Estimating the Size of a BEAD Rainy-Day Fund Focused on Bolstering Last Mile Connectivity Projects

Vernonburg Groug recently released a blog describing broad and growing bipartisan support for allowing state and territorial broadband offices to use their remaining uncommitted Broadband Equity, Access, and Deployment (BEAD) funds for broadband projects that further the Infrastructure Investment and Jobs Act’s (IIJA) direction that Eligible Entities use allocated funds to “facilitate the goals of the BEAD program.” One potential use for these remaining funds would be for the National Telecommunications and Information Administration (NTIA) to allow Eligible Entities to reserve a portion of their allocated but uncommitted BEAD funding for a “rainy-day fund” focused on bolstering BEAD-funded last mile connectivity projects and ensuring that high-speed last mile infrastructure is extended to unserved and underserved locations not identified for support in the first round of BEAD funding. Ultimately, NTIA could adopt a requirement for Eligible Entities to reserve a portion of their remaining BEAD funds to bolster their last mile connectivity programs with percentages varying based on the presence of RDOF defaults. NTIA could then allow allocated funding in excess of these amounts—approximately $15 billion—to be spent on other NTIA-approved and statutorily-permitted uses. This is a prudent approach that will greatly increase the likelihood that last-mile infrastructure projects will be successfully completed and sustained.