BEAD Project Areas Analysis


Michael Santorelli, Alex Karras


November 18, 2023

The ACLP at New York Law School has released an analysis of states’ proposals for setting the Project Areas that they will use as part of the BEAD grant process.

The Project Area (PA) issue is of central importance to the successful deployment of state grant programs. Project areas that are too big (e.g., those set at the County-level) could disincentivize participation by ISPs by making it exceedingly diffcult – and expensive – to serve every eligible location in the PA. Smaller PAs, on the other hand, like those set at the individual location or Census Block level, appear better positioned to assure robust participation by established ISPs. In addition, for ISPs considering participation in BEAD programs in multiple states, a lack of consistency in defining PAs could greatly increase compliance costs and discourage applications in some instances.


The ACLP’s analysis:

  • Summarizes the myriad of approaches to designing PAs that are evident across the country. To date, of the 48 states that have released a Volume 2 and thus indicated how they will design their PAs:
    • 6 states will permit applicants to propose their own PAs
    • 19 states will use established geographics units (e.g., county or muni boundaries; Census Block Groups) to set their PAs
    • 17 states will use an alternative approach (e.g., school district boundaries; a custom design)
    • 6 states are still deciding and will rely on public comments to inform their decision
  • Identifies the often-conflicting factors that influence a state’s approach to setting PAs. These factors include a desire to achieve universal service; balancing a need for achieving some measure granularity in setting PAs to assure consistency in density and geographic characteristics with practical concerns about efficiently administering the BEAD program; and achieving a level of meaningfulness in the establishment of PAs (rather than just dividing a state into a grid of equally sized squares).
  • Surveys the array of “off-the-shelf” geographic units devised by the Census Bureau that are being used in many states across the country. This section provides graphics to depict the impact of choosing, say, PAs defined by Census Blocks versus County borders on the number and density of eligible locations to be served.
  • Concludes that the best approach to designing PAs that will encourage robust ISP participation and assure some measure of consistency across the country is to focus on smaller project areas.

Michael Santorelli is the Director of the ACLP. Alex Karras is a Senior Fellow at the ACLP.