Unpacking Approved BEAD Volume 2s: Kentucky


Michael Santorelli


June 25, 2024

NTIA recently approved Kentucky’s BEAD Initial Proposal Volume 2 (V2). The ACLP has compared the final version with the version that the state submitted to NTIA. A redlined version is available here. The following identifies changes made to the state’s V2 ahead of NTIA’s approval:

Subgrantee Selection Process

Scoring – Fair Labor Practices

Like other states that have cured their V2s, Kentucky provided additional discussion about how it will allocate points to new entrants. Unlike many other states, KY made clear that new entrants that are unable to provide evidence of previous compliance with applicable labor laws will receive zero points. All applicants will be able to receive up to 5 points for plans for future compliance with these laws.

Scoring – Speed to Deployment

Previously, the state planned to award full points (2) to applicants that committed to building networks within 4 years. Now, full points will go to applicants that commit to building them in 2 years; 1.5pts will go to building commitments of 3 years or less; 1 point will go to 4 years or less.

Scoring – Scalability of Technology

The state has split the 8pts available into five new subcategories: (1) Technology, where up to 4pts can be awarded to applicants that use XG-PON or better, and (2) Network Design, where up to 4pts will be awarded to projects that result in high density fiber with spare capacity, (3) Useful Life of Funded Infrastructure, where up to 4pts will go to proposals for networks with useful lives of 10+ years, (4) Speed and Latency Performance, with max pts going to projects of at least 1G/500M service with less than 100ms of latency, and (5) 1pt for applicants that adequately address the cost effectiveness of future scalability.

Low-Cost Option

The state has shifted course vis-à-vis its Low-Cost Option. Previously, the state defined low-cost option pricing relative to the FCC’s Urban Rate Study. Now, it has set the price for the option at $30/month, which aligns with the NTIA model plan. It will offer a waiver to applicants that can demonstrate that the $30/month price-point is financially unsustainable. If granted, the applicant can increase the low-cost option price to $65/month. The state might allow for price adjustments consistent with the CPI on an annual basis. Otherwise subgrantees must offer the low-cost option “for the duration of the federal interest” in the project (i.e., 10 years).