Analysis of Texas Middle-Mile Applications Finds Evidence of Significant Overbuild

Analysis of half of project applications to the TMM program found that 98% of locations within a mile of network routes are already served. This finding is consistent at 5 and 10 miles from the routes.

Key Takeaways

• We analyzed GIS data for 7 of the 14 projects that applied for funding as part of the $200M Texas Middle-Mile Grant Program. The other 7 projects did not provide GIS data necessary for this type of analysis.
• We found that 98.0% of locations within 1 mile of the proposed network routes already have access to terrestrial broadband at 100/20 Mbps or faster. This suggests the routes primarily traverse well-served corridors.
• This finding is consistent even when the distance from the route is increased to 5 miles (98.1%) or 10 miles (98.1%). This further underscores how well-served these corridors are.
• Program rules require applicants to “make all efforts possible to avoid overbuilding where existing middle-mile infrastructure already exists.” The state has made clear that it will prioritize projects that complement rather than duplicate existing infrastructure. That half of the proposals would significantly overbuild existing infrastructure appears to contravene the program’s focus.
• As the ACLP has noted extensively elsewhere, using public funds to overbuild existing middle-mile and last-mile infrastructure is wasteful and should be avoided lest these duplicative networks fail to attract enough customers to financially self-sustain. Officials in Texas and anywhere else that might be contemplating a similar program should study the myriad struggles and failures that have arisen when publicly-funded middle-mile networks overbuilt private infrastructure.

This post provides a summary of our full report, which includes a detailed methodology, and by-project estimates of served percentages.

TMM Overview

The Texas Middle-Mile (TMM) program, which is being administered by the state’s Broadband Deployment Office, is a $200M grant program that seeks to “strengthen network resiliency, support open-access networks to increase affordability for end-users and improve high-speed internet access by reducing the cost of connecting unserved or underserved areas to the internet backbone.”

Applications were accepted between August and November 2025, and the state released data submitted by applicants regarding network routes in January 2026.

Analysis

Using middle-mile network route data from applicants, we compiled a list of broadband serviceable locations within approximately 1 mile of the routes. We then utilized data from the National Broadband Map to determine which of these locations are already served.

On aggregate, 98.0% of locations within 1 mile of the proposed network routes already have access to terrestrial broadband at 100/20 Mbps or faster. This suggests the routes primarily traverse well-served corridors. Our finding is consistent even when the distance from the route is increased to 5 miles (98.1%) or 10 miles (98.1%). This further underscores how well-served these corridors are. Per-project estimates are in our full report.

Unfortunately, only 3 out of the 10 applicants, covering 7 out of 14 projects, provided data in a format allowing for geographic analysis. The other 7 applicants/projects provided only PDF documents containing images of their routes and are thus excluded from the analysis.

We expect that most other applications would yield similar results if we had access to geographic data. For example, the city of Brownsville recently submitted an application for funding to help it expand its burgeoning municipal fiber network to serve adjacent areas. That proposal will likely yield significant overbuilding.

Program rules require applicants to “make all efforts possible to avoid overbuilding where existing middle-mile infrastructure already exists.” The state has made clear that it will prioritize projects that complement rather than duplicate existing infrastructure. That half of the proposals would significantly overbuild existing infrastructure appears to contravene the program’s focus.

As the ACLP has noted extensively elsewhere, using public funds to overbuild existing middle-mile and last-mile infrastructure is wasteful and should be avoided lest these duplicative networks fail to attract enough customers to financially self-sustain. Officials in Texas and anywhere else that might be contemplating a similar program should study the myriad struggles and failures that have arisen when publicly-funded middle-mile networks overbuilt private infrastructure.