As of August 6th, 2024, 41 states have completed the Challenge Phase for BEAD and are moving towards Final Determinations, with another four states currently in the Challenge Phase. If you’ve missed our summary of the BEAD Challenge Process, check out our last article, Breaking Down the Challenge Process.

The NTIA requires completion of the Challenge Process within 120 calendar days, starting with the initiation of the Challenge Phase and ending with the submission of final classifications to the NTIA. However, timelines for many states are currently slipping, with state broadband offices shifting back their Challenge Process windows— either to complete deduplication efforts or receive NTIA approval. 

Getting to Final Determinations is a messy and (surprise, surprise) challenging process. Some states are leveraging input from the Challenge Phase to clean up location data they currently have, leading to delays in Final Determinations, and as a result, application windows. Other states are taking the time to clean up data prior to the Challenge Phase, which also leads to application delays further down the line. 

So, what’s the holdup?

States are juggling multiple perspectives, many of which directly oppose each other. As part of the Challenge Process, providers can debate the eligibility of locations. Some providers see this as an opportunity to establish a competitive edge – challenging other providers’ speeds and locations to expand their own opportunities. Meanwhile, states are reconciling their own records, including RDOF grants, RDOF defaults, state programs, and other enforceable commitments. By taking locations off the table, states seek to prevent overbuilding and ensure they’re playing by the rules.

Often, the data sources themselves can be nebulous. States are swimming in federal data from the National Broadband Availability Map and the Broadband Data Collection Fabric, both of which are regularly updated and may contain inaccurate reporting or errors from multiple sources. On a local level, states are sifting through provider challenges and their own internal data, further complicating the journey to the truth.

The timelines for the Challenge Process mean that multiple states will likely intersect BEAD application windows, forcing providers to prioritize, plan, and prepare to tackle different states, locations, and deployments. States have outlined their scoring criteria, priorities, and geography types that will be used to define project areas, ranging from census block groups (“CBGs”) to counties to school districts in pending or approved Volume II Proposals. 

Many states are currently opening Pre-Registration for providers interested in BEAD, and in some cases, providers can go so far as to specify the geographic areas they intend to pursue when application windows open. Along with monitoring the stages and outputs of the Challenge Process and Pre-Registration, providers will have to organize internal resources and assets to prepare for the summer storm. 

The Challenge Process is complex, messy, and high stakes. State broadband offices, many of which are nascent organizations, are tasked with the monumental process of dissecting and stitching multiple sources of federal, state, and local-level data. The process is rocky, but it also presents an opportunity. Frequently moving targets, timelines, and data sources means that providers who are aware or active throughout the Challenge Process will enter the BEAD application window with a leg up. 

With $42 billion on the line, no amount of preparation is too much.