Unpacking Approved BEAD Volume 2s: Massachusetts

NTIA recently approved Masschusetts’s Initial Proposal Volume 2. The ACLP compared the final version with the initial pre-comment draft that the state released last fall (it did not release the version it submitted to NTIA). A redlined comparison is available here. The following major changes were evident:

Subgrantee Selection Process

Project Areas

The state has shifted its approach to setting PAs in Round 2. In Round 1, PAs will be set at the municipal level. In Round 2, the state will create PAs based on remaining un/underserved BSLs (previously, the state indicated that it would allow applicants to propose their own PAs).

Scoring - Minimal BEAD Outlay

The state switched to points from percentages in its approved V2; 200 total points are now available. For Minimal BEAD Outlay, up to 60pts will be available (65 for non-priority projects).

Scoring - Affordability

Previously, the state proposed evaluating proposals relative to a fixed price-point of $80/month for 1/1 Gbps service. In the final V2, the state has shifted and will award points for most affordable price by comparing proposals to the results of a pricing analysis.

Scoring - Fair Labor Standards

A max of 30pts will be available to applicants without a record of prior labor violations and who commit to adhering to relevant labor laws.

Scoring - Secondary Criteria

The state made a number of tweaks to these categories:

• Speed of Network - up to 10pts available for non-priority projects (up from 41.6%).
• Serving CAIs - up to 10pts will be available to applicants based on the number of CAIs served as part of the project.
• Open Access - the state removed this category from its rubric. Low-Cost Plans - up to 20pts will be available based on pricing comments for the low-cost option, with max points going to plans of $10/month or less.
• Serving MDUs at Enterprise Level - up to 10pts will be available to applicants that “commit to offering Enterprise Level Agreements, which is a single price that provides service to every unit within the MDU at a discounted rate

These shifts amount to the state placing more emphasis on labor standards (% of total points stemming from this category rose from 10% to 15%) and slightly less on BEAD Outlay and Affordability (% of total points stemming from each category decreased from 32.5% to 30%). Among secondary criteria, the Low-Cost Plan category saw the biggest increase in points, increasing from 5% of total points to 10% (it appears that this category absorbed the points from the eliminated Open Access category).

Scoring - Round Three (CAIs)

The state included a high-level overview of its rubric for Round 3.

Non-Deployment Uses

The state included significantly more information about how it will use remaining BEAD funds for non-deployment activities. Among other things, the state will seek to invest in digital equity activities and a variety of programs aimed at making broadband and Wi-Fi available in affordable housing, apartments, and rural areas.

Low-Cost Option

The state made only minor adjustments to the option parameters, revising it to reflect a post-ACP environment and clarifying that the $30/month price-point will remain.

Middle-Class Affordability Plan

The state removed mention of a separate “Middle-Class Broadband Service Option” and instead narrowed the focus to “Incentivizing Affordability Through Scoring,” noting that its “affordability scoring is aimed at incentivizing applicants to offer their most affordable services on BEAD funded networks for those households that do not qualify for the low-cost service option. This means that proposals emphasizing lower prices are rewarded with higher scores.”