Unpacking Approved BEAD Volume 2s: Delaware

NTIA recently approved Delaware’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

Scope of Changes

The state added significant new language to this section. Most of the additions reflect verbiage included in most other states’ V2s and encompass additional discussion and details about how the state will administer the grant process, the principles that will guide its efforts, etc.

Scoring

The state overhauled its scoring rubric, raising the overall number of potential points available for Priority Projects from 100 to 400. Specifically:

• Minimal BEAD Outlay: up to 140 pts available (up from 35, although, as a percentage of total points, it remains the same at 35%). The state will award points based on the proposed project cost relative to its reference cost. The adoption and use of a reference cost is new.
  
• Affordability: up to 84 points available (representing 21% of total points, up from 15pts/15%). Initially, points were to be awarded based on a commitment to offer symmetrical gig service at a price no greater than offerings in urban parts of the state. Now, the state has set a $100 reference price for use in awarding points, with full points going to applicants that commit to offer gig service for less than $30/month (the state has adopted a complicated formula for determining how many points applicants will receive in this category).
• Fair Labor Standards: up to 100 points available (representing 25% of total points, similar to the initial rubric). In its final V2, the state has broken out its scoring into 4 discrete buckets: (1) Job Quality (30pts); (2) Safety and Training (30pts); (3) Local Hire and Targeted Hire (30 points); and (4) compelling narrative addressing past compliance with relevant laws.
• Speed to Deployment: up to 76 points available (representing 19% of total points, up from 15pts/15%). Full points will go to applicants that commit to deploying networks within 18 months.
• Local Support & Past Performance: The state eliminated these categories from its final scoring rubric.

EHCPLT

The state rewrote and expanded this section. It expects that it will not need to implement the threshold, but if it does, the final V2 offers more details about how it will be set and used.

Non-Deployment Activities

The state offers additional information regarding the types of projects it might fund with leftover BEAD funds and how it will allocate those funds. These include 14 potential categories, e.g., training and workforce development; remote learning or telehealth; digital literacy/upskilling; coding/computer science; etc.

Workforce Development

The state notes that it has not identified a workforce shortage vis-à-vis building new broadband networks. Even so, the state rewrote significant portions of its Workforce Development section to flesh out its commitments and the expected commitments of prospective subgrantees.

Low-Cost Option

The state retained most aspects of its proposed low-cost option. However, it included a waiver option should ACP lapse. Specifically:

• “If the ACP program terminates, DTI will keep the low-cost offering price point requirement at $30 per month or less. However, ISPs will be able to submit to DTI a waiver request asking for an increase of the low cost price up to no more than $65/month.”
• The waiver request must be supported with evidence of how the $30/month requirement would be financially unstainable and how the increased price would still be affordable to low-income households.

The state will also allow for price increases over time in line with the CPI.