Three Questions About BEAD Non-Deployment Funding

The Department of Commerce’s National Telecommunications and Information Administration (NTIA) recently announced sweeping changes to the Broadband Equity, Access, and Deployment (BEAD) Program. Included in the BEAD Restructuring Policy Notice from NTIA is instruction that “funding for allowable non-deployment purposes is under review and NTIA will issue updated guidance in the future.” This is a reversal of NTIA’s prior position. Before the Policy Notice was issued, NTIA had approved non-deployment activities in states’ Initial Proposals; the Policy Notice rescinds those prior approvals and indicates that Final Proposals need not describe non-deployment projects. 

Non-deployment funds refer to BEAD funds that are left over after a state meets BEAD’s infrastructure deployment requirements. Under NTIA’s previous guidance, non-deployment funds could be used for projects related to broadband adoption, providing devices, digital skills training, and other activities to complement BEAD’s universal connectivity goals. But now, while NTIA develops new guidance, it is unclear how non-deployment funds can be used, or if the funds will even be available for such purposes.

 

1. What is non-deployment BEAD funding?

If a state can demonstrate that it would be able to serve all unserved and underserved locations with “affordable, high-speed broadband service,” remaining funds in the state’s allocation can be directed towards non-deployment activities. NTIA’s original BEAD Notice of Funding Opportunity (NOFO) “strongly urges” that funds be allocated to connect eligible community anchor institutions (CAIs) prior to considering funding non-deployment activities, though a state could provide justification for prioritizing non-deployment projects over deployment of service to eligible CAIs.

A list of eligible non-deployment activities in the original BEAD NOFO includes:

1. Cybersecurity and privacy training,
2. Remote learning or telehealth services/facilities,
3. Digital skills training (including basic digital literacy and more advanced upskilling programs),
4. Computer science, coding and cybersecurity education programs,
5. Implementation of digital equity plans,
6. Broadband sign-up assistance and tech support,
7. Multi-lingual outreach to support adoption and digital literacy,
8. Prisoner education to promote pre-release digital literacy, job skills, and online job-acquisition skills,
9. Digital navigators,
10. Direct subsidies for use toward broadband subscriptions that improve affordability,
11. Costs associated with stakeholder engagement, and
12. Other allowable costs necessary to carrying out programmatic activities of an award, not to include ineligible costs described in the NOFO (e.g., to support or oppose collective bargaining, administrative expenses beyond a 2% cap)

The NOFO stipulates that non-deployment projects are not limited to the listed activities; the list functions as suggestions or examples. It also allows for non-deployment activities to proceed before and during broadband deployment, in recognition that the timeline for deployment projects may be lengthy. If an adequate plan to serve all unserved and underserved locations is in place, the NOFO imposes no requirement to wait to conduct non-deployment activities. The state may also decide to subgrant funds through a competitive selection process.

The list of activities indicates that non-deployment funds are complementary to deployment projects: they would support adoption of networks built with deployment funds, better equip the public with digital skills, and create conditions to encourage specific beneficial uses of networks, such as online learning and telehealth. For states with fewer unserved and underserved locations, non-deployment funds present an attractive opportunity to maximize return on investment for new and existing network infrastructure by increasing adoption and use.

2. What were the shovel-ready states planning to do with non-deployment funding?

Prior to the June 6 BEAD Restructuring Policy Notice, three states had received approval for their BEAD Final Proposals—Delaware, Louisiana, and Nevada—with one more nearing approval, West Virginia. Three of these Final Proposals included plans for non-deployment activities. [Nevada’s plan indicated that no non-deployment projects would be supported with BEAD funding.] 

The amount of funding allocated for non-deployment projects in the Final Proposals varied widely (indeterminate for Delaware, $510 million for Louisiana, $154 million for West Virginia), as did the nature of projects. Assistance for education, health, and workforce and economic development features prominently across the proposals. Though some of these projects resemble eligible uses listed in the NOFO (especially those involving digital skills training, telehealth, and the corrections system), many go beyond those suggestions, such as upgrading networking hardware, assisting businesses in adopting digital tools, and developing the broadband workforce.

In addition, Delaware and West Virginia propose addressing gaps in mobile service coverage with non-deployment funds. Importantly, non-deployment projects with direct benefits to BEAD deployment projects, such as mapping underground utilities (Louisiana) and centralizing information about utility poles (West Virginia), are among them. The projects listed here are just a sample of those that the 56 states and territories aimed to conduct with what they had left after connecting all unserved, underserved, and community anchor locations. 

Delaware 

Delaware’s Final Proposal (draft for public comment) detailed five non-deployment projects, including a combination of state-administered and competitive grant activities. The amounts of funding associated with each project were not yet determined in the document.

• The Statewide Internet Resiliency Program would have funded two carrier-neutral Internet Exchange Points (IXPs) in Sussex County (home to Delaware’s rural population) and at the University of Delaware. 
• The Wireless Resiliency Program would have mapped mobile dead zones and led to the issuance of a competitive Request for Proposal (RFP) to build carrier-neutral towers.
• The Public School Cybersecurity and Resiliency Program would have replaced and standardized networking equipment in schools.
• Community Connection Hubs would have provided support for CAIs to provide internet access, affordable devices, and digital skills training to the public.
• The Workforce Investment and Digital Upskilling Program would provide funds to establish and improve workforce development programs that better respond to employers’ needs for workers with technical skills.

Louisiana

Louisiana’s Final Proposal described four non-deployment projects to be carried out by the state and six to be conducted via a competitive grant process. Louisiana estimated that $510 million would have been allocated for the following work.

State Projects

• The Louisiana Department of Administration would have received $50 million to supplement efforts at mapping underground utilities, including those along BEAD-funded fiber deployment routes.
• The Louisiana Board of Regents would have received $50 million to supplement funding to launch new degree and credentialing programs in “digitally-focused areas,” incorporate digital skills in other degree and credentialing programs, expand existing programs to institutions across the 34 members of four Louisiana higher education systems, and market these programs.
• The Louisiana Department of Public Safety & Corrections would have received $20 million to supplement efforts in correctional facilities to expand work-based learning and training programs related to digital skills, embed digital skills in work-based learning programs, and implement and scale access to a platform with reentry employment opportunities.
• The Louisiana State University AgCenter would have received $20 million to purchase Internet of Things (IoT) tools and train farmers in their use, as well as to supplement efforts at training farmers in advanced precision agriculture techniques customized for small-scale and non-commodity producers.

Subgrantee Projects

• $100 million to care providers, academic institutions, non-profits, and startups with a telehealth focus for telehealth expansion and broadband-enabled interventions for maternal health, behavioral health, and chronic disease.
• $100 million to local workforce boards for workforce development for training programs for broadband-specific roles and related jobs; credentialing, job placement, and wraparound services for trainees; regional collaboration among workforce development entities; and promotion of digital skills training
• $100 million to K-12 school systems to provide and expand virtual tutoring programs, create and implement virtual courses, adopt and scale digital tools (e.g., digital math platform, digital education platform with accessibility features), upgrade cybersecurity equipment and measures
• $30 million to training providers, small business development centers, and small businesses for promoting digital skill development and conducting outreach about digitization in small businesses, expanding online services for small businesses, and adopting digital tools within small businesses
• $30 million to “legacy businesses” in specific industries to digitize operations, enhance employees’ digital skills, adopt digital tools, and find new broadband-related business opportunities
• $10 million to state parks to expand Wi-FI coverage and market the improvement, focused on 41 parks in BEAD deployment sub-project areas, obtain digital tools for park rangers to better serve visitors with disabilities, establish a mobile emergency alert system, and digitize guest check-in and locks for campgrounds and cabins.

West Virginia

West Virginia’s draft Final Proposal (never released for public comment) described two non-deployment projects to be carried out by the state and two to be conducted via a competitive grant process. In total, West Virginia planned to allocate $154 million for these efforts. 

State Projects

• $30 million to create a pole inspection database, contract with pole-owning utilities to collect data about poles and populate the database, contract with pole-owning utilities or others to perform pole replacement and make-ready work as needed for BEAD deployment projects, and monitor pole betterment work
• $4 million to the West Virginia Network (WVNET) to upgrade network equipment that is obsolete, vulnerable to security breaches, and unsuited to meet growing bandwidth demands 

Subgrantee Projects

• $90 million to mobile network operators to expand service at locations that lack access to 4G or better mobile wireless service and/or expand service along to be defined “Target Corridors” that lack access to consistent coverage from at least one national mobile network operator
• $30 million to offer credentialing programs that would lead to employment in the broadband sector and work-based learning programs. The funding was expected to flow to entities like higher education institutions, career and technical education institutions and student organizations, public-private partnerships, county boards of education, K-12 schools and districts, workforce development organizations, industry associations, and employers.

3. What happens next?

As NTIA reviews non-deployment funding and develops updated guidance, stakeholders should pay careful attention. The Infrastructure Investment and Jobs Act directs the Use of Funds for broadband service in unserved and underserved locations; connecting eligible community anchor institutions; collecting data, mapping, and planning; installing internet and Wi-Fi infrastructure or providing reduced-cost broadband in low-income multi-family residential buildings; broadband adoption, including device provision; and other uses that NTIA determines facilitate the goals of the BEAD Program. As NTIA revises its guidance about non-deployment funds, the “other uses” that NTIA previously approved could be on the chopping block.

Yet, there is strong support for non-deployment uses of BEAD funding. Texas Comptroller of Public Accounts Glenn Hegar writes in a March 4, 2025 letter of his support for “complementary, common-sense, non-deployment initiatives such as workforce development, small business growth, education, and healthcare improvements that will enhance quality of life and drive economic growth.” Versions of state proposals drafted before the June 6 Policy Notice illustrated the importance of non-deployment projects, identifying how each project complemented deployment spending and contributed to the goals of the BEAD Program. 

While it might appear at first glance that savings could be attained by removing non-deployment uses from eligible BEAD funding, unspent BEAD funds would be redistributed to other states for BEAD-eligible activities rather than returned to the U.S. Treasury. Non-deployment activities are consistent with the Infrastructure Investment and Jobs Act, and the NTIA’s Policy Notice modifies the original Notice of Funding Opportunity, not, of course, the law itself. 

Non-deployment activities, if allowed, could certainly increase the return on BEAD deployment investments by fostering adoption and use of broadband. The diversity of previously approved non-deployment projects underscores that there are many sectors and communities that will benefit from new broadband infrastructure, as well as many strategies to catalyze those benefits. 

Dr. Caroline Stratton is the Research Director for the Benton Institute for Broadband & Society. 
 

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.

---

© Benton Institute for Broadband & Society 2025. Redistribution of this email publication – both internally and externally – is encouraged if it includes this copyright statement.

---

For subscribe/unsubscribe info, please email headlinesATbentonDOTorg

Kevin Taglang
Executive Editor, Communications-related Headlines
Benton Institute
for Broadband & Society
1041 Ridge Rd, Unit 214
Wilmette, IL 60091
847-220-4531
headlines AT benton DOT org

Share this edition:

Broadband Delivers Opportunities and Strengthens Communities