Incorporating Subsidies Into The FCC’s New Map

Incorporating Subsidies Into The FCC’s New Map

Allocating BEAD funds without double-subsidizing some areas requires adding data about money that has already been awarded to relevant maps. Although, as we understand it, NTIA will allocate funds without taking already-funded areas into account,1 the states cannot consider a location “unserved” or “underserved” for the purpose of distributing BEAD money if the location has already been awarded funds from, for example, the Rural Digital Opportunities Fund (RDOF), ARPA via the Capital Projects Fund and the SLFRF at the Department of Treasury, the CARES act, and others.2 Taking subsidies into account can substantially reduce the number of unserved and underserved locations in a state.

This post focuses on the implications of incorporating RDOF areas into the availability fabric. At the risk of being the butt of looking under the streetlight jokes, we start with RDOF simply because the information exists. Other programs do not appear to provide public data on geographic boundaries of their subsidies (yet?). The analysis we present here, therefore, understates the issue since we can only incorporate one of many subsidy programs.

We use the TPI Broadband Mapping Platform to combine the FCC’s new availability fabric data with data on RDOF locations (that had not defaulted as of November 28) in order to identify locations the FCC says are served but are scheduled to receive RDOF subsidies. 

The map of New Hampshire Census Blocks below highlights the issue. The hash marks show Census Blocks with RDOF commitments, while shades of blue show the extent of 25/3 service availability. Many RDOF awards cover locations the new FCC map shows not having 25/3 “reliable service” as NTIA defines it (i.e., excluding satellite and fixed wireless provided by unlicensed spectrum).

New Hampshire, Share of Locations Served at 25/3 by Census Block and Blocks Receiving RDOF Subsidies

The table below shows how the share of unserved and underserved decreases in each state when taking RDOF into account. The figure below shows how the share of unserved and underserved decreases in each state when taking RDOF into account. (Text continues after figure).

The maps below show the change at the county level. (Drag the slider to see estimates from the FCC map and how it changes when incorporating RDOF). Note that on these maps lower numbers (lighter shades) are better as they show the share of unserved and underserved locations. The aspirational policy goal is to push all those numbers towards zero.


Removing areas that are unserved or underserved from the FCC's list naturally reduces the number of locations a state must try to cover with its funds compared to the estimates on the FCC map. This reduction creates opportunities and challenges. Reducing the number of un- and underserved locations in a state after the money has been allocated is significant because it may create opportunities the states to use more funds for the other activities NTIA allows beyond subsidizing infrastructure in unserved and underserved locations:3

  1. Deploying and/or upgrading broadband network facilities to provide or improve service to an eligible community anchor institution
  2. Installing internet and Wi-Fi infrastructure or providing reduced-cost broadband within a multi-family residential building, with priority given to a residential building that has substantial share of unserved households or is in a location in which the percentage of individuals with a household income that is at or below 150 percent of the poverty line applicable to a family of the size involved is higher than the national percentage of such individuals;
  3. Broadband adoption, including programs to provide affordable internet-capable devices;
  4. Training and workforce development; and
  5. Other uses, including other Digital Equity programs not already included above, proposed by Eligible Entities and approved in advance in writing by the Assistant
    Secretary that support the goals of the Program.

The challenge is that states not only need mechanisms to allocate infrastructure funds efficiently (see our Broadband Policy Guidebook on that score) but also ways of prioritizing other broadband objectives and approaching those efficiently. These pots of money are likely to generate a flood of proposals from all kinds of organizations, some with good ideas and some with terrible ideas, most well-meaning but some snake-oil salespeople hoping to capitalize. Without proper foresight, it would be easy for states to waste this money.


  1. Section 60105 of the IIJA requires the FCC to collect information on federal subsidies and integrate that into the map, but -- again, as we understand it -- that will not happen before NTIA uses the map to allocate funds.
  2. "In identifying an Unserved Service Project or Underserved Service Project, an Eligible Entity may not treat as 'unserved' or 'underserved' any location that is already subject to an enforceable federal, state, or local commitment to deploy qualifying broadband...." https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf (Section IV.B.7.a.ii.3)
  3. https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf, p.33

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