Final_Proposal_Eligible_Entity_Guidance_BEAD_Restructuring_v2.1.pdf

National Telecommunications and Information Administration 1401 Constitution Ave., NW Washington, DC 20230

BEAD Final Proposal Guidance for Eligible Entities Version 2.1 | July 2025

NTIA | 1

CONTENTS

PURPOSE AND OVERVIEW

INTRODUCTION

OVERVIEW OF THE FINAL PROPOSAL

OVERVIEW OF DOCUMENTS

FINAL PROPOSAL STRUCTURE

FINAL PROPOSAL REQUIREMENTS SUMMARY

FINAL PROPOSAL DEVELOPMENT, SUBMISSION, REVIEW AND APPROVAL

FINAL PROPOSAL DEVELOPMENT

APPLICATION REVIEW AND CURING

AWARD APPROVAL

PREPARING FOR AWARD AND MONITORING

FINAL PROPOSAL GUIDANCE BY REQUIREMENT

FINAL PROPOSAL DATA SUBMISSION

SUBGRANTEE SELECTION PROCESS OUTCOMES (REQUIREMENT 1)

TIMELINE FOR IMPLEMENTATION (REQUIREMENT 3)

OVERSIGHT AND ACCOUNTABILITY PROCESSES (REQUIREMENT 4)

LOCAL COORDINATION (REQUIREMENT 5)

CHALLENGE PROCESS RESULTS (REQUIREMENT 6)

UNSERVED AND UNDERSERVED LOCATIONS (REQUIREMENT 7)

IMPLEMENTATION STATUS OF PLANS FOR COST AND BARRIER REDUCTION,

COMPLIANCE WITH LABOR LAWS, LOW-COST PLANS, AND NETWORK RELIABILITY

AND RESILIENCE (REQUIREMENT 11)

SUBSTANTIATION OF PRIORITY BROADBAND PROJECTS (REQUIREMENT 12)

SUBGRANTEE SELECTION CERTIFICATION (REQUIREMENT 13)

ENVIRONMENTAL AND HISTORIC PRESERVATION (EHP) DOCUMENTATION

(REQUIREMENT 14)

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CONSENT FROM TRIBAL ENTITIES (REQUIREMENT 15)

PROHIBITION ON EXCLUDING PROVIDER TYPES (REQUIREMENT 16)

WAIVERS

APPENDIX

CRITICAL DATA ELEMENTS

PROJECT ID

UNIQUE ENTITY IDENTIFIER

FRN

LOCATION ID

LIST OF CSVS

SUBGRANTEES (FP_SUBGRANTEES.CSV)

DEPLOYMENT PROJECTS (FP_DEPLOYMENT_PROJECTS.CSV)

LOCATIONS (FP_LOCATIONS.CSV)

NO BEAD LOCATIONS (FP_NO_BEAD_LOCATIONS.CSV)

CAIS (FP_CAI.CSV)

CHANGE LOG

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PURPOSE AND OVERVIEW

The purpose of this document is to outline the National Telecommunications and Information Administration (NTIA) Final Proposal Guidance to assist each Eligible Entity in submitting quality Final Proposals for the Broadband Equity, Access, and Deployment (BEAD) Program.

This document is intended solely to assist recipients in better understanding the Broadband Equity, Access, and Deployment (BEAD) Program and the requirements set forth in the Infrastructure Investment and Jobs Act, Notice of Funding Opportunity (NOFO), as modified by the BEAD Restructuring Policy Notice (RPN). This document does not and is not intended to supersede, modify, or otherwise alter applicable statutory or regulatory requirements, the terms and conditions of the award, or the specific application requirements set forth in the NOFO not modified by the RPN. In all cases, statutory and regulatory mandates, the terms and conditions of the award, and follow-on policies and guidance, shall prevail over any inconsistencies contained in this document.

This document does not include detailed guidance for the Final Proposal Funding Request (FPFR), which includes the budget and budget narrative submitted along with the Final Proposal. The FPFR is a required submission that includes requirements set forth by NTIA and NIST to request funds pursuant to 47 U.S.C. § 1702(e)(3)(D)(ii)(III).

See also BEAD NOFO at 46, § V.B.8. Guidance on the FPFR will be published by NTIA at a later date. The Eligible Entity’s Final Proposal submission and FPFR submission must be consistent with each other. In other words, all requested uses of funds in the FPFR must comport with the information provided in the Final Proposal.

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INTRODUCTION

OVERVIEW OF THE FINAL PROPOSAL

The Final Proposal is the “final submission” for the Eligible Entity’s BEAD grant funding, and, among other things, should provide an update to the approved Initial Proposal, as modified by the BEAD Restructuring Policy Notice, on how each State and Territory will ensure that every resident has access to a reliable, high-speed broadband connection, drawing on all funding available to accomplish this goal, including but not limited to BEAD Program funds. The contents of the Final Proposal described in this guidance align with the BEAD Restructuring Policy Notice.

OVERVIEW OF DOCUMENTS

The Final Proposal submission consists of the following documents:

1. The Final Proposal: The Final Proposal describes the results of the Eligible

Entity’s deployment Subgrantee Selection Process. The Final Proposal should demonstrate that the Eligible Entity has adequately planned for, and will, implement a program that meets BEAD program objectives. The Eligible Entity will enter narrative responses and answer questions directly within the NTIA Grants Portal BEAD Final Proposal intake module, supplemented by attachment uploads.

2. Final Proposal Data Attachments (CSV files): These five (5) datasets capture how and where the Eligible Entity plans to serve locations validated as part of the Challenge Process and are the basis of the Final Proposal submission. The datasets will be submitted in CSV format using provided templates, and include:

• Subgrantees (fp_subgrantees.csv)

• Deployment Projects (fp_deployment_projects.csv)

• Locations (fp_locations.csv)

• No BEAD Locations (fp_no_BEAD_locations.csv)

• Community Anchor Institutions (fp_cai.csv)

A completed fp_cai.csv is only applicable if the Eligible Entity plans to serve Community Anchor Institution (CAI) locations. A completed fp_no_BEAD_locations.csv is required to identify any Eligible Entity locations

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that will not be covered by a BEAD project. Each Eligible Entity will upload the CSV files to the NTIA Grants Portal BEAD Final Proposal intake module.

3. Final Proposal Attachments: Each Eligible Entity will upload additional files to the NTIA Grants Portal BEAD Final Proposal intake module to satisfy the Final Proposal requirements. These attachments include:

Required:

• Accountability Documents o BEAD Program Monitoring Plan o Agency Policy Documentation

• EHP Plans

Conditional:

• Tribal Resolution Document(s)

Optional:

• Waiver Request

4. The Final Proposal Funding Request: A consolidated budget form and associated project plan/narrative to support the implementation of the Final Proposal. Each Eligible Entity will be required to submit a FPFR as a separate attachment and upload it as part of the Final Proposal package using the NTIA Grants Portal. FPFR requirements are set forth by NTIA and NIST to request funds pursuant to 47 U.S.C. § 1702 (e)(3)(D)(ii)(III).1

FINAL PROPOSAL STRUCTURE

FINAL PROPOSAL REQUIREMENTS SUMMARY

The BEAD NOFO outlines Final Proposal requirements, which have been modified or waived by the BEAD Restructuring Policy Notice. The table below summarizes the modifications to the Final Proposal requirements based on the BEAD Restructuring Policy Notice.

Table 1: Final Proposal Requirements

Final Proposal Requirement (#)

Description of Alignment to BEAD Restructuring Policy Notice

1 See also BEAD NOFO at 46, § IV.B.8.

https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf

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Final Proposal Data Submission

• Revises Subgrantees CSV file to remove data fields on types of service providers (non-traditional, Women Owned Business Enterprise (WBE), Minority Business Enterprise (MBE), and Small Business)

• Revises Locations CSV file to remove data field on the Extremely High Cost Threshold

• Requires submission of the No BEAD Locations CSV file

• Revises the No BEAD Locations CSV file to include subcodes (financially incapable and excessive cost) for reason code 7

• Removes Non-Deployment Projects CSV file Subgrantee Selection Process Outcomes (1)

• Removes question on the Extremely High Cost Per Location Threshold

• Includes question on revising eligible CAI lists to conform with Section 4 of the BEAD Restructuring Policy Notice

• Revises guidance to require the Eligible Entity to describe how it conducted at least one additional “Benefit to the Bargain Round” and made applicants aware of the scoring rubric in Section 3.4 of the BEAD Restructuring Policy Notice

• Revises guidance to remove examples referencing regulatory burdens (e.g., participation of non-traditional providers) addressed in the BEAD Restructuring Policy Notice

Timeline for Implementation (3)

• Removes question on non-deployment activities per Section 5 of the BEAD Restructuring Policy Notice

Oversight and Accountability Processes (4)

• Removes references to non-deployment activities Section 5 of the BEAD Restructuring Policy Notice

• Adjusts references to reporting requirements per Section 2 of the BEAD Restructuring Policy Notice

Local Coordination (5) • Removes submission of the Local Coordination Tracker Tool, per Section 2.4 of the BEAD Restructuring Policy Notice

• Adjusts to focus on the public comment requirement.

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• Updated question and guidance require the Eligible Entity describe its public comment period, which was previously in another section of the Final Proposal

Challenge Process Results (6)

• No change

Unserved and Underserved Locations (7)

• Adjusts to align to Section 4 of the BEAD Restructuring Policy Notice requirement to submit the No BEAD Locations CSV file

• Updates to include a reason code for not serving BEAD-eligible locations through a BEAD project due to excessive cost

Non-Deployment Uses

(8) and Non- Deployment Subgrantee Selection Outcomes (9)

• Removes requirement per Section 5 of the BEAD Restructuring Policy Notice

Participation of Non- Traditional Broadband Providers (10)

• Removes requirement per Section 2.5 of the BEAD Restructuring Policy Notice

Implementations Status of Plans (11)

• Removes requirements for utilization of minority businesses, women-owned business, and labor surplus area firms, per Section 2.1 of the BEAD Restructuring Policy Notice

• Removes requirement for middle-class affordability plans, per Section 2.6 of the BEAD Restructuring Policy Notice

• Adjusts questions and guidance to align to:

o Section 2.1 of the BEAD Restructuring Policy

Notice on compliance with federal labor and employment laws o Section 2.2 of the BEAD Restructuring Policy Notice on broadband infrastructure reliability and resilience o Section 2.7 of the BEAD Restructuring Policy Notice on the low-cost service option

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Substantiation of Priority Broadband Projects (12)

• Adjusts question and guidance to align to Section 3.1 of the BEAD Restructuring Policy Notice to focus on the Eligible Entity’s methodology for applying the statute’s definition of “Priority Broadband Project”

Subgrantee Selection Certification (13)

• Adjusts question and guidance to focus on how the Eligible Entity applied the scoring rubric outlined in Section 3.4 of the BEAD Restructuring Policy Notice

Environmental and Historic Preservation Documentation (14)

• Adjusts guidance to note the requirement to use ESAPTT per Section 6 of the BEAD Restructuring Policy Notice

Consent from Tribal Entities (15)

• No change

Prohibition on Excluding Provider Types (16)

• Adjusts question and guidance in alignment with Section 2.5 of the BEAD Restructuring Policy Notice to certify adherence to baseline statutory requirement

In contrast to the two volumes of the approved Initial Proposal, each Eligible Entity will submit the Final Proposal in one submission. The Final Proposal will describe the implementation of the plan each Eligible Entity submitted in its approved Initial Proposal, as modified by the BEAD Restructuring Policy Notice. Several Final Proposal requirements are interrelated, where the data submitted as part of Requirement 0 (Final Proposal Data Submission) will fulfill or support the information requested to satisfy other requirements. Therefore, the completeness and accuracy of the Final Proposal data submissions are fundamental to the assessment of the overall Final Proposal.

The FPFR is a separate package that an Eligible Entity must submit with its Final Proposal. The FPFR is composed of two required documents: (1) Project Plan/Narrative and (2) a Consolidated Budget Form. The contents of the FPFR must be updated from the approved Initial Proposal Funding Request (IPFR). The updated information provided in the FPFR will be used to determine if the specific award conditions (SACs) placed on the Eligible Entity’s award when the IP and IPFR were approved can be lifted based on the information provided. Additional FPFR submission guidance is forthcoming.

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FINAL PROPOSAL DEVELOPMENT,

SUBMISSION, REVIEW AND APPROVAL

FINAL PROPOSAL DEVELOPMENT

The Eligible Entity will have 90 days from the issuance of the BEAD Restructuring Policy Notice to complete the following:

1. Complete Deployment Subgrantee Selection;

2. Meet with NTIA to review its deployment subgrantee selection outcomes;

3. Post the Final Proposal for a 7-day public comment period; and

4. Submit its Final Proposal to NTIA via the NTIA Grants Portal.

The Eligible Entity is strongly encouraged to utilize the support of its assigned Federal Program Officer for informal reviews and feedback while conducting the BEAD NOFO-mandated activities (as modified by the BEAD Restructuring Policy Notice) and drafting the Final Proposal. The Eligible Entity is also strongly encouraged to use NTIA’s technical assistance documents linked in the section above. If the Eligible Entity needs further technical assistance beyond the documents linked above, it is encouraged to contact its Federal Program Officer.

The Infrastructure Act mandates a set of interim actions, detailed below, that the Eligible Entity must successfully complete prior to submitting its Final Proposal.

CHALLENGE PROCESS

Once each Eligible Entity’s Initial Proposal Volume I was approved and it had submitted its Initial Proposal Volume II, the Eligible Entity was permitted to initiate its Challenge Process. The Challenge Process was meant to finalize the list of unserved, underserved, and CAI locations that may be funded by the BEAD program. The Challenge Process supports the programmatic objective of BEAD to deploy service to unserved and underserved locations within each Eligible Entity’s jurisdiction. For more details the Challenge Process, the Eligible Entity can also see the BEAD Challenge Process Policy Notice on the BroadbandUSA website.

https://broadbandusa.ntia.doc.gov/funding-programs/broadband-equity-access-and-deployment-bead-program

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SUBGRANTEE SELECTION

The Subgrantee Selection Process must follow the process approved in the Eligible Entity’s Initial Proposal Volume II and align with the BEAD Restructuring Policy Notice.

After resolving each challenge and at least 60 days before allocating grant funds for network deployment, an Eligible Entity must provide public notice of the final classification that was approved by NTIA of each unserved location, underserved location, or eligible CAI within the jurisdiction of the Eligible Entity.

Each Eligible Entity should expect to be in frequent dialogue with its Federal Program Officer during subgrantee selection, and will be expected to share, as a part of its monitoring obligations, progress made toward provisionally selecting subgrants that will accomplish program goals. Prior to submission of the Final Proposal, an Eligible Entity must have: (1) provisionally selected its subgrantees in accordance with the process in its approved Initial Proposal, as modified by the BEAD Restructuring Policy Notice, and (2) met with NTIA to review its deployment subgrantee selection outcomes after the completion of the deployment Subgrantee Selection Process (and prior to posting the draft Final Proposal for public comment). If the Eligible Entity has questions related to subgrantee selection, it should contact its Federal Program Officer immediately.

Addressing BEAD-Eligible Locations During Subgrantee Selection That Will Not Be Served by BEAD Funding

In its Final Proposal, an Eligible Entity must investigate and account for locations that do not require BEAD funding using the reason code process as detailed in the Final Proposal Guidance. Specifically, Eligible Entities must remove locations that have been removed from Version 6 of the FCC Fabric (reason code 3), locations already served by an enforceable commitment (reason code 4), and locations already served by non-subsidized service (reason code 5) wherever possible and account for them in the Final Proposal. However, reason code 5 cannot be used for low-earth orbit satellite service.

Locations may only be excluded from a BEAD-funded subgrant for the reasons detailed in the guidance to Intake Question 7.7, and the Eligible Entity must maintain appropriate evidence to support the conclusion that those locations require no BEAD service. Evidence of no BEAD service is not provided to NTIA during Final Proposal submission, though NTIA may request evidence from the Eligible Entity at any point, NTIA | 11 and will validate the use of reason codes when reviewing the Final Proposal. Eligible Entities must also certify in the Final Proposal that – to their knowledge – none of the BEAD funded BSLs should be classified under reason code 1 (should not have a broadband connection) or reason code 2 (do not need mass-market broadband service due to the nature of use). Eligible Entities must utilize reason codes 1, 2, and 3 for the entire period of performance by updating the no BEAD location list in Semi-Annual Reports (SARs), in accordance with the Final Proposal Guidance. Bead-eligible locations not being served through a BEAD project will be reflected in “fp_no_BEAD_locations.csv” and are not subject to BEAD Program requirements.

Each Eligible Entity is required to run its Subgrantee Selection Process using the list of BEAD-eligible locations approved by NTIA in the “post_challenge_locations.csv” file.

However, the Eligible Entity must modify its BEAD-eligible location list to include locations no longer served due to a default on a federal enforceable commitment where the federal entity has notified NTIA and the Eligible Entity of the default by the BEAD Restructuring Policy Notice publication date (June 6, 2025). NTIA will send each Eligible Entity, if applicable, a list of defaulted or newly eligible locations (e.g., federal enforceable commitment locations that were rescoped) that qualify for BEAD within 14 calendar days of the publication of the BEAD Restructuring Policy Notice. The Eligible Entity must determine that these locations are not served by some other means (e.g., state enforceable commitment), certify that the locations are unserved or underserved, and incorporate these locations into their BEAD location list prior to accepting applications in subgrantee election.

At the conclusion of the Subgrantee Selection Process, every BEAD-eligible BSL2 in the final list of eligible locations (either the approved Challenge Process list or the updated approved Challenge Process list) must be included in the Final Proposal either in the “fp_locations.csv” file to indicate the BSL will be served as part of a BEAD project, or in the “fp_no_BEAD_locations.csv” file to indicate it will not be served as

2 Such locations have a value of 0 or 1 in the “location classification” field of the file post_challenge_locations.csv. Some locations with value 2 may also appear in “fp_locations.csv” file if they are part of a BEAD project. (“A “project” may constitute a single unserved or underserved broadband-serviceable location, or a grouping of broadband-serviceable locations in which not less than 80 percent of broadband-serviceable locations served by the project are unserved locations or underserved locations.” BEAD NOFO at 14.)

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part of a BEAD project. Guidance in Requirement 7 further details the eligible reason codes that would apply to a BSL included in the “fp_no_BEAD_locations.csv.”

Specifically for new enforceable commitments (reason code 4), if a federal entity notifies an Eligible Entity of an enforceable commitment after submission of Challenge Process results to NTIA, the Eligible Entity may object to the new enforceable commitment and proceed as if there is no enforceable commitment.3 If the Eligible Entity either makes enforceable commitments under state-administered programs or does not object to new federal enforceable commitments upon notification by the awarding agency, it must apply one of the strategies described below to exclude the covered BEAD-eligible BSLs from the Subgrantee Selection Process.

When an Eligible Entity determines before Subgrantee Selection begins that BEAD-eligible locations may not be included in a BEAD project, the Eligible Entity may choose among the two permitted strategies listed below to notify applicants that the designated locations may not be served by BEAD, which applicants should factor into applications for BEAD deployment subgrants:

• Separate: The Eligible Entity may separate No BEAD Locations associated with any eligible reason code into separate project areas to notify applicants that the covered locations may not be served by BEAD. An Eligible Entity should avoid separating No BEAD Locations into a single, large project area and should instead separate these locations into compact and reasonable project areas.

These separate project areas and accompanying locations must be listed in the “fp_no_BEAD_locations.csv” file.

3 If the Eligible Entity becomes aware of a new federal enforceable commitment after submitted the Challenge Process results but before the Assistant Secretary approves those results, the Eligible Entity should notify its Federal Program Officer. Though the Eligible Entity has the right to object in this instance, it may determine after consultation with NTIA that the best path forward would be to deduplicate the new enforceable commitment before NTIA approves Challenge Process results.

The Eligible Entity should also notify its Federal Program Officer if the Eligible Entity make an enforceable commitment under a state-administered program after submitting the Challenge Process results but before the Assistant Secretary approves those results. Consultation with NTIA will help determine the best way to account for the new state-administered enforceable commitment and remove the covered locations from Subgrantee Selection

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• Indicate: The Eligible Entity may identify No BEAD Locations associated with any eligible reason code as such (for example, by using an asterisk in the subgrantee selection portal or location map), so that applicants may account for them when applying to serve a project area. Indicating these locations notifies applicants of their status and the likelihood these locations will not be served by BEAD. These locations must be listed in the “fp_no_BEAD_locations.csv” file.

When locations have been removed from Version 6 of the FCC Fabric (reason code 3) or will be served by an enforceable commitment (reason code 4), the Eligible Entity may, in addition to the two strategies listed above, choose to omit locations to prevent potential subgrantees from including the location in applications for BEAD deployment subgrants:

• Omit: The Eligible Entity may omit only locations removed from Version 6 of the FCC Fabric (reason code 3) or covered by a new enforceable commitment (reason code 4) from the BSL list used for conducting the Subgrantee Selection Process. These omitted locations must be listed in the “fp_no_BEAD_locations.csv” file.

o For enforceable commitments, the Eligible Entity omits locations at its own risk because if the enforceable commitment is not final at the time of Final Proposal submission the Eligible Entity is required to serve the covered locations through a BEAD project.

With the exception of locations for which reason codes 3 and 4 will apply, the Eligible Entity may not omit BEAD-eligible locations from the BSL list used for Subgrantee Selection or prohibit applicants from including them in their applications. This includes locations for which reason codes 1, 2, 5, and 6 may apply.

The Eligible Entity may not use the strategies above for reason code 7 (the Eligible Entity is financially incapable of service to an unserved or underserved location). The Eligible Entity may only use reason code 7 after it has completed Subgrantee Selection and has consulted with NTIA. The Eligible Entity is not permitted to indicate an inability to financially serve unserved or underserved locations to applicants during the Subgrantee Selection process. As such, the determination to use reason code 7 may only be made by the Eligible Entity after all applicants have submitted applications.

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PUBLIC POSTING

The Eligible Entity should post the Final Proposal narrative, accompanying attachments, and applicable CSV files for public comment. FPFR materials are not required to be posted for public comment. The Eligible Entity may submit its entire Final Proposal (including all CSV files, attachments, and FPFR) in NGP when it publishes the draft for public comment.

The Eligible Entity is strongly encouraged to seek guidance from its Federal Program Officer as needed in the development of its Final Proposal before it is published for public comment. NTIA encourages each Eligible Entity to utilize the format of the Final Proposal Intake Questions when posting its Final Proposals for public comment prior to submission to NTIA.

The Eligible Entity must describe a public comment period of no less than 7 days, provide a high-level summary of the comments received, and demonstrate how the Eligible Entity incorporated feedback in its Final Proposal submission, as applicable.

The Eligible Entity is not required to respond to all individual comments but must note where public comments impacted the contents of the Final Proposal submission.

NGP SUBMISSION

Each Eligible Entity can reference the NTIA Grants Portal clickpath that will be posted on the BroadbandUSA website to view instructions on how to submit the Final Proposal in the NTIA Grants Portal. If any Eligible Entity needs guidance on how to submit any portion of the Final Proposal, it should contact its Federal Program Officer and the NTIA Grants Portal Help Desk (ngphelpdesk@ntia.gov).

APPLICATION REVIEW AND CURING

The Eligible Entity may be asked to address issues identified by NTIA during the review process. If the Eligible Entity is requested to address an issue identified in its Final Proposal, NTIA will contact the Eligible Entity via email. In the email, NTIA will identify the issue(s) found within the Final Proposal and the timeline for when the issue(s) must be resolved by the Eligible Entity.

https://broadbandusa.ntia.doc.gov/funding-programs/broadband-equity-access-and-deployment-bead-program mailto:ngphelpdesk@ntia.gov

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Once the Eligible Entity has received the email of the issue(s) that need to be resolved for its Final Proposal to continue to be reviewed, the Eligible Entity should begin to resolve the issue(s) identified immediately. Failure to resolve the identified issue(s) will delay the review process.

AWARD APPROVAL

NTIA will approve the Final Proposal and submit the Final Proposal package to NIST for final approval. Once NIST approves the Final Proposal package, the Assistant Secretary will notify the Eligible Entity that its Final Proposal has been approved. Once the Eligible Entity receives the notice of approval for its Final Proposal, the Eligible Entity will be able to access the remaining program funds identified in the Eligible Entity’s Notice of Available Amounts to be used to implement the Eligible Entity’s Final Proposal.4

PREPARING FOR AWARD AND MONITORING

NTIA will release guidance on each Eligible Entity’s continuing reporting requirements, including the post-Final Proposal Semi-Annual Reports (SARs). This guidance will include the information that NTIA expects to collect from each Eligible Entity at the award-, subgrantee-, project-, contract/subcontract-, and location-levels. It is critical that each Eligible Entity consider this guidance in designing its subgrantee solicitation and provisional award materials to ensure this data can be collected from subgrantees and provided to NTIA.

4 SACs may limit access to certain amounts of BEAD funding until particular conditions are met.

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FINAL PROPOSAL GUIDANCE BY

REQUIREMENT

FINAL PROPOSAL DATA SUBMISSION

The Eligible Entity must submit data as comma separated values (CSV) files using templates provided by NTIA to document its deployment subgrantee selection outcomes. Not using the templates provided, making modifications to formulas, failing to fully complete all required fields, or changing the types of column content will result in NTIA rejecting the Final Proposal until curing is addressed. The templates can be found on the BroadbandUSA website and can also be provided by the Federal Program Officer supporting the Eligible Entity. The Eligible Entity may contact its assigned Federal Program Officer as it develops the CSV files to confirm the format, field names, and data types prior to submission. To prevent difficulties with data analysis, data fields in CSV files must not contain linebreaks.

The Eligible Entity must collect data at the project level, rather than aggregated by the subgrantee, to complete the CSVs. This structure is to ensure that each Location ID eligible for BEAD funding is mapped to a project using the project identified. For the Final Proposal requirements, the Eligible Entity must collect information from its subgrantees at the project level, and some subgrantees may be reporting on multiple projects.

0.1 Attachment (Required): Complete and submit the Subgrantees CSV file (named “fp_subgrantees.csv”) using the NTIA template provided.

The purpose of the Subgrantees CSV file is to capture information related to the provisionally selected subgrantees. The CSV file must adhere to the data format specified in Table 3 of the Appendix. Likewise, the Eligible Entity must complete all mandatory fields, unless otherwise denoted, in the file named “fp_subgrantees.csv” as outlined in Table 3 in the Appendix including:

1. State or Territory: two-letter USPS abbreviation identifying the state or territory associated with the Eligible Entity;

2. Unique Entity Identifier (UEI): SAM.gov assigned legal identifier of subgrantee;

3. UEI Name: registered name associated with the UEI record in SAM.gov;

https://broadbandusa.ntia.doc.gov/funding-programs/broadband-equity-access-and-deployment-bead-program

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4. FRN: 10-digit FCC Registration Number of the subgrantee, with leading zeroes

To download a copy of the NTIA Template for Subgrantees, please see the file named “fp_subgrantees.csv.”

0.2 Attachment (Required): Complete and submit the Deployment Projects CSV file (named “fp_deployment_projects.csv”) using the NTIA template provided.

The purpose of the Deployment Projects CSV file is to capture the outcomes of the Subgrantee Selection Process, including details about planned deployment projects (including other than last-mile deployment projects), their scope, and their significance. This information helps NTIA understand the project’s objectives and expected outcomes.

For subgrantees that intend to implement multiple projects, list each unique project as a separate row and include a unique project identifier.

The CSV file must adhere to the data format specified in Table 4 of the Appendix.

Additionally, the Eligible Entity must complete all mandatory fields, unless otherwise denoted, in the file named “fp_deployment_projects.csv” as outlined in Table 4 in the Appendix, including:

1. State or Territory: two-letter USPS abbreviation identifying the state or territory associated with the Eligible Entity;

2. Project Name: Eligibility Entity assigned project name;

3. Project ID: Eligible Entity assigned unique identifier;

4. UEI: SAM.gov assigned legal identifier of subgrantee;

5. Project Description: brief description of the project (max 1,000 characters);

6. Project Type: select a project category that best describes deployment activity (e.g., last-mile broadband deployment, CAI deployment project, middle-mile project, and MDU Wi-Fi project);

7. Priority Broadband Project: indicate whether the project is a Priority Broadband Project (Y) or not (N) based on the Eligible Entity’s application of the statutory definition of Priority Broadband Project.;

8. Estimated Miles of Aerial Fiber Deployed: anticipated number of aerial miles of fiber to provide service to the locations within the project

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9. Estimated Miles of Buried Fiber Deployed: anticipated number of buried miles of fiber to provide service to the locations within the project

10. Estimated Number of Jobs: estimated number of employment opportunities created by the project;

11. Estimated Subaward Date: anticipated date of project execution (i.e., the date the subgrantee agreement is signed and active);

12. Estimated Period of Performance Start Date: anticipated date when the project will commence its period of performance;

13. Estimated Period of Performance End Date: anticipated date when the project will close its period of performance; must be after the project start date and before March 2, 2032;

14. Tribal Intersection: indicate whether or not any BSLs or CAIs funded by the project intersects Tribal territory (see Requirement 15 for the NTIA Tribal Map Package that identifies Tribal areas for the purposes of the BEAD Program);

15. Tribal Name(s): name of the tribe(s) in whose territory the project will conduct activities;

16. Projected BEAD Funding: anticipated amount of BEAD funds used to complete the project, in USD;

17. Fixed Amount Subaward: indicate whether the subaward is a fixed amount subaward or not – only applies to [last-mile] deployment projects;

18. Subgrantee Match: total amount of cash and in-kind matching funds for the project to be provided by the subgrantee itself, in USD;

19. Federal Match: total amount of cash and in-kind matching funds for the project to be provided by match-eligible federal sources, in USD;

20. State Match: total amount of cash and in-kind matching funds for the project to be provided by the Eligible Entity, in USD;

21. Other Match: total amount of cash and in-kind matching funds for the project to be provided by other sources such as nonprofits organizations, in

USD;

22. Federal Match Source(s): name of federal funding source(s) that is match eligible; and

23. Notes: optional notes about the project. For projects that have not been tentatively awarded, state the cause.

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To download a copy of the NTIA Template for Deployment Projects, please see the file named “fp_deployment_projects.csv.”

0.3 Attachment (Required): Complete and submit the Locations CSV file (named “fp_locations.csv”) using the NTIA template provided. The Location IDs in this list must match the NTIA-approved final list of eligible locations .

The purpose of the Locations CSV file is to capture the final location data of all underserved and unserved locations eligible for BEAD funding after the Eligible Entity’s Challenge Process results are approved and the technical and performance aspects of the project. Each Location ID (BSL) must be associated with a specific Project ID. The CSV file must adhere to the data format specified in Table 5 of the Appendix. Likewise, the Eligible Entity must complete all mandatory fields, unless otherwise denoted, in the file named “fp_locations.csv” as outlined in Table 5 in the Appendix including:

1. Location ID: unique identifier of the location from the Broadband Serviceable Location Fabric;

2. Project ID: Eligible Entity assigned unique identifier defined in the Deployment Project CSV;

3. Location Classification: indicate the category classifying the location as unserved, underserved, or served from the final list of eligible locations;

4. Technology Code: indicate the type of technology to be deployed for service to the location, using the FCC Broadband Data Collection technology codes;

5. Upload Speed Anticipated: planned maximum upload speed, in Mbps;

6. Download Speed Anticipated: planned maximum download speed, in Mbps;

and

7. Low Latency: indicate whether the committed service meets the definition of low latency or does not meet the definition of low latency as defined in the BEAD NOFO.

To download a copy of the NTIA Template for Locations, please see the file named “fp_locations.csv.”

0.4 Attachment (Required): Complete and submit the No BEAD Locations CSV file (named “fp_no_BEAD_locations.csv”) using the NTIA template provided. The Location IDs in this list must match the NTIA-approved final list of eligible locations.

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The purpose of this No BEAD Locations CSV is to expand upon the reasons for not serving a BEAD-eligible location with a BEAD project provided in the Locations CSV.

The CSV file must adhere to the data format specified in Table 6 of the Appendix.

Likewise, the Eligible Entity must complete all mandatory fields, unless otherwise denoted, in the file names “fp_no_BEAD_locations.csv” as outlined in Table 6 of the Appendix including:

1. Location ID: unique identifier of the location from the Broadband Serviceable Location Fabric;

2. Location Classification: the category classifying the location as unserved, underserved, or served from the final list of eligible locations;

3. Reason: reason, from a list, for not serving a location through a BEAD project;

4. Non-BSL Code: description of locations not being eligible BSLs, from a list, for not serving a location through a BEAD project, as applicable to the reason code selected;

5. Location Type: description of the location, from a list, for not serving a location through a BEAD project, as applicable to the reason code selected;

6. Financial Type: the financial reasoning for reason code 7

7. Evidence Type: the type of evidence maintained by the Eligible Entity to support the explanation of the reason code (evidence will not be submitted with the Final Proposal);

8. Provider ID: the unique 6-digit code generate by the FCC that identifies a service provider, as applicable to the reason code selected;

9. Technology: type of technology already provided to the location, using the FCC Broadband Data Collection technology codes, as applicable to the reason code selected;

10. Program: the state or federal enforceable commitment program, as applicable to the reason code selected;

11. Challenge ID: challenge identifier for the location challenge submitted to the FCC, as applicable to the reason code selected;

12. Notes: if needed, brief explanation of why locations should not receive service through a BEAD project.

To download a copy of the NTIA Template for No BEAD Locations, please see the file named “fp_no_BEAD_locations.csv.”

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0.5 Question (Y/N): If the Eligible Entity intends to use BEAD funds to serve CAIs, does the Eligible Entity certify that it ensures coverage of broadband service to all unserved and underserved locations, as identified in the NTIA-approved final list of eligible locations and required under 47 U.S.C. § 1702(h)(2)?

The Eligible Entity must indicate if it intends to use BEAD funds to serve any CAIs. If the Eligible Entity intends to use BEAD funds to serve any CAIs, it certifies that it ensures coverage to broadband service to all unserved and underserved locations, as identified projects upon conclusion of the Challenge Process required under 47 U.S.C.

§ 1702(h)(2). This will serve as the Requirement 7 certification mandated by the BEAD

NOFO.

0.6 Attachment (Required – Conditional on a ‘Yes’ Response to Intake Question 0.5): Complete and submit the CAIs CSV file (named “fp_cai.csv”) using the NTIA template provided. Although CAIs are not included under (f)(1) deployment projects, to confirm the Eligible Entity’s compliance with the BEAD prioritization framework and identify BEAD-funded CAIs, the NTIA template is required. The Eligible Entity must only include CAIs funded via BEAD in this list; the Eligible Entity may not propose funding CAIs that were not present on the approved final list from the Eligible Entity’s Challenge Process results.

The purpose of this CAIs CSV file is to capture the eligible CAIs, as documented in the Eligible Entity’s approved Challenge Process results and modified by the BEAD Restructuring Policy Notice, that will be served by a BEAD-funded project.

The Eligible Entity must revise their list of eligible CAIs to ensure their designations conform with the statutory definition of a CAI established by the Infrastructure Act.

NTIA revokes the more expansive definition adopted by the BEAD NOFO. Per 47 U.S.C.

§ 1702(a)(2)€, “the term ‘community anchor institution’ means an entity such as a school, library, health clinic, health center, hospital or other medical provider, public safety entity, institution of higher education, public housing organization, or community support organization that facilitates greater use of broadband service by vulnerable populations, including low-income individuals, unemployed individuals, and aged individuals.” For BEAD purposes, a “community support organization” is an organization located in a government-owned facility that provides publicly accessible Internet service and currently offers digital skills training. NTIA will closely review all CAI submissions and reserves the right to reject any CAI designation.

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The CSV file must adhere to the data format specified in Table 7 of the Appendix.

Likewise, the Eligible Entity must complete all mandatory fields, unless otherwise denoted, in the file named “fp_cai.csv” as outlined in Table 7 in the Appendix including:

1. Type: indicate the CAI location type;

2. Entity Name: official name of the CAI;

3. Location ID: unique identifier of the location from the Broadband

Serviceable Location Fabric, if available;

4. Project ID: Eligible Entity assigned unique identifier;

5. Street Address: street number, street name, and any applicable prefix or suffix of the first address line (primary address) of the CAI;

6. City: full name of the city, town, municipality, or census designated place associated with address;

7. State or Territory: two-letter USPS abbreviation identifying the state or territory associated with the Eligible Entity;

8. Zip Code: five-digit USPS ZIP code associated with address, including any leading zeros;

9. Latitude: unprojected (WGS-84) geographic coordinate latitude in decimal degrees for the CAI, with a minimal precision of 4 decimal digits;

10. Longitude: unprojected (WGS-84) geographic coordinate longitude in decimal degrees for the CAI, with a minimal precision of 4 decimal digits;

11. Technology Code: indicate the type of technology to be deployed for service to the location, using the FCC Broadband Data Collection technology codes;

12. Upload Speed Anticipated: planned maximum upload speed, in Mbps; and

13. Download Speed Anticipated: planned maximum download speed, in Mbps;

The Eligible Entity must enter the address of the physical location of the CAI, not the administrative location. For example, the address must describe the location of the school building, not the board of education administrative building.

To download a copy of the NTIA Template for CAIs, please see the file named “fp_cai.csv.”

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SUBGRANTEE SELECTION PROCESS

OUTCOMES (REQUIREMENT 1)

Relevant Instructions from the Infrastructure Act, 47 U.S.C. § 1702 (e)(4)(A)(i)(I):

the eligible entity may submit a final proposal for the remainder of the amount allocated to the eligible entity ... that includes—

(I) a detailed plan that specifies how the eligible entity will—

(aa) allocate grant funds for the deployment of broadband networks to unserved locations and underserved locations, in accordance with subsection (h)(1)(A)(i); and

(bb) align the grant funds allocated to the eligible entity under subsection (c), where practicable, with the use of other funds that the eligible entity receives from the Federal Government, a State, or a private entity for related purposes

Relevant Instructions from BEAD Restructuring Policy Notice Section 3.3, Pages 10 – 11:

… NTIA is requiring Eligible Entities to conduct at least one additional subgrantee selection round for every BEAD-eligible location (the “Benefit of the Bargain Round”). The Benefit of the Bargain Round must permit all applicants – regardless of technology employed or prior participation in the program – to compete on a level playing field undistorted by the non-statutory regulatory burdens eliminated above.

All subgrantee selection conducted after the release of this Policy Notice must comply with the terms of this Policy Notice.

Eligible Entities must rescind all preliminary and provisional subaward selections and notify applicants that a further round of applications will be considered before final awards are made. Eligible Entities that have already completed subgrantee selection must conduct at least one Benefit of the Bargain round. Eligible Entities have 90 days to comply with the obligations outlined within this Policy Notice and submit a Final Proposal that reflects the results of the Benefit of the Bargain round. This deadline replaces the deadline extensions previously granted in the Programmatic Waiver of the Final Proposal Deadline Requirements. NTIA will complete its review of each Final Proposal within 90 days of submission.

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To the extent an Eligible Entity has a prequalification process, it must be reopened to all interested applicants, although the Eligible Entity may make prequalification submissions part of the application package. Existing qualified applicants do not need to resubmit prequalification documentation. If an applicant previously failed the prequalification process, it may choose to update its materials and seek prequalification again. Eligible Entities, however, must still ensure that applicants meet the financial and managerial capacity, technical and operational capability, and other requirements in 47 U.S.C. § 1702(g)(2)(A).

Where an applicant elects to stand on an existing subgrantee application received prior to the publication of this Policy Notice, that application shall be rescored under the rubric detailed below and may be awarded during the Benefit of the Bargain round, but no BEAD subgrantee will be permitted to recover costs to comply with the regulatory burdens eliminated in this Policy Notice. Existing applicants may also choose to submit a new application that eliminates the cost of these regulatory burdens in anticipation of competition from additional applicants. Eligible Entities must exclude all non-statutory regulatory burdens as identified above from the application and scoring processes for subgrantee selection. Eligible Entities must also allow applicants to propose to exclude select broadband serviceable locations (BSLs) that the applicant determines are excessively high-cost locations from the project area (or would otherwise make the project economically unviable for the technology being used).

Relevant Instructions from the BEAD Restructuring Policy Notice Section 4, Page 14:

Eligible Entities must revise their list of eligible Community Anchor Institutions (CAIs) to ensure their designations conform with the statutory definition of a CAI as established by IIJA (47 U.S.C. §1702(a)(2)(E)).