Unpacking Approved BEAD Volume 2s: Missouri
NTIA recently approved Missouri’s Initial Proposal Volume 2. The ACLP compared the final version with the cured draft that the state released in June (an analysis of changes made in that draft vis-à-vis the draft it initially submitted to NTIA is also included below). A redlined comparison of the final and cured versions is available here. The following changes were evident:
Subgrantee Selection Process
Alternative Technologies
The state added language describing when it might resort to satellite or other broadband services that are not “reliable” according to NTIA guidance. In those cases, the state will undertake a final round of competitive bidding before permitting the use of an alternative technology in areas where costs exceed the EHCPLT.
Low-Cost Option
Like VA before it, Missouri caved to NTIA pressure and set a $30/month price-point for its low-cost option. It will allow subgrantees to apply for a waiver to charge up to $70/month upon a showing that the lower price-point would not be economically feasible. It will also allow annual adjustments of the price to account for inflation.
This leaves FL and SC as the remaining states that have yet to set a price for the low-cost option.
Changes Made by Missouri to its BEAD V2 in its June 2024 Cured Draft (Relative to V2 Draft Initially Submitted to NTIA)
Scoring
Scoring – Max BEAD Outlay
The state, like several others, has proposed scoring applications relative to a maximum BEAD outlay pre-determined by the state. Applicants receive more points the lower their proposed BEAD allocation is from the maximum. NTIA apparently pushed back on this proposal, but the state has retained it in the cured V2. In a curing note, MO argues that its proposed approach is essential to helping it realize the goal of universal service and that applications that exceed the outlay in one round will be pushed to subsequent rounds, when the max outlay is increased. In addition, the state, in response to NTIA feedback, distinguishes its BEAD maximum outlay approach from the extremely high-cost threshold by saying that “the Maximum BEAD Outlay protects the BEAD allocation from overly costly projects, regardless of the proposed technology.” Scoring – Labor & Workforce. The state provides additional discussion and detail regarding its approach to scoring labor and workforce aspects of applications from new entrants. In particular, the state has adjusted its scoring for applicants with less than 3 years of experience by splitting its points into two new categories, with upwards of 5 points available for sufficiently complete labor plans and up to 5 points available for especially strong labor plans. For workplace safety, the state has detailed a more flexible approach to assigning up to 10 points based on 4 new factors detailed in the cured V2. Scoring – Speed to Deployment. The state has reduced the number of points available here from 20 to 18. Scoring – Additional Clarifications. The state provides additional information for several secondary scoring categories, including Hiring Commitments (in the Equitable Workforce bucket) and the Missouri Nexus prong in the Economic Development bucket.
Extremely High-Cost Threshold
The state provided additional information about its iterative approach to setting preliminary thresholds before and after each round. The state notes that its “process would work by generating target savings in each round through use of a non-priority broadband technology and setting the EHCPLT at the highest possible level that achieves those savings.”
Climate Assessment
Specified the parts of the state where initial hazard screening will be required.
Low-Cost Option
The state did not make any substantive changes to this section but noted that curing is “ongoing” and “further changes are expected.” This could signal that the state may be considering a shift towards a firmer yet still flexible price-point for the low-cost option, e.g., the FCC’s Urban Rate Survey. Several states, including GA most recently, have adopted that approach as a seeming middle-ground between no price-point and a subjectively selected rigid price-point. MO initially proposed specific price-points for the low-cost option in its draft V2 but then embraced an approach that would let applicants set the price themselves based on a market analysis. [See above for how the state resolved this issue]
Subgrantee Accountability
The state has expanded how it will provide subgrantees with funds. Specifically, the state notes that it “reserves the right to designate projects as either (1) eligible cost reimbursement subawards; or (2) as allowed under NTIA’s guidance in Tailoring the Application of the Uniform Guidance to the BEAD Program (“Fixed Amount Waiver”), as fixed amount subgrants. If subsequent guidance or waivers open additional options as did the waivers regarding fixed amount subgrants, OBD may request to revise the approach…”