Unpacking Approved BEAD Volume 2s: Utah

NTIA recently approved Utah’s Initial Proposal Volume 2. The ACLP analyzed Utah’s approved BEAD Volume 2 by comparing it with the most recent cured version that the state released on June 19. A redlined comparison is available here. The ACLP did not identify any additional major changes made by the state.

Below is a summary of changes made by the state in the cured draft vis-à-vis the draft it initially submitted to NTIA in the fall.

Subgrantee Selection

Registration and Pre-Application

The state provides more details about how the pre-application will play out, the requirements, etc.

Project Areas

The state has changed how it will define its PAs. Initially, it said it would use Census Block Groups; now, it says it will use Census Blocks.

Additional Obligations

Utah is one of the first states we’ve seen include the array of service obligations included in the BEAD NOFO but absent from most subsequent guidance documents. In particular, Utah has added the following NOFO requirements for BEAD-funded networks to its V2:

• No data caps or unjust/unreasonable network management practices
• Provide broadband to each customer in the service area on reasonable and non-discriminatory terms and conditions
• Subgrantees must carry out public awareness campaigns in the service area to promote adoption
• Adhere to interconnection and wholesale access middle-mile requirements (from NOFO p. 66)

NTIA recently captured these and other requirements in a BEAD Terms and Conditions document that will apply to all subgrantees.

Scoring – Fair Labor

The state has adjusted how it will allocate points. In particular, it has shifted to a category-based system where applicants can receive 5 points for certifying compliance with all applicable labor laws; 2pts for a record of compliance with federal laws; 1pt for disclosing labor violations from the last 5 years; 1pt for disclosing violations by sub/contractors from the last 5 years; 0.5pts for wage information; and 0.5pts for workplace safety policy.

Scoring – Secondary Criteria

The state made several tweaks to these criteria, including:

• Reducing the number of points from 7 to 6 for Local Coordination
• Increasing the number of points from 6 to 7 for Community Impact

Low-Cost Option

The state edited this section significantly, adding in additional research and data points to supports its requirements. This yielded some small but important adjustments, namely an increase in the low-cost price-point in rural areas from $55/month to $60/month.