The Broadband Equity, Access, and Deployment (BEAD) Program is driving the most ambitious broadband expansion effort in U.S. history. Over the past two years, state broadband offices (SBOs) have been working diligently to adhere to the statutory requirements of BEAD to meet the outcome that Congress has appropriated for—deploying funding to ensure universal broadband service, while prioritizing networks that can easily scale to meet evolving needs, support 5G expansion and future wireless technologies. 

In my role at Ready.net, I’ve had the opportunity to support these efforts, working closely with SBOs to navigate the complexities of BEAD implementation and ensure funding is deployed efficiently and effectively. However, recently proposed changes introduced by the SPEED for BEAD Act and signaled by the Department of Commerce threaten to disrupt this momentum, causing delays, funding inefficiencies, and weakened broadband expansion efforts. Reform efforts should prioritize accelerating the deployment of BEAD, but the proposed changes risk undermining state-led strategies, limiting flexibility, and weakening BEAD’s overall impact.

To fulfill BEAD’s mission, any modifications to the program should accelerate progress, maintain state flexibility, and preserve the integrity of ongoing broadband initiatives.

BEAD’s Data-Driven, State-Led Approach

BEAD’s foundation is built on precision, increased accountability, and state-based data-driven decisionmaking. The program was designed to specifically address the fundamental shortcomings of past broadband programs—such as the Federal Communications Commission's Connect America Fund (CAF I and II) and the Rural Digital Opportunity Fund (RDOF)—by implementing several key improvements:

• More accurate broadband mapping: The FCC’s National Broadband Map now assesses broadband availability at the location level, improving precision compared to past census-block-based methods.

• Refined eligibility and oversight: States conducted rigorous challenge processes, leveraging data from local governments, ISPs, and nonprofits to ensure funding reaches unserved areas.

• Cost-Efficient Infrastructure Investment: Balanced funding decisions prioritize cost-efficient, high-quality network solutions rather than selecting the cheapest option. The inclusion of community anchor institutions (CAIs) at statutory speed thresholds supports robust middle-mile and last-mile connections across Rural, Urban, and Tribal communities.

• Strong community and provider engagement: SBOs designed their programs through public listening sessions, industry consultations, and stakeholder feedback, ensuring broad participation.

• Efficient grant allocation: States streamlined subgrantee selection through pre-qualification requirements, reducing administrative bottlenecks.

Eligible Entities incorporated these improvements into their Initial Proposals, all of which have been approved by NTIA. 

Following these Initial Proposals, states have made significant progress:

• 47 Eligible Entities have concluded their state challenge process. (All remaining Eligible Entities have closed their challenge submission process.)

• 33 Eligible Entities have started subgrantee selection. (Others have already begun subgrantee pre-qualification and published applicant resources.)

• 4 Eligible Entities have completed subgrantee selection.

• 3 eligible entities have had their Final Proposals approved by NTIA.

Early Data Proves BEAD’s Pragmatic Approach and Effectiveness

The BEAD program is delivering results. Early data shows that BEAD’s competitive, data-driven, state-led approach is driving high participation, strong competition, and cost-efficient broadband expansion.

Among the 33 states that have initiated subgrantee selection, several have released preliminary data from Round 1 of their respective application review processes, demonstrating strong participation, competition, high coverage rates, and cost-efficient broadband expansion.

• Arkansas: Received 814 applications from 43 providers for 98% of the eligible locations, with 82% receiving 2+ bids

• Indiana: Received 743 applications from 34 providers for 94% of the eligible locations, with 82% receiving 2+ bids

• Pennsylvania: Received 239 applications for 26 providers for 97% of the eligible locations

• Wisconsin: Received 425 applications for 95% of the eligible locations

• Virginia: Received 2000+ applications from 24 providers for 92% of the eligible locations

• Kansas: Received 200 applications from 23 providers for 96% of the eligible locations

In addition to these Round 1 results, three of the four states that have completed subgrantee selection have posted their Final Proposal data, demonstrating promising results that achieve universal coverage, while optimizing funding to maximize technologies and networks that can easily scale to meet evolving needs over time and support the deployment and expansion of 5G and future wireless technologies. The results show:

• Delaware achieved universal coverage, reaching 100% with fiber at $3,049.05 per location 

• Louisiana achieved universal coverage, reaching 95% with fiber at $5,297 per location (96% of the eligible locations received 2+ bids)

• Nevada achieved universal coverage, reaching 83% with fiber at $8,861.28 per location 

Across these three states, 175,906 locations are slated to be served by a fiber project at $5,971.92 per location. This accounts for 92 percent of locations at 90 percent of the total cost.

These early results demonstrate that SBOs are implementing rigorous programs with effective processes that yield efficient outcomes. 

Put simply: A massive overhaul of BEAD  is neither needed nor merited. Any changes implemented by Congress or the Administration should afford states the trust they’ve earned. 

Keeping BEAD on Track

States have spent the past two and a half years designing and implementing locally informed broadband grant programs, with every state on pace to complete their subgrantee selection process within the 2025 calendar year.

Many of the proposed changes to BEAD could stall progress by forcing states to pause, backtrack, redo, or risk legal challenges from mid-process rule changes, ultimately slowing implementation and undermining the act's main goal of accelerating BEAD. 

To ensure any legislative or administrative changes enhance, rather than disrupt, BEAD implementation, each proposed change should be carefully evaluated. First, assess the direct impact of each change by answering 'Will the proposed change affect':

1. Plans approved in the Initial Proposal?

2. Location eligibility? 

3. Scoring or prioritization during subgrantee selection? 

4. Gating criteria for applicants or applications? 

If any answer is yes to any of these, the proposed changes must be carefully reviewed to address key risks by asking 'Will the proposed change':

• Force states to restart or delay their programs?

• Undermine a fair and consistent subgrantee selection process?

• Create legal risks for states or the NTIA?

If yes was the answer to any of these risks, the change should either 1) Be avoided entirely to prevent unnecessary delays or 2) Be made optional, allowing states to adopt changes at their discretion without disrupting progress.

This process ensures that any changes to BEAD support state progress rather than cause delays, serving as a tool for acceleration by adding flexibility to implementation.

The Risks of Changing BEAD Midstream

As mentioned above, states have spent years developing competitive, data-driven, open, and transparent selection processes aligned with federal and local priorities. Moreover, providers have also made significant financial and operational investments in preparing applications, designing network buildouts, and securing necessary resources based on the existing rules. Retroactively changing conditions risks stranding private capital, reducing provider participation and confidence, and discouraging future investment in broadband infrastructure expansion. 

Similarly, the Build America, Buy America (BABA) requirements in BEAD have spurred major supplier investments to expand domestic broadband equipment production. Companies like Nokia and Calix have opened U.S.-based manufacturing facilities, and 41 companies have self-certified broadband equipment that meets BABA compliance. Uncertainty or sudden rule changes could jeopardize these commitments, weaken domestic supply chains, and disrupt the carefully planned deployment of broadband infrastructure.

The following sections outline key risks associated with major modifications to BEAD, highlighting why any changes must be carefully structured to preserve momentum, ensure consistency, and support the program’s long-term success. 

Risk 1: Redefining “Reliable Broadband Service” 

The BEAD Notice of Funding Opportunity (NOFO) currently defines Reliable Broadband Service as:

• Speeds of at least 100/20 Mbps

• Latency under 100 milliseconds

• Delivery over fiber-optic, cable, licensed fixed wireless, or DSL technologies

For subgrantee selection, qualifying broadband follows these same standards for residential and business locations, while community anchor institutions (CAIs) must have symmetrical 1 Gbps service.

Proposed Changes

• Expand the definition of Reliable Broadband Service to include more technologies

• Redefine eligible CAIs by requiring only 1 Gbps download speeds, rather than symmetrical speeds

Potential Risks to BEAD Implementation: A tech-neutral approach could accelerate BEAD implementation—if introduced with precision—by expanding rather than restricting state flexibility. This requires careful impact assessment to prevent delays or unintended consequences. Taking a more tech-neutral approach would, at a minimum, require changing the definition of “Reliable Broadband Service” to include all technologies. Any change in this definition should be accompanied by important caveats: 

• Preserve challenge process data: States spent months refining maps through rigorous challenge processes. Requiring a re-run would undermine accuracy and delay implementation.

• Protect subgrantee selection results: States that have begun or completed subgrantee selection, including pre-registration and pre-qualification, should not be forced to restart or modify their process, as this could disrupt transparency and consistency.

• Avoid disrupting scoring and priorities: Regardless of whether a state has launched subgrantee selection, expanding “Reliable Broadband Service” should not alter the definition of priority broadband projects or force changes to scoring criteria, which would require massive program overhauls

• Maintain the CAI definition: CAIs need symmetrical speeds, especially K-12 schools, rural healthcare facilities, and libraries. Downgrading this requirement would undercut essential services.

• Prioritize quality over lowest cost: Investing in thriving communities and American innovation is not about finding the cheapest solution. Prioritizing cost over quality disproportionately harms Rural, Urban, and Tribal communities, where the demand for robust connectivity is growing rapidly.

If a tech-neutral approach is a priority for this Administration or Congress, it should come with clear guidance and allow states to opt in seamlessly, while avoiding unnecessary disruption for those who opt out.

Risk 2: Removing Incentives for Affordable Pricing

Proposed Change: The Speed for BEAD Act seeks to expand the existing prohibition on price regulation by preventing states from considering price as a scoring factor in subgrantee selection.

• The Infrastructure Investment and Jobs Act (IIJA) already prohibits the NTIA from regulating broadband rates: “Nothing in this title may be construed to authorize the Assistant Secretary or the National Telecommunications and Information Administration to regulate the rates charged for broadband service.”

• This proposed expansion would prohibit Eligible Entities from regulating, setting, or mandating broadband rates, including using price as a scoring criterion in subgrantee selection.

Potential Risks to BEAD Implementation: 

• The IIJA affirms that affordable broadband is essential for full participation in modern life. Without price as a scoring factor, applicants may not voluntarily commit to lower consumer prices, undermining Congress’ goal of affordability.

• Every state currently includes affordability as a primary scoring criterion, assessing subgrantees based on their total price for 1 Gbps/1 Gbps (priority projects) and 100/20 Mbps (non-priority projects). Many states also incorporate secondary criteria for low-cost plans. Banning price as a scoring factor would undermine subgrantee selection, making existing processes incompatible with federal rules, forcing costly overhauls, delaying implementation, and reducing incentives for affordable broadband access. 

Risk 3: Prohibiting Subgrantee Award Conditions

Proposed Change: The Speed for BEAD Act prohibits the NTIA and states from enforcing 14 specific conditions, including bid scoring and reporting requirements. Additionally, Commerce Secretary Lutnick’s statement on BEAD states that Commerce is removing what he calls “pointless requirements”

Potential Risks to BEAD Implementation:

Prohibiting certain conditions that impact scoring criteria—such as open access and data cap restrictions—could disrupt subgrantee selection. If the NTIA invalidates conditions that states scored or treated as commitments, it would undermine ongoing processes and delay upcoming rounds by requiring revisions to applicant materials and software systems. 

These changes should be accompanied by important caveats: 

• Protect subgrantee selection processes: States that have completed or begun subgrantee selection should not be forced to restart or modify their processes which could create delays, legal challenges, and inconsistencies in program implementation.

• Enforce existing commitments: If subgrantees are no longer held accountable for previously scored commitments, it could lead to legal disputes from rejected applicants who may claim they were disadvantaged under the old rules, jeopardizing the fairness of the selection process.

• Avoid disrupting scoring and priorities: Retroactively prohibiting certain conditions could force changes to priority broadband project definitions or scoring criteria, requiring massive program overhauls, delaying implementation, and introducing confusion among applicants and reviewers.

Risk 4: Imposing a Per-Location Spending Cap

A federally imposed limit on cost-per-location funding could have unintended consequences—introducing constraints and delays to broadband deployment. BEAD’s competitive selection process is designed to optimize funding, maximizing the number of locations served while delivering the best solution in each area. A rigid or overly restrictive cap could disrupt this balanced approach, particularly in rural and high-cost areas.

Potential Risks to BEAD Implementation:

• Forcing cost over quality: Investing in American communities, through innovation and broadband infrastructure expansion does not mean prioritizing the cheapest or least-cost solutions. A hard spending cap could deprioritize the best broadband options in favor of deployments that sacrifice scalability, reliability, and long-term performance—particularly in areas where fiber or other high-capacity networks are the most effective solution.

• Disrupting ongoing projects: As with other proposed changes, a spending cap risks upending both active and completed subgrantee selection processes, where applications have already been submitted and projects have already been awarded based on existing budget models. States would have to rework their allocations, potentially causing delays, legal challenges, and inefficiencies.

• Undermining the optimization process for universal coverage: The BEAD subgrantee selection process is designed to balance cost efficiency with quality—selecting the best option for each location while ensuring every unserved area gets connected. A low, arbitrary cap would disrupt this balance, forcing states to award more locations to cheaper options instead of the most effective long-term solutions, without necessarily expanding coverage. 

A nuanced, flexible approach—such as an adjustable cap that prioritizes universal coverage without arbitrarily restricting state flexibility—would be preferable to an across-the-board spending limit that ignores geographic and logistical realities.

The Path Forward for BEAD

The BEAD program is well underway. Over the past two and a half years, states have implemented transparent, competitive, and locally driven broadband grant programs, keeping BEAD on track to complete subgrantee selection in 2025. This progress is instrumental in delivering broadband infrastructure to strengthen communities and support innovation, economic growth, and national security. 

State-led implementation and decisionmaking remain the best path forward. To maximize BEAD’s success, any changes or reforms should enhance state flexibility, avoid disruptions, and maintain the program’s competitive integrity. America’s broadband future depends on a strategic, steady approach—one that builds on progress rather than reversing it.

Dustin Loup is the Senior Director, Policy Development and Analysis for Ready.net and leads the National Broadband Mapping Coalition. 

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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