Unpacking Approved BEAD Volume 2s: California

NTIA recently approved California’s Initial Proposal Volume 2. The ACLP compared the final version with the Proposed Final released in late August. Analysis of that draft, which compared it with the version submitted by the state to NTIA, is included below.

Our analysis of the Proposed Final highlighted most of the major changes made by the state to its V2; the additional analysis below of the approved V2 identifies a couple of clarifications included in the V2 by the state in the last few weeks. A redlined version of the comparison of the final V2 and the Proposed Final is available here. The added clarifications were in the Low-Cost option section:

Low-Cost Option

The state made two clarifications in this section. First, “Subgrantees may apply increases in price after at least 12 months not to exceed the Consumer Price Index for All Urban Consumers (CPI-U) 12-month percentage point change for the “All Items” category, published by the U.S. Bureau of Labor Statistics. Existing customers must be informed via mail, billing announcement, or email, no later than 30 days before a price increase.”

Second, regarding the ACP, “If there is no such successor program, the applicant must agree to participate in other low-income connectivity programs, as determined by the Commission, such as Lifeline, California LifeLine, and/or any similar low-income connectivity program or subsidy offered federally or by the State” (emphasis added to highlight the clarification).

Analysis of Proposed Final V2 vis-à-vis Draft V2 Submitted by California to NTIA

Subgrantee Selection

Pre-Qualification Phase

The state has added a pre-qualification requirement to its BEAD grant program.

Scoring – Fair Labor Practices

The state has adjusted how it will allocate up to 20pts in this category. Up to 12pts will be “awarded on the basis of the quality and contents of labor practice related items” detailed in the V2. Up to 8pts will be available for past compliance with relevant labor laws.

Scoring – Speed to Deployment

The state will still award the full 5pts to applicants that commit to completing their projects within 2 years. However, the state will now award 1pt to applicants that commit to completing a project between 2 and 3 years.

EHCPLT

The state provided additional details about how it will set and use the EHCPLT.

Low-Cost Option

The state has retained most aspects of its low-cost option and adjusted its waiver. In particular, the state will allow applicants to seek a waiver to charge up to $50/month for the low-cost option upon a showing that the $30/month price-point is not sustainable. Per the proposed final V2, “the CPUC will consider [low-cost] waiver requests at the pre-qualification stage.”