Top broadband leaders in Illinois are concerned that changes to the federal Broadband Equity, Access, and Deployment (BEAD) Program could leave rural communities unconnected. Mandated changes—if they come from either Congress or the U.S. Department of Commerce—could force states to rerun their entire BEAD sub-grantee selection processes. The resulting delays will cost ISPs across the country hundreds of millions of dollars in time and resources to plan for the new program guidelines and reapply for awards.

A Breakdown of Estimated Delays

The Illinois Office of Broadband, within the Illinois Department of Commerce and Economic Opportunity, estimates that wholesale changes to BEAD will result in broadband deployment delays. Here’s how. 

Changes to…

• Technology requirements, such as changing the definition of “reliable broadband service” to include unlicensed fixed wireless and low-earth orbit (LEO) satellite 
• Labor policy, which is a part of Illinois’ BEAD grant scoring criteria (e.g., awarding points for use of project labor agreements)
• The low-cost service option that is required by law as part of all BEAD-funded projects

Would require the Illinois Office of Broadband to…

• Revise state broadband program administrative rules, which requires approval of the Illinois General Assembly. (~4-6 months)
• Revise the BEAD-funded Connect Illinois Round 4 Notice of Funding Opportunity (~1 month)
• Rerun the state mapping challenge process to recalculate eligible locations (~9 months)
• Revise the State’s Initial Proposal Volume II and rerun completed first wave of the BEAD subgrantee selection process (~6-9 months)

Resulting in deployment delays of up to two years. 

The largest of these estimated delays includes rerunning the state mapping challenge process and revising the state’s Initial Proposal Volume II so the state is able to rerun the first wave of subgrantee selection. These steps alone would take 15-18 months.

The original challenge process took nearly nine months to complete. Its purpose was to determine, using the FCC Broadband Map, along with provider, non-profit, and local government input, which locations in the state lacked access to reliable broadband service. Should the definition of Reliable Broadband Service change, the Illinois broadband map may need to change along with it. Updating this map would require the Illinois Office of Broadband to:

• Revive and update the challenge portal.
• Issue guidance and rules documentation.
• Conduct awareness and outreach campaigns.
• Complete review, rebuttal, and adjudication phases.
• Prepare the challenge process data in the correct format for submission to the U.S. Department of Commerce's National Telecommunications and Information Administration (NTIA).
• Submit the challenge process results to NTIA.
• Complete NTIA curing processes. 

Repeating this process would mean duplicating costs associated with platform management, staff time, and external reviewers. Additionally, data request fatigue could lead to lower engagement from both communities and ISPs, making it harder to collect meaningful input.

Revising the Initial Proposal Volume II and rerunning the already completed Wave 1 of BEAD subgrantee selection would take between six and nine months, depending on the results of NTIA’s review of the BEAD program. Depending on those results, the Illinois Office of Broadband would be required to:

• Identify and implement required changes to the State’s already approved Initial Proposal Volume II based on new BEAD program rules.
• Submit and complete the curing processes with NTIA for the updated Initial Proposal Volume II.
• Update the BEAD-funded Connect Illinois Round 4 application and templates to reflect new BEAD program rules.
• Conduct webinars and outreach to explain new program rules.
• Rerun the BEAD-funded Connect Illinois Round 4 Wave 1 (including requalifying applicants, accepting ISP submissions, re-scoring using a new rubric, conducting deconfliction and resubmissions, and issuing preliminary awards).

Not Just Illinois

In Illinois, BEAD subgrantee selection has begun, as it has in 41 other states. The first wave of application submissions has already been concluded. Applicants’ submissions propose to cover 86 percent of BEAD-eligible locations in the state, with end-to-end fiber proposals covering 66 percent of eligible locations. Many of these locations are among the hardest to serve in the entire state.

The Illinois Office of Broadband recently delivered remarks to State Connections, a national working group of state legislators focused on broadband issues. The message: lawmakers across the country should—

1. Understand the status of the BEAD program in their state, and 
2. Encourage the Department of Commerce and Congress to avoid wholesale changes to the BEAD Program. 

BEAD is being implemented according to the bipartisan Infrastructure Investment and Jobs Act. Changes from NTIA or Congress at this stage could rip autonomy away from the states and undo the strong outcomes states are achieving across the country (e.g., West Virginia was on track to bring fiber service to 100% of its BEAD-eligible locations before pausing in anticipation of federal changes).

Illinois Office of Broadband Director Devon Braunstein has a simple message for the U.S. Commerce Department and Congress: Let the states finish what they started. 

The Illinois Office of Broadband, as well as state broadband offices across the country, has worked for nearly three years to create a plan to deploy broadband networks to all unserved and underserved locations in its territory. The Trump Administration’s current delay of the BEAD Program is imposing costs on states and ISPs and inhibiting local economic development and job creation. Changing BEAD would exacerbate these costs and, potentially, extend the digital divide.  

In a letter to broadband stakeholders, Braunstein asked them to: 

Reid Sharkey is a Community Broadband Specialist & Research Associate at the Benton Institute for Broadband & Society. He completed a year of Americorps service in 2023 which was his introduction to working in broadband and digital equity policy. Sharkey first worked with the Benton Institute during his service term. He assisted in administering the Benton Institute's Accelerate community engagement and broadband infrastructure planning program in Tennessee, where he was serving as an American Connection Corps Fellow at the Tennessee Department of Economic and Community Development. Reid received a Masters of Public Policy from George Mason University in 2022.

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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