Navigating the BEAD Weeds

These standalone documents provide in-depth discussion of discrete topics related to the BEAD program. A short summary and link to download a PDF copy are provided below for each Navigating the BEAD Weeds document.

Project Areas

November 2023


  • A key element of state BEAD grant programs is how states define their project areas. Project areas (PAs) are where ISPs will use BEAD funding to build new networks. PAs can be as small as a single location or as large as a county or Census tract.
  • States could allow applicants to define their own PAs. However, to date, most states have elected to dictate their own PAs by using a range of geographic unit systems that bear little, if any, relationship to existing networks. For example, some states are seeking to define PAs by using the pre-existing borders associated with Census Block Groups, county borders, or school districts, among others. This means that PAs in a state might encompass all unserved and underserved locations in a county or across a school district.
  • The analysis explores why states should select the most granular system that is administratively feasible. Higher levels of granularity – i.e., PAs that are as small as a single location – provide greater opportunity for efficient, targeted buildouts and gives the most flexibility to applicants both large and small.
  • States may believe that PAs that are very large, like those set at the county level, might be easier for them to administer, but in practice, large PAs might be too expansive – and expensive – for applicants to serve.
  • Using standardized, granular units from the Census Bureau, such as Census Blocks, to design PAs is probably the most efficient approach for states seeking off-the-shelf solutions.

Click here to download.

Maximizing Reach

February 2024


This analysis highlights the myriad ways in which states are attempting to ensure that BEAD funds go as far as possible vis-à-vis closing their digital divides. Some states have sought to address this issue by establishing very large BEAD project areas (PAs) and requiring subgrantees to serve every unserved and underserved location in those PAs. In the view of these states, a major upside of this approach is its simplicity since it will not require much effort to deconflict overlapping proposals. In practice, however, large PAs might prove daunting and impractical for many prospective applicants, an issue that the ACLP tackled in its previous BEAD Weeds installment on PAs.

In response, several states have adopted novel approaches to stretching BEAD funds as far as they can go that involve smaller PAs. These approaches include Alternative Percentages, which allow applicants to propose serving less than 100% of a PA; a variety of Deconfliction techniques, many of which allow applicants to sever overlapping locations from their proposals; and ways to address Leftover and No-Bid locations. This analysis examines these approaches and identifies several best practices that states and NTIA might embrace as Initial Proposals are finalized and BEAD programs begin to roll out.

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Vetting Subgrantees

March 2024


This analysis examines the tiered approach to vetting prospective BEAD subgrantees developed by NTIA and adopted by the states.

As an overview, the analysis:

  • Details how NTIA, through its guidance and waivers, has allowed for the creation of a tiered approach to vetting prospective BEAD subgrantees. Experienced ISPs will be subject to rigorous screening, while less experienced entities with little or no track record in the broadband space will have a much lower bar to clear.
  • Highlights how, in practice, this tiered approach resembles the flawed vetting procedures used during previous federal broadband funding programs.
  • Offers recommendations to NTIA and the states for bolstering vetting processes for inexperienced applicants, streamlining the process for established ISPs, and otherwise amending the screening criteria to prevent another LTD debacle.

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In-Kind Contributions

June 2024


This analysis closely examines the issue of in-kind contributions for use in BEAD, in light of an absence of federal guidance specific to the program.

As on overview, the analysis:

  • Porvides a high-level examination of in-kind contributions.
  • Unpacks the rules governing them.
  • Identifies examples of potentially allowable in-kind-contributions in BEAD.
  • Highlights a range of considerations and open issues that applicants should account for when determining whether to include a contribution in their application.

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