Unpacking Approved BEAD Volume 2s: Florida
NTIA recently approved Florida’s Initial Proposal Volume 2. The ACLP compared the final version with the version submitted by the state to NTIA last fall. A redlined comparison is available here. The following changes were evident:
Low-Cost Option
Until approval of its V2, Florida was the last state to set a price for the low-cost option. With approval of its V2, Florida joins the handful of other states before it (GA, MO, MT, SC, and VA) to submit to NTIA pressure to set a price for the option.
In its approved V2, Florida documents its discontent in having to do so, noting that it “philosophically disagrees with the NTIA’s position that rate requirements are not rate setting.” Even so, the state “has worked diligently to find a data-driven solution that meets the NTIA’s requirements, improves the potential for companies to participate in the program and serves all Floridians.”
The option price in Florida will be set by a formula, which “stipulates that the annual cost of the state’s low-cost plan should not exceed 2% of the average of the state’s second and third-quintile household income means for family of three. This value is then divided by 12 to determine the monthly price for the state’s low-cost plan.”
Waivers are available upon a showing that the option price is unsustainable, but “the waiver cannot propose a monthly cost, inclusive of all taxes, fees, and charges, that exceeds the average for the applicable year’s average monthly rate for Internet services as published by the https://data.bls.gov/timeseries/CUUR0000SEEE03?output_view=data U.S. Bureau of Labor Statistics.”
Subgrantee Selection Process
Scoring - Minimal BEAD Outlay
The state made significant adjustments to the primary criteria in its scoring rubric. The number of points available in this category increased from 260 to 320. In terms of allocating points, the state will do so relative to the total amount of BEAD funding requested rather than relative to the size of the match. The new standard takes into account both the total projected cost to build the network and the match percentage. The applicant with the lowest proposed cost will receive max points, and all others will be scored relative to that amount.
Scoring - Affordability
The number of points in this category was reduced from 60 to 30. Allocation remains the same, with the lowest cost for symmetrical gig receiving max points and all others receiving fewer points relative to that amount.
Scoring - Fair Labor Practices
The number of points in this category was reduced from 40 to 30. Experienced subgrantees will receive up to 6pts each for plans to comply with relevant laws, disclosure of past violations (for subgrantee and subcontractors), wage information, and provision of workplace safety committees. New entrants must only provide a plan to ensure compliance with relevant state and federal employment laws to receive full points.
Scoring - Secondary Criteria
The state made several adjustments to these criteria, including:
- Awarding 30pts for Speed to Deployment by awarding 10pts each for (1) completion within two years, (2) providing a detailed plan for meeting that deadline, and (3) identification of risks and mitigation plans.
- For Meeting Prior Federal Commitments, entities without any commitments will receive full points, as will entities with RDOF commitments who have broken ground on them. Entities with RDOF commitments that have not broken ground on those projects will not receive any points.
Scoring - Non-Priority Projects
The state adjusted the scoring for these projects to align with the rubric for priority projects.
Project Areas
The state will use Census tracts to create PAs. Per the approved V2, “A combination of multiple census tracts may make up a project area so that the areas are large enough to avoid selective applications that avoid difficult-to-reach locations, but small enough to encourage small providers who may not have the operational reach to cover a large geographic space.”