Unpacking Approved BEAD Volume 2s: Iowa
NTIA recently approved Iowa’s Initial Proposal Volume 2. The ACLP compared the final version with the initial version the state released for public comment last fall (it did not post a post-comment version online). A redlined comparison is available here. The following changes were evident:
Subgrantee Selection Process
Scoring - Fair Labor Practices
The state adjusted its criteria, consistent with other states, to provide new entrants with a means of receiving full points by making forward-looking commitments for adhering to relevant labor laws.
Climate Assessment
The state included additional climate-mitigation planning requirements, specifically:
“Applicants will be required to submit climate resilience plans as part of the Supplemental Data Collection Phase outlined in Section 1.8.8. of the NOFA (Appendix A). Applicants will be required to utilize the tools provided to determine any potential climate-related impacts to their proposed project areas and complete an initial hazard screening. Utilizing the DNR PERMT system, specifically addressed in Section 2.2.6.11. of the NOFA (Appendix A), will be required for applicants as part of the submission process. DOM believes that flooding is the most significant threat statewide, and the PERMT system addresses floodplain management. Although flooding can be a factor statewide, DOM has identified the following counties for the potential significant risk of flooding: Des Moines, Lee, Muscatine, and Scott. Possible mitigation measures include location of facilities vulnerable to flooding, waterproofing of facilities, redundancy, diverse routing, and disaster recovery plans. The hazard screenings will be reviewed during the subgrantee selection process and the climate resilience plans will be monitored for compliance during defined monitoring periods.”
Low-Cost Option
The state maintains its $40/month price-point but, in response to public comment, has created “a waiver process that would allow for a low-cost service option cost of up to $70 per month provided the applicant submits a justification outlining the need for a low-cost service option price above $40 specifically in an effort to ensure 100% coverage of unserved locations in Iowa by attempting to include hard to reach areas in their proposal.”
Also of note is this bit of insight into Iowa’s curing process and NTIA’s focus on “affordability”:
“…in the last round of curing comments from NTIA, the reviewer required that the State,”Provide a justification for proposing a low-cost service option where the end-user cost is greater than $0.” In alignment with the above comments, the State believes that it would be beyond its authority to require providers to convey service for free to a qualifying population, as this amounts to imposing an unfunded mandate running for the useful life of the network. The State of Iowa does not have its own broadband subsidy program, meaning that establishment of a no-cost broadband service option is unattainable.”