Unpacking Approved BEAD Volume 2s: Oklahoma

NTIA recently approved Oklahoma’s Initial Proposal Volume 2. The ACLP compared the final version with the pre-comment draft the state released last fall (it did not post the version it submitted to NTIA). A redlined comparison is available here. The following changes were evident:

Subgrantee Selection Process

Deconfliction

The state provided significantly more detail about the automated deconfliction process that it will deploy. Indeed, the state expanded many elements of the Subgrantee Selection Process section, providing additional details about specific elements of almost every step of the application, review, and allocation process.

Scoring – Minimal BEAD Outlay

The state largely preserved its scoring approach but increased the number of points available in this category from 60 to 65.

Scoring – Affordability

The state largely preserved its scoring approach but decreased the number of points available in this category from 45 to 44.

Scoring – Fair Labor Standards

The state shifted its allocation strategy in this category and embraced the now-common approach to awarding points for past compliance with relevant laws and plans for future compliance (previously the state proposed awarding points based on the type of workforce used and commitments to safety and training). The state also decreased the number of points available here from 15 to 11.

Scoring – Low-Cost Option

The state has clarified that it wishes to encourage all subgrantees, not just those engaged in non-priority broadband projects, to offer the low-cost option to all subscribers in a project area. It reasons that having to administer means tests to determine eligibility is burdensome; accordingly, in the state’s view offering the low-cost option to everyone is more efficient.

Low-Cost Option

The state maintained its $60 price-point and added a lengthy discussion about why it chose to set the price higher than the NTIA model (among other things, the state concludes that a higher price-point may attract more applicants, whereas a lower price-point could disincentivize participation). The state also ties this back to its Low-Cost Option scoring category (discussed above), noting that “the incentivization in the OBO’s scoring rubric of the removal of the means test for the low-cost service option will also help to mitigate administrative burden and make BEAD low-cost internet service real rather than merely notional.” It also cites this incentive as another component of its Middle-Class Affordability Plan.