs under the Broadband Equity, Access, and Deployment program.”

Per the article:

NTIA told states the locations were no longer eligible for funding because the Federal Communications Commission’s latest broadband coverage map, published earlier this month, showed one of two things: the locations were not the kind of structure that needed broadband, like a shed or barn, or that the locations were already in fact served by a terrestrial ISP.

This comes on the heels of at least one state, South Carolina, having cut its BEAD awards in half to reflect continued buildout by ISPs.

To attempt to investigate this, we analyzed the latest Serviceable Location Fabric (v9) and the latest BDC data release (2025-12-31, which uses Fabric v8) to see how many locations awarded BEAD funds for satellite service are either (1) no longer included in the Fabric as broadband-serviceable locations or (2) are already “served.” The following table breaks that down at the national level, showing how many satellite BEAD locations drop off from these updates.

As shown above, based on the data available to us, about 35% of locations awarded BEAD funds for satellite service are likely no longer in need (42% if unlicensed fixed wireless is included), which aligns with the statements quoted above. In terms of funding, this eliminates roughly $354M in expenditures ($423M if unlicensed fixed wireless is included).

The NTIA officials’ statements may be based on 2026-06-30 BDC data, which was recently reported by ISPs and has not yet been released to the public. This newer data is likely to include additional served locations, likely further reducing the number of locations in need of satellite service.

Takeaways & Open Questions

This latest development highlights several important takeaways and open questions about BEAD and the state of broadband availability in the U.S.

First, this development underscores that the BEAD map and the digital divide BEAD was created to close remain moving targets. Prior ACLP analyses have shown that the number of unserved and underserved locations in the U.S. have dropped precipitously since BEAD launched in December 2022. Indeed, just last week South Carolina announced that it was reducing its BEAD awards by half to reflect newly served locations across the state, many of which were supported by ARPA funds and ISP matching dollars.

Second, these gains continue to be driven by relentless investment by ISPs, who continue to push their terrestrial networks to more parts of the country. These investments, some of which are leveraging other federal grant dollars (e.g., CPF), have shown little sign of abating, reflecting the competitive intensity of a marketplace being shaped by insatiable consumer demand for faster speeds and seamless connectivity.

Third, the continued refinement of the BEAD map with the latest data indicates that, notwithstanding the complaints of some, the FCC’s BDC process continues to improve with each iteration, yielding ever more accurate maps. With each iteration, we have clearer insights into where the remaining – and shrinking – coverage gaps exist, helping to ensure that available funding is used as efficiently and effectively as possible.

Fourth, this latest directive from NTIA comes at a time when BEAD projects in many states are still getting off the ground. Even though NTIA has approved almost every state Final Proposal, most BEAD projects remain in their infancy as subgrantees move to deployment mode. With BEAD dollars in hand, many ISPs must now navigate the thicket of overlapping, confusing, and costly permitting, ROW, pole attachment, and related processes. All told, BEAD’s runway continues to be very long, which means that there will likely be further refinements to the BEAD map down the line. In short, the longer it takes for BEAD projects to launch, the higher the chances that BEAD-eligible locations might be taken off the board.

Finally, when BEAD locations come off the map, the question then becomes, what happens to those funds? Do they go into the non-deployment bucket? NTIA has yet to provide guidance to states regarding what they can do with non-deployment funds, which total more than $20 billion. Adding to this bucket via removal of BEAD locations could put additional pressure on NTIA to finally release its non-deployment guidance.

Remaining Satellite Locations by State

Note that the data for several states is based on draft or submitted Final Proposal data, and that several states have revised their awards after their approved Final Proposal data was released. These are not official figures; they represent only our estimate of the potential impact of these pending changes. States without satellite awards and territories are omitted from this table.

Updated to reflect similar reductions already made by South Carolina, and to add a by-state table of remaining satellite locations.

Key Takeaways

• The New York City Public Advocate recently released a plan that calls for the city to spend well over $2 billion to build and operate a city-owned municipal fiber network.
• The Plan omits recent data and is devoid of rigorous analysis. It also includes a variety of extreme proposals, like studying how the city might seize the assets of a private utility to support this initiative, and shrugs off the considerable fiscal headwinds facing the city in the coming years.
• The Plan echoes the tabled Internet Master Plan (IMP), which was released in 2020 by a prior mayor and called for similarly far-reaching and unnecessary interventions into the local marketplace. The city’s new mayor, Zohran Mamdani, is required by law to issue his own “master plan” later this year.
• Municipal fiber networks are inherently risky and costly ventures. These risks and costs are compounded exponentially in the country’s most populous and diverse city, where it is challenging to build anything at scale, let alone a sprawling fiber network. The logistics and costs of such an endeavor are dizzying and would likely take many more years to build and cost much more than current estimates.
• In this first installment, the ACLP provides essential context for evaluating the Public Advocate’s Plan and understanding the dynamics at play as Mayor Mamdani begins to formulate his own broadband plan.

The New York City Public Advocate’s Office recently released an “Internet for All” Plan that, among many other things, recommends spending more than $2 billion of scarce public resources to build a city-owned open-access municipal fiber network across the five boroughs. The Plan also suggests that the city explore ways to potentially seize infrastructure owned by a private electric utility, Con Edison, via eminent domain to support this initiative.

These are among the more outlandish proposals in a Plan that, at any point in the past, would be easy to dismiss as far outside the mainstream and not reflective of the broadband connectivity challenges facing the city. However, the Public Advocate’s Plan comes at an interesting time in New York City.

In late 2025, the New York City Council passed a law requiring the mayor to develop an internet master plan. This would be the second time an NYC mayor issued such a plan. In January 2020, then-mayor Bill de Blasio released his own Internet Master Plan (IMP), which recommended spending upwards of $2.1 billion to deploy a citywide public fiber network, like what the Public Advocate is now calling for. The IMP was shelved by de Blasio’s successor, Eric Adams. The law requires the new mayor, Zohran Mamdani, to release a draft broadband plan by November of this year and a final version by May 1, 2027.

Since his election, there have been increasing calls for Mayor Mamdani to revive the IMP. The Public Advocate’s Plan offers the latest and highest profile effort to date to amplify these calls to action. As such, this Plan, for all its many flaws, cannot be dismissed out of hand.

Over the next few months, the ACLP will publish a series of analyses evaluating broadband connectivity in New York City from key supply- and demand-side vantages. The overarching goal will be to ensure that the forthcoming discourse about broadband in NYC is informed by data and grounded in reality.

For this first piece, data support three high-level contextual points that, respectfully, should inform the discourse in NYC going forward.

1. Broadband availability is not an issue in New York City, which has one of the most vibrant and competitive broadband markets in the country.
2. Municipal broadband projects are always fraught with risk. The complexity and uniqueness of NYC introduce numerous additional risk factors.
3. Broadband challenges in NYC exist almost exclusively on the demand-side. Supply-side initiatives will not solve them.

Broadband availability is not an issue in New York City, which has one of the most vibrant and competitive broadband markets in the country.

A central flaw of the Public Advocate’s Plan is its reliance on outdated and incomplete data. Indeed, the Plan draws primarily on data cited in the IMP, which was drafted in 2019, and does not otherwise seriously engage in new data collection or analysis.

The following chart provides a succinct summary of the latest data about broadband availability in NYC.

The data are clear: broadband availability and competition in the city is incredibly robust. Nearly every household in the city can access 900+ Mbps connections from a variety of providers, and fiber is widely available. In addition, the current landscape also includes a new platform, fixed wireless access (FWA), that is available across the city from Verizon and T-Mobile, providing customers with additional choices. When the IMP was released, FWA was still nascent. Now, almost every New Yorker can choose from at least three fixed (i.e., non-mobile) broadband options. And when 5G mobile service is included, broadband access is effectively universal across the city.

Within this environment, broadband prices have barely grown over the last decade. ACLP analysis of federal pricing data shows that, in real terms, what people actually pay for broadband has grown at a much slower pace than inflation. Further, broadband prices, as a share of household expenses on essential items like electricity, gas, and water, are minute compared to those other costs, which have risen much more sharply.

In short, the supply of broadband in NYC is not an issue, though some readers of the Public Advocate’s Plan who lack knowledge of these trends might draw the opposite conclusion. This is why it is imperative that broadband discussions in New York City (and elsewhere) be grounded in objective data, rather than outdated assumptions (and data). Otherwise, these dialogues, and the policy proposals that stem from them, will be shaped by other, more subjective forces.

Municipal broadband projects are always fraught with risk. The complexity and uniqueness of NYC introduce numerous additional risk factors.

Municipal broadband remains exceedingly rare in the U.S. Out of more than 90,000 local governments across the country, only about 400 localities have chosen to build their own broadband networks. This works out to less than one-half of one percent, a vanishingly small share that speaks for itself.

This is not an accident. It reflects two basic realities. First, broadband is widely available across the country, rendering such extreme government intervention unnecessary. Second, municipal broadband projects carry significant financial and operational risks, making them unattractive to most cities, many of which face a growing array of public infrastructure challenges, increasing financial pressures, and other pressing priorities.

The risks involved with pursuing municipal broadband revolve around the intertwined factors of: (1) the very high capital costs associated with building, operating, and upgrading the network; and (2) the need to generate enough revenue to cover those costs. Even networks that are non-profits still need to make money to cover expenses. This involves convincing enough customers to switch from their current ISP to the public offering, a difficult proposition in markets that are already well served by established service providers, who tend to compete fiercely to retain their customers.

When municipal broadband systems fail to attract enough customers to grow or even sustain the minimum required investment, the economics unravel quickly. Revenues fall short, bills pile up, debt obligations remain, and the project can enter a downward financial spiral. At that point, cities are often left with two bad options: subsidize the failing network with taxpayer dollars or sell it off after sinking substantial public resources into a failed experiment. Many municipalities have already learned this lesson the hard way (the ACLP has documented many municipal broadband failures here).

Unfortunately, the inherently risky nature of these ventures is often glossed over or omitted entirely in municipal broadband discussions, including the Public Advocate’s Plan. Missing from these conversations are the dozens of public broadband projects that have struggled or failed outright. That omission is especially striking in New York City, which has already seen two notable public broadband failures: NYCWiN, a failed public safety wireless network, and LinkNYC, which has encountered countless problems across several iterations (the ACLP has discussed these NYC failures previously, including in testimony before the NYC Council in 2025, and will revisit these and other failed muni broadband initiatives in subsequent parts of this series).

Instead, the Public Advocate’s Plan points to the municipal fiber network in Chattanooga, TN, to bolster its recommendation that NYC build something similar. The ACLP has written extensively on the uniqueness of Chattanooga’s municipal fiber network and how unlikely it is that any city of any size can replicate it. Chattanooga is among the largest cities in the country to deploy a municipal fiber system. Even so, it is still a relatively small city whose population is similar to that of the Upper East Side of Manhattan or Greenpoint and Williamsburg in Brooklyn. Put differently, NYC is 44 times bigger population-wise than Chattanooga.

This goes to an important point overlooked by the Public Advocate and many others who continue to talk about building a municipal broadband network in New York City. Looking anywhere other than the city for evidence that something might work here is unwise. There is no place like New York City – it is a large, sprawling metropolis with an incredibly diverse population living in high-rises in Midtown, low-rises in Bed-Stuy, and single-family homes in Whitestone. Doing anything here at scale is complex and expensive and time-consuming, and when government does it, it usually takes even longer to complete and costs more than expected. That the Public Advocate fails to grapple with the cost impacts of his proposal is particularly egregious given the widening out-year budget gaps and mounting obligations across housing, public safety, and social services that the city faces. More immediately, the city is facing a significant cash crunch, further underscoring its financial precariousness.

The crumbling state of public housing across the city is instructive. Per the New York Times, public housing “residents regularly struggle with heat outages, broken elevators and mold, and the cost of backlogged repairs has soared to nearly $80 billion.” Conditions have deteriorated to the point where the city is increasingly looking to the private sector to help finance and rebuild growing portions of its public housing stock, an explicit acknowledgement that the city is poorly positioned to build and take care of things at scale. It can’t even build public toilets in a timely or cost-effective manner.

These and other examples do not bode well for a city-run broadband system that will have to compete with faster-moving, better-capitalized private ISPs. Moreover, even under optimistic assumptions, building a citywide fiber network would take many years to complete, delaying any potential benefits while other, more pressing connectivity issues remain unaddressed. And in such a competitive marketplace, unlike private investment, municipal broadband would require ongoing taxpayer support if revenues fall short, compounding the fiscal threats looming on the horizon.

Broadband challenges in NYC exist almost exclusively on the demand-side. Supply-side initiatives will not solve them.

Broadband availability is not an issue in NYC. Nearly every resident has access to multiple choices for internet service. But not every resident has chosen to adopt broadband. Why is that?

The Public Advocate attempts to argue that broadband adoption rates are low in certain communities because the cost of service is too expensive. While this argument might be appealing from a political standpoint at a time when “affordability” remains a popular buzzword, it is incomplete and misleading. Moreover, it defies the data, which consistently show that broadband adoption decisions are much more complex and influenced by non-cost factors like not seeing broadband as relevant or useful or necessary.

Consider, for example, the following table of broadband adoption rates in New York City over the last decade. The trends are generally positive, but in-home wireline adoption (e.g., of cable or fiber) has flattened in recent years. When mobile connections are included, adoption rates continue to rise, suggesting that a growing number of people are choosing to go mobile-only. The Public Advocate downplays this trend in support of his proposal for a citywide fiber network, but the data tell a different story.

It is also notable that in-home adoption rates have plateaued despite the wide availability of subsidies from the federal government during the pandemic – via the Emergency Broadband Benefit program (EBB) and its successor, the Affordable Connectivity Program (ACP) – and the city itself via Big Apple Connect (BAC). The following chart depicts this dynamic.

When combined with low-cost offerings from local ISPs like Charter and Verizon, in-home broadband subscriptions for qualifying households have been free for many years. And yet, adoption rates have barely budged. Moreover, broadband adoption rates in the Bronx have yet to recover from decreases during the pandemic despite the wide availability of free broadband.

National survey data consistently finds that the primary reason for non-adoption remains relevance, not price. Indeed, studies have found that some won’t adopt broadband even when it’s free. This might sound shocking, but as in NYC, the national broadband adoption rate barely increased during the years when substantial subsidies from the federal government were available, which could be used in tandem with ISP low-cost offerings to receive service for free.

So, spending billions to build a municipal fiber network and offer service at very low cost or even for free will not solve these lingering adoption issues in New York City. Instead, investing resources in this manner may ultimately entrench these demand-side issues because it will shift available resources away from experts on the demand-side, who have proven time and again that they know how to bring even the most reluctant people online.

The ACLP has a lot more to say about the need for the city to invest in demand-side activities. The Public Advocate omits any mention of the importance of addressing demand-side issues, which is unfortunate and reflects an incomplete understanding of how broadband adoption really works.

Heated Rivalry

The emerging discussion about the role of city government in the broadband market comes at a tense moment in the relationship between the private sector and New York City officials. This is not surprising given the rhetoric of many officials, who have expressed deep faith in the ability of government to do more on behalf of residents, while also voicing pointed critiques of the private sector. In furtherance of this agenda, city government is moving ahead with building municipal grocery stores to compete with and take business away from local shop owners. There is talk of seizing private property – apartment buildings, utility infrastructure – for public purposes. At the same time, the city has not prioritized traditional economic development programs that, for decades, sought to bolster private investment.

This is the context in which the emerging discussion about municipal broadband in New York City must take place. It is more than just a niche conversation about broadband connectivity in the five boroughs. It is part of a larger debate about the role of private enterprise in a city that is beginning to operationalize a fundamentally different economic philosophy than at any time in the recent past. Is the city comfortable potentially crowding out or chilling private investment to support this new vision for the economy?

The ACLP will soon say more on all these topics, so please stay tuned for additional parts in this ongoing series.

Key Takeaways

• Across 54 states and territories, BEAD has catalyzed $30.6 billion in total broadband investment.
• ISPs are contributing $11.4 billion in matching funds, or 37.2% of total project costs.
• 51 of 54 states and territories have match rates at or above 25%.
• Match commitments scale with provider size: established national ISPs match 49% of project costs, compared to 28% for small/regional ISPs.
• These significant contributions of capital by established ISPs mirror their long-term and ongoing commitment to enhancing their networks. On average over the last 5 years, ISPs collectively invested in excess of $90 billion annually.
• In the BEAD context, these matches, which far exceed the 25% minimum, further underscore the depth of commitment by established ISPs to continue expanding their networks to serve as many people as possible.

National Summary

The BEAD program requires subgrantees (typically ISPs) to contribute matching funds toward project costs. The table below shows how total investment breaks down nationally.

The ISP match alone, $11.4 billion, represents the vast majority of non-federal investment, underscoring the scale of private-sector commitment to closing the digital divide.

Match Rates by ISP Footprint

The table below groups subgrantees by the size of their existing broadband footprint, measured by locations reported to the FCC’s Broadband Data Collection, to show how match commitments scale with ISP size.

12 national ISPs alone committed $6.1 billion in matching funds — more than every other BEAD subgrantee combined. At close to half of project costs in that tier, these established carriers are matching well above the 25% statutory minimum.

Top ISPs by Matching Contribution

The table below shows the 20 ISPs contributing the most in matching funds. Several of these ISPs have matching rates exceeding the subgrantee match average of 37.2%.

State Breakdown

The table below shows BEAD investment and match rates for all 54 states and territories.

Methodology

This analysis uses project-level data from NTIA’s BEAD Initial Proposal submissions, covering 54 states and territories with approved, submitted, or draft proposals. Funding figures are summed from 6,500 individual project records. “ISP Match” refers to the subgrantee match field, the matching contribution committed by the subgrantee (typically the ISP deploying the network). “Total Match” also includes state, federal, and other matching sources.

For the top ISPs list, ISPs are consolidated by corporate subsidiary. Of 501 total BEAD subgrantees, 420 are matched to a consolidated provider.

Key Takeaways

• BEAD-funded broadband projects will touch an estimated 3,954,030 utility-owned poles across 2,053 electric utility service territories, based on 188,287 planned aerial fiber route-miles.
• About 40% of all BEAD aerial fiber will be deployed across electric cooperative territories, which are disproportionately represented relative to cooperatives’ share of electric customers (13%).
• Pole attachment regulation is scattershot. The FCC has jurisdiction over poles owned by investor-owned electric utilities (IOUs) in 27 states; in the other 23 states, IOU poles are regulated by state public utility commissions. Regulation of poles owned by electric cooperatives and municipal electric utilities differs across all 50 states – some leave these entities entirely unregulated; some regulate one but not the other; and some regulate both.
• Pole-related costs could range from $534M to $4.63B nationwide, depending on make-ready charges and pole replacement rates. Even our base scenario estimates $1.25B in total pole-related costs. Costs that are unexpectedly high could strain deployment budgets, slow deployment, lead to defaults, and deprive communities of broadband.
• Unresolved electric utility pole issues have long impacted broadband deployment. NTIA has sought to address the regulatory patchwork in the BEAD context by extending the reach of the FCC’s rules. The FCC has signaled a willingness to act more quickly in resolving pole disputes. However, it remains to be seen if these approaches will translate to more streamlined and cost-effective access to utility poles, especially given ongoing quarrels involving utilities already subject to the FCC’s rules.

Overview

The BEAD program will fund construction of broadband infrastructure to nearly 4 million unserved and underserved locations across the United States. A significant portion of this build-out will use aerial fiber, which requires attachment to utility poles. Planned aerial deployment totals about 188,287 route-miles, or 41.8% of total BEAD fiber miles.

Utility poles are plentiful. By some estimates there are some 180 million poles across the country. Leveraging poles to deploy fiber is cost-effective – the Fiber Broadband Association estimates that aerial deployments cost half as much as burying fiber – and can speed network construction. However, negotiating access to poles can be fraught as ISPs must navigate a patchwork of regulated and unregulated electric utilities of varying sizes and sophistication. These interactions can quickly become adversarial, delaying projects and raising costs.

This analysis overlays 3,855,167 BEAD-funded locations across 6,265 projects against 2,053 electric utility service territory boundaries to investigate how BEAD deployments will span utility service territories. We focus on electric utility-owned poles, which comprise the vast majority of poles across the country – upwards of 70% according to recent estimates – and because many pole-related disputes between parties involve electric utilities.

We then apply planning assumptions to estimate utility-pole touches and related costs. Our goal is not to duplicate subgrantee cost estimates, which formed the basis for their BEAD applications. Indeed, applicants should have planned for reasonable pole-related costs. However, in practice, recent history is replete with examples of ISPs encountering higher-than-expected pole costs, including instances where pole owners have attempted to unlawfully shift the cost of curing pre-existing violations to new attachers. These actions can cause significant delays and have even made broadband projects uneconomic despite significant grant dollars.

Given these stakes, we present a spread of potential pole-related costs to offer insight into how higher-than-expected pole costs could impact BEAD, and why policy interventions are needed to mitigate project delays or defaults.

BEAD Aerial Miles by Utility Ownership Type

The following table is based on the latest available compiled state BEAD Final Proposal data, which includes a mix of draft, submitted, and approved final proposals from state broadband offices.

Most notably, a disproportionately large share of BEAD deployments will take place across electric cooperatives’ service territories, as compared to their share of total utility customers. In other words, about 40% of all aerial BEAD fiber deployment may involve poles owned by cooperatives, who, collectively, serve 13% of all electric customers in the U.S.

Why Utility Ownership Type Matters: FCC oversight extends only to private investor-owned electric utilities (IOUs) in 27 states; public utility commissions in the other 23 states regulate IOU poles. Municipal electric utilities and electric cooperatives are exempt from FCC oversight, and many states do not regulate these entities.

Under this framework, FCC oversight would extend to about 10% of the utility poles that BEAD will touch.

BEAD will touch millions of poles that are not regulated by the FCC, where there are fewer guardrails in place to provide predictability and consistency in how pole-related costs are set. For example, one study found that the attachment rates for pole owners subject to regulation (IOUs and private companies) were significantly lower than those exempt from regulation, such as municipalities, cooperatives, and public utilities. BEAD recipients may encounter higher-than-expected pole fees from these entities, which could drive up costs and trigger delays or defaults.

To address this patchwork, NTIA requires that “poles owned within the [state’s] jurisdiction that are not currently subject to state or FCC pole attachment regulation will be governed by FCC rules through the federal interest period.” Its stated goal is to “reduce the regulatory burden on BEAD participants.” How these rules are applied and enforced, though, remains to be seen. Cooperative advocates have expressed their displeasure at this federal encroachment into the state-by-state regulatory approach that has evolved for these entities over the last few decades. Moreover, recent disputes involving ISPs and electric utilities underscore the myriad possibilities for the latter to attempt to circumvent seemingly clear rules governing pole access. It is notable that some of these parties are back before the FCC with new complaints about pole practices (see below for further discussion).

Given this continued uncertainty, even after commendable steps taken by the FCC and NTIA to address these barriers, it remains likely that ISPs will encounter unexpectedly high pole-related costs in some instances.

Pole Touches and Cost Exposure

The following section uses planning assumptions to estimate utility-owned poles touched and cost exposure from BEAD aerial route-miles. These are intended to illustrate the magnitude of potential costs and are not exact engineering estimates. The “low” and “high” scenarios represent the cumulative result of picking all low and high assumptions, respectively, and are intended to act as lower and upper bounds.

Methodology

Methodological details and sources for our model estimates are available in the full report.

Takeaways & Recommendations

From a policy perspective, utility poles remain an area that is long overdue for reform. Continuing forward with the status quo may delay BEAD projects and could result in project defaults if ISPs encounter substantially higher-than-expected costs.

How could this happen? BEAD subgrantees were required to estimate, to the best of their ability, pole-related costs in their applications. Those estimates informed the final proposed cost for the project. In practice, the Benefit of the Bargain round implemented by the Trump NTIA operated largely as a reverse-auction, with lowest bids winning in most instances. This left little room for buffers or contingency funds to address higher-than-expected costs of key inputs, from the materials needed to build a network to the costs associated with gaining access to poles, ROW, and easements.

The preceding analysis highlights the wide variability and significant unpredictability in the costs associated with accessing, placing attachments on, and replacing electric utility poles. These costs vary widely from utility to utility, and from state to state. This reflects the highly fragmented nature of oversight of pole disputes involving ISPs and electric utilities, which creates numerous opportunities for these entities to attempt to shift the costs of maintaining their poles to ISPs.

Electric utilities are natural monopolies that, in the absence of regulation, will seek to maximize profits. This is why private IOUs are subject to exacting public utility regulation. Nearly every action taken by an IOU must be scrutinized and approved by a regulatory body, and even then, regulators generally defer to utilities, yielding ever-higher electric rates in most states across the country (in the robustly competitive broadband sector, by contrast, prices have barely budged in a decade).

Municipal utilities and cooperatives, on the other hand, have been left to mostly govern themselves. Indeed, the primary accountability mechanism for these entities is the electorate. This creates an incentive for these entities to keep electric rates low lest officials be voted out of office or kicked off the co-op board. This dynamic also creates incentives to shift costs to third parties to make up for revenue shortfalls resulting from maintaining low rates. A version of this dynamic is evident in the dozens of municipal electric and cooperative systems governed by the Tennessee Valley Authority, a federal entity that is required by statute to keep electric rates as low as possible. TVA has accomplished this goal in part by devising pole formulas that allow for greater cost-shifting to ISPs than the FCC allows, all in the name of keeping electric rates “as low as feasible.”

The possibility of pole disputes is not theoretical. Rather, disputes happen all the time, and many are becoming more contentious given the high stakes and costs associated with rural broadband deployment. A recent dispute involving Comcast and Appalachian Power Company, a major IOU in Virginia, illustrates how these conflicts tend to unfold.

Comcast must negotiate access to Appalachian’s poles to support buildout in parts of the state. As part of that process, Appalachian estimated the costs to prepare its poles for Comcast’s equipment. Those costs were critical to the applications Comcast submitted for BEAD funding, so accuracy and fairness were of paramount importance. However, Comcast noticed that Appalachian sought to charge it to replace poles with pre-existing safety violations. Since Comcast did not cause those violations, it filed a complaint with the FCC and argued that having to shoulder the costs was unreasonable. The FCC sided with Comcast and found that Appalachian’s attempted cost-shifting violated its rules. The FCC reaffirmed that costs should be shared based on who caused them, meaning providers can only be charged for the additional improvements needed to attach their equipment, not for correcting old violations they did not create.

This was a major ruling that underscored the willingness of the FCC to act promptly in the application of established pole attachment rules. In theory, such prompt, direct application would seem to provide stability and predictability, especially with NTIA extending the reach of the FCC’s pole approach more broadly in the BEAD context. However, Comcast and Appalachian Power are back before the FCC, with the ISP having brought another complaint about how the utility is pricing access to its poles.

If this dynamic is not addressed and uncertainty remains, it is likely that ISPs will encounter higher-than-expected pole costs. Per the analysis above, using the base case as a reasonable proxy for what pole-related costs are expected to be by subgrantees, then costs could increase severalfold as they approach the “high” threshold estimate. This could prove ruinous to many projects.

Key Takeaways

• Multi-dwelling unit (MDU) locations make up a small share of broadband serviceable locations but a much larger share of units (e.g., apartments, offices, etc.).
• Among BEAD-awarded locations, 278,571 (7.2%) are MDUs, accounting for 879,582 units (19.7%).
• Among remaining unfunded locations, 96,082 (8.6%) are MDUs, but they account for 369,757 units (26.6%).
• MDUs are thus somewhat overrepresented among remaining unfunded locations relative to BEAD awards, particularly in terms of housing units.
• Most MDU locations are small (2 to 4 units), but a handful of very large buildings account for a disproportionate number of units.
• Most Medium and Large MDUs in remaining unfunded areas sit in well-served neighborhoods. 81% of Medium and 74% of Large MDU units are surrounded by locations that are 80–100% served. Small MDUs show a wider range of neighborhood service levels.

Background

A single “Broadband Serviceable Location” (BSL or “location”) can contain many units. For example, an apartment building may have dozens or hundreds of units. The FCC’s Broadband Serviceable Location (BSL) Fabric includes a unit_count for each location, which allows for analysis that accounts for this distinction.

Multi-dwelling units present unique deployment considerations. While serving a single MDU location can bring broadband to many households at once, the economics of MDU deployment differ from single-family homes. Factors such as building access, inside wiring, and landlord cooperation can impact deployment in ways that don’t apply to single-dwelling units (SDUs).

This analysis examines the MDU composition of both BEAD-awarded locations and remaining unfunded locations to provide context for ongoing discussions about broadband deployment priorities.

MDU Composition: BEAD Awards vs. Remaining Unfunded

Using the FCC’s Fabric (version 7) unit counts, we classified each location as either an MDU (more than 1 unit) or SDU (exactly 1 unit) and compared the two groups.

A few patterns are apparent:

• MDUs are a small share of locations in both groups (7.2% of BEAD, 8.6% of remaining), but a much larger share of units (19.7% of BEAD, 26.6% of remaining).
• The MDU unit share is higher among remaining unfunded locations (26.6%) than among BEAD awards (19.7%). This means that, when counting housing units rather than locations, a larger proportion of the unfunded gap is attributable to MDUs.
• In total, roughly 369,757 housing units in MDU buildings lack funded 100/20 Mbps service after accounting for BEAD awards and other funding programs.

MDU Size Distribution

MDUs range widely from a duplex up to large apartment buildings with hundreds of units. The table below breaks down MDU locations by unit count.

Among remaining unfunded MDUs:

• Small buildings (2–4 units) dominate by location count, making up 89.5% of MDU locations. These are often duplexes, triplexes, and fourplexes that may face deployment challenges similar to SDUs.
• Large buildings (100+ units) are few but contain many units. Just 80 locations with 100+ units account for 48,588 units, more than any other size category except 2 to 4.

Service Level of Areas Around Remaining Unfunded MDUs

A useful way to contextualize remaining unfunded MDUs is to analyze the level of service in the area immediately around them. In other words, are they in areas where nearby locations typically have service, or are they in largely unserved territory? To explore this, we examined the share of locations within approximately half a mile of each MDU that are served with 100/20 Mbps terrestrial service.

The table and chart below show housing units by MDU building size and neighborhood served share.

A couple of patterns stand out:

• Medium and Large MDUs are most often in well-served neighborhoods — 81% of Medium (5–25 unit) and 74% of Large (26+ unit) MDU housing units are in neighborhoods that are 80–100% served. For these buildings, broadband infrastructure may already be at the curb and might already be inside.
• Small MDUs are more evenly distributed across neighborhood types, with 63% of their units in mostly unserved or mixed service areas.

Methodology

This analysis uses the “including satellite BEAD” scenario from our updated remaining unfunded locations analysis. BEAD-awarded locations include all technology types, including satellite (technology code 61). Remaining unfunded locations are those in the BFM without 100/20 Mbps terrestrial service that are not covered by BEAD or another deployment program (after also excluding state “No BEAD” locations, except those marked as too expensive to serve).

Unit counts are drawn from the FCC’s Fabric version 7 active BSL data. Locations not matched to the Fabric are assigned a default unit count of 1.

Neighborhood service levels are estimated using the FCC’s National Broadband Map. For each remaining unfunded MDU, we identify all locations within approximately half a mile using H3 resolution-8 hex grid cells (covering the location’s cell plus its six immediate neighbors). The share of those locations with at least one provider reporting terrestrial 100/20 Mbps service defines the “neighborhood served %” for that MDU.

Data Sources

• Broadband Funding Map (BFM): FCC location-level funding data
• BEAD Final Proposal data: State-reported BEAD award and “No BEAD” location lists
• FCC Fabric version 7: Broadband Serviceable Location data with unit counts
• FCC National Broadband Map: Provider-reported availability data (June 2025)

Key Takeaways

• We use FCC and BEAD data to determine the relative size of service territory expansion that will be underwritten with federal grants. To do so, we calculate an ‘expansion ratio’ by dividing the number of BEAD awarded locations by FCC reported locations. This is equivalent to the percent expansion of a given ISP’s territory.
• Why does this matter? The goal of this analysis, the first in a series aimed at getting to know the BEAD subgrantees, offers essential context for understanding the scale of the awards won by ISPs of different sizes. Intuitively, ISPs with smaller expansion ratios may find it more manageable to build BEAD-funded networks given their experience. Conversely, ISPs with a higher expansion ratio may encounter difficulty in expanding their service territory at such a large scale since they lack the bona fides of more established providers.
• This dynamic has been evident in previous federal funding programs, notably RDOF, where some of the largest awards were rescinded by the FCC because of concerns about the ability of relatively small providers to greatly scale their networks. The ACLP discussed these concerns in a previous analysis focused on ensuring that prospective BEAD subgrantees were rigorously vetted prior to award.

Data Summary

Analysis Overview

After more than three years, BEAD grants finally appear to be poised for award by the 56 states and territories that received a proportionate share of the $42B+ available to bolster broadband availability. Some states, like Louisiana, have received all the necessary federal approvals to begin deploying these funds. NTIA continues to review and approve these awards on a rolling basis.

So, who won BEAD funds? The ACLP has parsed all available Final Proposal data and identified approximately 519 different subgrantees (when grouped by parent company). Many of the winners are familiar, but some are not, and some appear to be completely unknown.

The following analysis is the first in a series that we will publish on BEAD subgrantees. This analysis offers a straightforward look at the extent to which BEAD recipients will use their funds to expand their service territories. To do so, we calculate an expansion ratio as such:

An expansion ratio below 1 means the subgrantee will use BEAD funds to pass fewer locations than currently exist in its footprint. An expansion ratio above 1 means the subgrantee will use BEAD funds to more than double the size of their current footprint.

Why does this matter? In short, the following analysis provides essential context to understanding the scale of awards won by entities of different size. Many of the largest ISPs in the country won sizeable BEAD awards, but, per the analysis below, those funds will only expand their current service territory in a very marginal way. Conversely, numerous new or small ISPs have received BEAD awards that will subsidize deployments that will significantly multiply their current service territory. Subsequent analyses will offer additional information about these firms.

Intuitively, ISPs with smaller expansion ratios may find it more manageable to build BEAD-funded networks given give their experience and existing scale. Conversely, ISPs with a higher expansion ratio may encounter difficulty in expanding their service territory at such a large scale since they lack the bona fides of more established providers. Time will certainly tell whether this dynamic holds true. The ACLP will be closely watching.

Expanding 1% or Less

80 providers received a BEAD award 1% or less of their FCC footprint. Here are the top 10 by BEAD locations.

Expanding 1%–10%

201 providers received a BEAD award between 1% and 10% of their FCC footprint. Here are the top 10 by BEAD locations.

Expanding 10%–50%

85 providers received a BEAD award between 10% and 50% of their FCC footprint. Here are the top 10 by BEAD locations.

Expanding 50%–100%

18 providers received a BEAD award between 50% and 100% of their FCC footprint. Here are the top 10 by BEAD locations.

Expanding 100% or More

24 providers received a BEAD award exceeding their FCC footprint. Here are the top 10 by BEAD locations.

Unmatched Providers

108 providers couldn’t be matched to FCC data. Here are the top 10.

This includes new market entrants like Amazon Kuiper, but also likely reflects FCC Registration Number (FRN) mismatches between BEAD and FCC datasets, unmatched subsidiary companies, providers who haven’t filed availability data with the FCC, or other data issues.

Methodology

BEAD data comes from states’ BEAD Final Proposal files compiled by BroadbandExpanded and available here. FCC data comes from the National Broadband Map as of 2025-06-30.

States/territories included (54): AK, AL, AR, AS, AZ, CA, CO, CT, DC, DE, FL, GA, GU, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MP, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY

Providers are matched by FRN (FCC Registration Number). Each BEAD subgrantee may have multiple FRNs; these are matched against FCC data and aggregated. The expansion ratio is BEAD locations divided by FCC locations.

Providers with multiple subsidiaries sharing the same FCC provider ID are consolidated in the tables above.

Of note, the location counts in this post and in our report do not incorporate unit counts, and look only at raw Broadband Serviceable Location (BSL) counts as provided in BEAD Final Proposal data files and from the National Broadband Map.

Additional information, including tables of all ISPs included in the analysis, the states in which they will provide BEAD-funded service, and a detailed methodology is available in our PDF report.

Key Takeaways

• After canceling a $26M broadband grant in Cortland and Cayuga counties, New York is racing to reallocate those, and additional, federal funds through a new MIP Round 4 before the end-of-year CPF deadline.
• In January, Cortland County issued an RFP seeking a partner to apply for MIP Round 4 funding.
• An ACLP analysis of the Cortland County RFP data found that 93% of Top and Medium Priority locations and 99% of Low Priority locations already have 100/20 Mbps broadband service, consistent with the pattern of overbuilding seen in previous MIP rounds.
• ConnectALL has not provided updates on the status of any MIP projects, and with less than a year until the statutory completion deadline, it remains unclear whether these networks are on track for completion.

Over the last several years, New York State has used over $210 million in federal Capital Projects Funds (CPF) to engage in massive overbuilding of private broadband infrastructure. In two previous analyses, the ACLP detailed the extent to which the state, via its Municipal Infrastructure Program (MIP), chose to use these resources to subsidize duplicative broadband infrastructure across huge swaths of the state. Specifically, the ACLP found that, of the 85,000+ locations to be passed by the 13 projects awarded MIP grants in rounds 1 and 2, 89% already have access to a broadband connection. The ACLP projected a similar rate of overbuilding for MIP grants allocated after round 2.

The state now appears on track to continue funding overbuilding as it races to meet an end-of-year deadline for completing projects built with CPF funds.

What’s Happening in Cortland

In December 2025, it was reported that ConnectALL, the state office administering the MIP, had canceled a $26M grant that was earmarked for broadband projects in Cortland and Cayuga counties. Apparently, the state did not have confidence that the project would be substantially complete by the end of 2026, the statutory deadline for CPF-funded projects.

On January 12, 2026, ConnectALL announced that “up to $36 million” in additional funding would be available in a new Round 4 of the MIP. Curiously, ConnectALL did not disclose that the funding being allocated in this round stemmed from the canceled Cortland/Cayuga project.

The next day, Cortland County issued an RFP seeking “partners to form a public-private partnership to expand broadband infrastructure countywide through New York State’s ConnectALL Municipal Infrastructure Program (MIP) – Round 4 reopened January 12, 2026.” The selected partner would join the county in formally applying for the funds available in MIP Round 4. (It is unclear if Cayuga County has taken similar steps.)

In its RFP, Cortland County identified “critical points of interest by priority (1-3) as well as unserved locations as provided by the ConnectALL office” that it wished to connect with MIP grant funds.

The ACLP sought to determine the extent to which these locations might already be served with broadband. To do so, we started with the geographic data files provided in the county’s January 2026 broadband RFP. These show the various “Top,” “Medium,” and “Low Priority” parcels (properties) which the project seeks to serve. These parcels were then merged with data from the FCC’s National Broadband Map to determine what proportion of locations (i.e., buildings) on those parcels already have access to 100/20 Mbps or faster terrestrial broadband service. The results of this analysis are summarized in Table 1.

Overall, 93% of Top and Medium Priority and 99% of Low Priority locations are already served. These findings are consistent with the significant overbuilding underwritten by ConnectALL with MIP funds. In contrast, only 37% of the “BEAD Program Points” which were included in the RFP data files are already served, a much lower rate of overbuilding. The full results of this analysis, along with a detailed methodology, are available in our full report.

What’s Next

Only one entity – Archtop Fiber – responded to the Cortland RFP. Per that response, Archtop is “in the midst of an aggressive, 3,000-mile fiber-optic construction push to provide broadband across the Hudson Valley, including Sullivan County.” Indeed, Archtop previously secured nearly $30M in MIP funds to “serve over 22,000 homes and businesses with 253 miles of fiber and fixed wireless on twelve towers” in Sullivan County. According to our analysis of that award, Archtop’s project in Sullivan County will overbuild 91% of those locations.

Whichever entity ultimately wins the available Round 4 MIP funding will have less than a year to complete its deployment. More broadly, it remains to be seen whether any of the MIP projects are on track to meet the statutory deadline for substantial completion. ConnectALL has not provided any updates on the status of these networks. Its inability or unwillingness to publicly acknowledge that it terminated the Cortland/Cayuga award does not inspire confidence that it will be forthcoming if additional projects are struggling or appear unable to meet the December 31 deadline.

Key Takeaways

• Cal Advocates’s estimate of “consumer harm” is built on unrealistic assumptions. The calculation treats every location as a subscribing household buying gigabit service at the highest promotional price. In reality, many subscribers choose lower (and cheaper) tiers, some households don’t subscribe, and some locations are vacant. When the report’s own regression coefficients are applied to actual subscribers, the implied figure falls below $93 million, less than one-tenth of the headline claim, and even that number is suspect given the many other methodological issues.
• Cal Advocates uses an outcome-driven model to yield supportive results. It chooses benchmark and monopoly prices to maximize the competitive “gap” between markets with and without multiple gigabit providers. The “competitive” benchmark uses the lowest promotional prices across multiple speed tiers, while the “monopoly” price uses each provider’s highest 1 Gbps promotional price—an apples-to-oranges comparison that inflates the claimed harm.
• The study’s own results undermine its conclusions. The models yield wildly inconsistent results across providers. If competition were a uniform driver of pricing, we would expect more consistent patterns. Sub-gigabit providers are associated with higher prices in several statistically significant models, the opposite of what a competition story would predict. And Comcast, one of the four major providers studied, was excluded from the regression because its pricing didn’t fit the model. More fundamentally, the analysis shows correlation, not causation. Without a more rigorous research design, one cannot conclude that competition caused the observed price differences.
• The policy recommendations outrun the evidence. Subsidizing new gigabit builds in areas that already have one gigabit provider is classic overbuilding, which is wasteful and not the highest-value use of limited broadband funds.

Overview

In January 2026, the California Public Utilities Commission’s Public Advocates Office (“Cal Advocates”) released a report examining broadband competition and pricing in four California cities: San Mateo, Oakland, Los Angeles, and San Diego. (Public Advocates Office 2026a) The headline finding was attention-grabbing: “Californians could save more than $1 billion annually if competitive pricing prevailed statewide.” (Public Advocates Office 2026a, 4)

The report makes an appeal to intuition. Where multiple gigabit providers compete, promotional prices are lower. Where a single provider dominates, prices are higher. Therefore, policies should support additional gigabit network builds. (Public Advocates Office 2026a, 5, 19)

However, a careful review of the study’s methodology reveals significant problems. The $1 billion figure rests on inflated assumptions, apples-to-oranges price comparisons, and a calculation that is disconnected from the report’s own statistical models. When applied consistently, those models imply a figure less than one-tenth as large. The report’s own regression results, provided in the technical appendices, show that competition explains only a small fraction of price variation. (Public Advocates Office 2026b, 13–15) And the statistical analysis demonstrates correlation but cannot establish causation.

This post walks through the key methodological concerns. The goal isn’t to dismiss the fundamental economic principle that competition leads to lower prices, but to highlight why the magnitude of the study’s claimed harm is overstated and the policy conclusions are premature. Notably, these methodological shortcomings echo those we identified in an earlier set of broadband studies submitted to the CPUC, which similarly relied on selective data, narrow technology-specific framing, and outcome-oriented analysis to support sweeping policy conclusions. (Santorelli and Karras 2021, 23–33)

A Lofty $1 Billion Estimate

The report’s primary attention-grabbing claim is that California consumers could save $1.13 billion annually if gigabit competition prevailed. This number appears in Table 5 and drives the report’s policy urgency. (Public Advocates Office 2026a, 18) But the calculation involves several assumptions, each of which inflates the final figure.

Weak Regression Results

Notwithstanding the myriad other issues with the analysis, the study’s own regression results are inconsistent.

The technical appendices provide the actual regression output, (Public Advocates Office 2026b, 13–15) and the results are weaker than the main report’s confident policy assertions suggest.

Correlation Is Not Causation

The report’s regression analysis purports to show that the number of gigabit providers is correlated with lower promotional prices. (Public Advocates Office 2026a, 14–15) But the report then draws causal inferences that the methodology cannot support.

Promotional Prices Are the Wrong Metric

The entire analysis is based on promotional prices, which raises several concerns: (Public Advocates Office 2026a, 11)

Other Methodological Concerns

• Frontier’s Exclusion. Frontier, a major fiber competitor, was excluded from the pricing analysis “due to its ongoing merger with Verizon.” (Public Advocates Office 2026a, 6) But Frontier appears as a meaningful competitive presence in the overlap tables: 80% of Charter’s lowest-priced tier in LA has Frontier overlap. (Public Advocates Office 2026b, 8–9) The merger doesn’t change the fact that Frontier’s current network presence affects competitive dynamics, and its exclusion may bias the report’s modeling. Moreover, the rationale is applied inconsistently: Charter and Cox—two of the three providers included in the regression—are themselves in a pending merger, yet neither was excluded on those grounds.

• Sampling Methodology Is Undisclosed. The appendices reveal sample sizes but not selection methodology. (Public Advocates Office 2026b, 2–3) Were locations chosen randomly? Stratified by neighborhood characteristics? Convenience-based? The phrase “selected sample locations” does significant work but is never explained. (Public Advocates Office 2026a, 8)

• The 10% Overlap Threshold. Appendix B excludes competitors with less than 10% geographic overlap as not representing “meaningful competitive pressure.” (Public Advocates Office 2026b, 4–11) This is an arbitrary threshold that could omit localized competitive effects.

• Excel-Based Regression With Apparent Errors. The regression tables show #NUM! errors and suspicious values (like standard errors of exactly 0) in several cells. (Public Advocates Office 2026b, 13–15) These errors, along with the table formatting, suggest the analysis was conducted in Excel rather than a proper statistical package. For a study of purported policy significance, the use of Excel raises concerns about, among other things: robustness checks, diagnostic testing, correct standard error specification, and reproducibility.

• Contradictory Overlap Patterns. The appendix reveals that some pricing patterns contradict the assertion that more competition brings about lower prices. For instance, Comcast’s lower-priced set in San Mateo shows less competitive overlap than its higher-priced set, and AT&T’s San Mateo pricing requires a “concentration” explanation rather than the simple provider counts used in the regression. (Public Advocates Office 2026b, 4–7)

Policy Implications

The report recommends that public investments “prioritize areas where consumers have only one gigabit provider.” (Public Advocates Office 2026a, 5, 19) This conclusion requires believing that:

• Correlation between provider counts and prices reflects causation (unproven)
• Promotional prices reflect sustained consumer welfare (questionable)
• Conditions enabling multiple providers in San Mateo can be replicated elsewhere (not analyzed)
• Subsidizing additional gigabit builds is higher-value than other uses of limited funds (not analyzed)

More broadly, the report’s exclusive focus on gigabit provider counts reflects a technology-specific view of competition that ignores the role of other platforms. Fixed wireless, 5G, and satellite services all exert competitive pressure, and consumers increasingly rely on non-wireline options for internet access. A technology-neutral assessment of competition would likely paint a different picture than one that counts only gigabit wireline providers. (Santorelli and Karras 2021, 37–38)

Key Takeaways

• According to the FCC’s Broadband Funding Map, 3,379,711 locations across the U.S. are currently without 100/20 Mbps terrestrial service.
• After accounting for BEAD awards, 1,101,356 locations without 100/20 Mbps service remain unfunded. When the number of units at a location is factored in (e.g., apartment units in a building), 1,342,667 units remain unfunded.
• Of the remaining unfunded locations, approximately 53.8% are “underserved” (have 25/3 Mbps service but not 100/20 Mbps).
• According to BFM data, 33.7% of BEAD locations already have 100/20 Mbps terrestrial service (wired or fixed wireless), suggesting that BEAD may involve overbuilding beyond the 20% allowed for in the program rules.
• This updated analysis underscores the need for a BEAD Reserve Fund, which the ACLP first proposed last October. Using remaining BEAD dollars to seed a Reserve Fund and deploying those resources as part of a second round of BEAD would ensure that the goal of the program is realized: that as many unserved and underserved locations as possible receive broadband service via BEAD.

Overview

This analysis estimates the number of broadband serviceable locations (BSLs) without 100/20 Mbps terrestrial service that remain unfunded by any program even after accounting for BEAD awards.

Updated Methodology

To identify locations that could be eligible for a second round of BEAD we:

1. Start with the FCC’s Broadband Funding Map (BFM), which provides a pre-computed list of locations that are unserved or underserved.
2. Set aside any location that is funded by another deployment program using the BFM’s award data from 5 federal entities spanning 15 broadband deployment programs.
3. Set aside locations which were intentionally not given a BEAD award by states, as identified in Final Proposal “No BEAD” data. These exclusions happened for a variety of reasons; we set aside all except those marked as ‘too expensive to serve.’
4. Count how many unserved/underserved locations that are currently unfunded will be covered by BEAD, and how many will remain.

This process differs slightly from our previous analysis, which manually identified unserved locations from National Broadband Map availability data. Since the pre-computed BFM location lists are generated by the FCC, we now utilize those lists instead of performing this portion of the analysis on our own.

Remaining Unfunded Summary by State

Current Status of BEAD Funded Locations

We compare the BFM locations against BEAD Final Proposal data compiled from 54 states and territories. We match BEAD award locations against the full BFM dataset to determine their current service status:

• 55.2% of BEAD locations are without 100/20 Mbps (both residential and business terrestrial service is not available)
• 33.7% have residential, business, or both types of terrestrial 100/20 Mbps service, or faster
• 11.1% do not match to any BFM location

Terrestrial includes wired, licensed, and unlicensed fixed wireless. If the definition of service is narrowed, the percentage of BEAD locations that are already served per BFM data decreases:

• 33.7% have terrestrial 100/20 Mbps (wired + all fixed wireless)
• 24.1% have wired or licensed fixed wireless 100/20 Mbps
• 5.5% have wired 100/20 Mbps

Regardless of what definition is used, it appears that BEAD deployments will involve some overbuilding of already served locations.

Key Takeaways

• We analyzed GIS data for 7 of the 14 projects that applied for funding as part of the $200M Texas Middle-Mile Grant Program. The other 7 projects did not provide GIS data necessary for this type of analysis.
• We found that 98.0% of locations within 1 mile of the proposed network routes already have access to terrestrial broadband at 100/20 Mbps or faster. This suggests the routes primarily traverse well-served corridors.
• This finding is consistent even when the distance from the route is increased to 5 miles (98.1%) or 10 miles (98.1%). This further underscores how well-served these corridors are.
• Program rules require applicants to “make all efforts possible to avoid overbuilding where existing middle-mile infrastructure already exists.” The state has made clear that it will prioritize projects that complement rather than duplicate existing infrastructure. That half of the proposals would significantly overbuild existing infrastructure appears to contravene the program’s focus.
• As the ACLP has noted extensively elsewhere, using public funds to overbuild existing middle-mile and last-mile infrastructure is wasteful and should be avoided lest these duplicative networks fail to attract enough customers to financially self-sustain. Officials in Texas and anywhere else that might be contemplating a similar program should study the myriad struggles and failures that have arisen when publicly-funded middle-mile networks overbuilt private infrastructure.

This post provides a summary of our full report, which includes a detailed methodology, and by-project estimates of served percentages.

TMM Overview

The Texas Middle-Mile (TMM) program, which is being administered by the state’s Broadband Deployment Office, is a $200M grant program that seeks to “strengthen network resiliency, support open-access networks to increase affordability for end-users and improve high-speed internet access by reducing the cost of connecting unserved or underserved areas to the internet backbone.”

Applications were accepted between August and November 2025, and the state released data submitted by applicants regarding network routes in January 2026.

Analysis

Using middle-mile network route data from applicants, we compiled a list of broadband serviceable locations within approximately 1 mile of the routes. We then utilized data from the National Broadband Map to determine which of these locations are already served.

On aggregate, 98.0% of locations within 1 mile of the proposed network routes already have access to terrestrial broadband at 100/20 Mbps or faster. This suggests the routes primarily traverse well-served corridors. Our finding is consistent even when the distance from the route is increased to 5 miles (98.1%) or 10 miles (98.1%). This further underscores how well-served these corridors are. Per-project estimates are in our full report.

Unfortunately, only 3 out of the 10 applicants, covering 7 out of 14 projects, provided data in a format allowing for geographic analysis. The other 7 applicants/projects provided only PDF documents containing images of their routes and are thus excluded from the analysis.

We expect that most other applications would yield similar results if we had access to geographic data. For example, the city of Brownsville recently submitted an application for funding to help it expand its burgeoning municipal fiber network to serve adjacent areas. That proposal will likely yield significant overbuilding.

Program rules require applicants to “make all efforts possible to avoid overbuilding where existing middle-mile infrastructure already exists.” The state has made clear that it will prioritize projects that complement rather than duplicate existing infrastructure. That half of the proposals would significantly overbuild existing infrastructure appears to contravene the program’s focus.

As the ACLP has noted extensively elsewhere, using public funds to overbuild existing middle-mile and last-mile infrastructure is wasteful and should be avoided lest these duplicative networks fail to attract enough customers to financially self-sustain. Officials in Texas and anywhere else that might be contemplating a similar program should study the myriad struggles and failures that have arisen when publicly-funded middle-mile networks overbuilt private infrastructure.

Background

Launched as a full FTTH system, the Lawrenceburg Municipal Utilities project represented one of Indiana’s first small-city fiber deployments. Despite significant capital investment, the network did not achieve a subscriber base large enough to offset operating and debt-service costs. Financial problems persisted for several years, and in 2020, the Indiana State Board of Accounts issued an audit finding that LMU had failed to account for losses associated with the fiber initiative, including misstated or unreported expenditures tied to the broadband project.

The audit revealed that the fiber network contributed to significant financial discrepancies within the utility, prompting increased scrutiny from both state auditors and local officials. These findings reinforced the city’s growing concern that the municipal broadband model was fiscally unsustainable for a system of Lawrenceburg’s size.

Failure and Transfer to Private Sector

Unable to resolve the ongoing financial issues or scale the network to profitability, Lawrenceburg eventually sought a private sector exit. In December 2022, the city announced it would sell its FTTH system to Altafiber (formerly Cincinnati Bell) for $3 million, transferring both ownership and operational responsibility to the private ISP.

The sale represented a substantial loss relative to the city’s original $10 million investment, underscoring the severity of the project’s financial underperformance. Altafiber noted that it would assume management and future expansion to the city’s fiber network, integrating it into the company’s regional infrastructure plans.

Takeaways

The Lawrenceburg network case illustrates several key challenges for municipal broadband:

1. Financial Instability – The project led to an accumulation of unrecoverable losses. The Indiana SBOA audit showed that broadband expenditures were not properly accounted for, revealing systemic fiscal management and highlighting the risk that small municipalities face when operating capital-intensive utilities without sufficient financial controls.
2. Insufficient Subscriber Base – Despite the high cost of deploying a citywide FTTH system, LMU failed to attract enough customers to cover operational expenses. As Local12 reported, the project was losing significant amounts of money even before the city explored a sale.
3. Below-Cost Divestiture – The ultimate sale of the system for $3 million, compared to the $10 million invested, demonstrates how much municipal broadband projects can expose taxpayers to long-term financial losses when adoption and revenue targets are not met.

Arianna is a 3L at New York Law School.