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Your numbers look more realistic, for sure. Variables I wonder about:

1. The FCC's new location-based reporting will still accept advertised speeds, which will allow (some) providers to overstate their coverage and block off (some) areas that still need service.

2. Awardees for RDOF and state-funded broadband grants can kick their respective cans down the road, potentially blocking providers who are ready to serve rural areas now. We've seen this movie before, with incumbents either delaying service to promised areas or just flat not serving them.

3. How long will the challenges to the new FCC maps take and will NTIA wait until they are complete - or as Mr. Davidson has said, just jump in at some point and say, "These are good enough." That alone could also disenfranchise some unserved/underserved locations that don't survive the challenge process.

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Good points all around.

On 1) I agree it is an area of concern, but I'm probably less concerned than most. If a location is served by fiber or cable, it is extremely likely to meet the 100/20 definition. To me, the challenge (pun intended) is technologies that sit across the 100/20 or 25/3 boundary and what are the actual throughputs available at any location (at the router) with those technologies?

2) Great point. FCC going to need to keep a super close eye on this

3) Yeah this is interesting. I can understanding wanting to give states one crack at updating the locations. But the "unserved" calculation needs ISP data and that will never be done/perfect...

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Thank you, sir.

One other thing I'm wondering now... in the BEAD NOFO, there is a challenge process an eligible entity (e.g., state) must conduct between submission of its initial proposal and before allocating BEAD funds to subgrantees.

This presents as a second round of challenges, separate from any initial challenges raised upon the release of the FCC's broadband service location maps.

In the context of ensuring states can apply their allocations to the "right" locations, this seems like a reasonable thing, but will it ultimately mean that BEAD funding, which everyone is super-excited about right now, won't be in play until late 2023/early 2024 (or even later) as folks haggle over whether a given location or set of locations is eligible (or not).

I keep thinking I've read somewhere that a service provider will be able to assert a location is served if they can activate service there within 30 (or possibly even 60) days, if that location is challenged. RDOF used a ten business day window; 30 days (and definitely 60) seems like a pretty big net to cast.

Apologies for thinking aloud in your thread - there are a lot of moving parts in these funding programs and I'm trying to get my head around all of them!

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