Unpacking Approved BEAD Volume 2s: West Virginia


Michael Santorelli


May 14, 2024

NTIA recently approved West Virginia’s BEAD Initial Proposal Volume 2 (V2). The ACLP has compared the final version with the version that the state submitted to NTIA for review (the state did not post a “cured” draft). 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 Changes

For priority projects, the state has changed how many points it will award in several categories:

  • Speed to Deployment will now receive up to 10 points, rather than 15.
  • Demonstrated Community Impact and Support will receive up to 20 points, rather than 15.
  • Resiliency and Scalability will receive up to 20 points, rather than 15.

Incentivizing Match

The state has added a requirement to it subgrantee selection process. If no applications are received for un/undeserved locations, then the state will require applicants with existing fiber or cable networks that are nearby or that overlap with these areas to accept an additional 20% of grant funding to extend those networks to serve those locations. The state indicates that it will not force applicants to build these extensions if it would exceed their capacity.

Use of Funds for Non-Deployment Purposes

In its submitted V2, the state indicated that it was planning to use $60M in BEAD funding for “the Permits and Licensing Coordination and Capacity Initiative and Workforce Development Program.” In its approved V2, the state has removed this commitment of funds.

Match Requirement

In its submitted V2, the state proposed requiring applicants to commit a match of $500/location. In its approved V2, the state has aligned the match requirement with NTIA guidance, i.e., a straightforward 25% match. However, the state “may waive a portion of the match that is proportionate to the number of Target Locations that fall within High-Cost areas.”

Non-Deployment Subgrantee Selection Process

The state adjusted various aspects of its selection criteria for applicants seeking non-deployment grants.

Low-Cost Option

The state retained its $50 price-point and increased the length of time subgrantees must offer it (10 years, up from 8 years).

The state rewrote its justification for setting the price-point at $50. It also added that “it acknowledges that [the FCC’s 2% benchmark, which it used to set the price-point] is not a perfect measure of affordability but can be used as one of many assessment tools.”

Use of 20% of Funding

As noted above, the state indicated in its approved V2 that it will not use $60M in BEAD funding for a licensing program or a workforce initiative. Even so, the state will use “a limited portion of BEAD funds to provide state and local government agencies a temporary surge of broadband deployment permits and licensing staffing capacity for the length of the [BEAD] program…” It will also use a portion of its administrative funds to “set up and run” a subgrantee selection process for workforce development “without awarding funds.”