BEAD’s Match Exemption for High-Cost Areas May Be Challenging for Tribal ISPs


After decades of failed broadband policy-making and incumbent provider neglect, many Tribal communities continue to lack affordable and reliable Internet connectivity. Limited access to capital for last-mile deployment on Tribal lands has been exacerbated by a vast “missing middle mile”  problem, and credible estimates put the costs of universal access on reservations at well over $10 billion.
Despite a historic investment in better Internet access from the federal government directly to Tribes, the problem is not even half solved. The first round of the Tribal Broadband Connectivity Program offered $2 billion in grants but received nearly $6 billion in requests from half of the 574 federally-recognized Tribes. With only $1 billion available in the final round of this program, an enormous funding gap remains.
Funding from the Broadband Equity, Access, and Deployment Program (BEAD) will have to be used strategically and collaboratively with Tribes to bridge this gap. The “high-cost area” match exemption could be an important tool to facilitate sustainable infrastructure deployment on Tribal lands, but it is not yet clear that states will make this exemption feasible.
Two years ago, Congress created BEAD and infused it with a historic $42 billion investment for broadband infrastructure with the goal of achieving universal connectivity. In a process overseen by the National Telecommunications Information Administration (NTIA), BEAD funds will be distributed through states with allocations based largely on the number of unserved locations in each state. States, in turn, are tasked with developing a process to disburse those funds to subgrantees. BEAD specifies that each proposed project must offer a minimum 25% match, except where that match requirement is waived – as it has been for designated “high-cost areas.”
“High-cost area” designations are distinct from the similarly-named “Extremely High-Cost Threshold” (EHCT). EHCT refers to a cost limit – set by each state individually – beyond which states may consider funding lower-cost alternatives to fiber optic technology, which should otherwise be the primary choice. If proposals to serve a location or locations with fiber cost more than the EHCT set by a state, it could instead choose to fund a proposal that used wireless, cable, or some other alternative.
(*To explore the overlap between Tribal lands and “high-cost areas” furt …

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