Overview: BEAD and Community Anchor Institutions

The Infrastructure, Investment & Jobs Act (IIJA) allocated $42B for broadband infrastructure investments through the BEAD Program. This money is being distributed to those states, territories, and tribal areas (“Eligible Entities”) that chose to participate. The BEAD Program and funding allocations are managed by the National Telecommunications and Information Administration (NTIA).

As part of the BEAD program requirements, Eligible Entities must create several documents, including an Initial Proposal. That proposal must include details regarding their treatment of community anchor institutions (“CAI”), such as: 

Only CAIs that lack access to gigabit-level service may qualify for BEAD funding (“Eligible CAIs”). That means that if a CAI can purchase gigabit service, but chooses not to, they do not qualify for funding. 

The IIJA calls upon NTIA to use the FCC’s National Broadband Map in identifying unserved and underserved locations.  Unfortunately, the FCC’s Map does not do a good job of collecting data concerning anchor institutions.  NTIA has recently given Eligible Entities the authority to develop their own sources of information regarding CAI broadband, and States can rely upon the information provided by the CAI itself. CAIs must seize the opportunity to provide this data to their state broadband offices if they are to receive the gigabit-level connections called for in the legislation. 

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Community anchors can help bridge the digital divide

As Eligible Entities create their BEAD project plans, including their Initial Proposals, it is important for them to consider how best to include CAIs. CAIs like schools, libraries, and hospitals are often the primary means of accessing reliable internet, devices, and digital skills training in communities around the United States. 


CAIs also play an important role in filling broadband infrastructure gaps; In some cases CAIs can facilitate connectivity to their local communities in ways that are more efficient, and make use of existing infrastructure. For example, CAIs can serve as anchor tenants on a network, strengthening its economic viability, and work as a connectivity “hub” to the surrounding community. In addition, anchor institutions with multi-gigabit connections can be a “jumping off point” to extend service to unserved/underserved homes. This “To and Through” approach supports connecting CAIs early in the build-out timeline as a cost-effective way to build last-mile connections to the home. Furthermore, this approach of connecting community households AND the CAIs can provide better service in areas most in need of broadband infrastructure, and the services and support that CAIs can provide. As long as Eligible Entities have a plan that prioritizes connecting all unserved/underserved homes with high-capacity last mile broadband, connecting the Eligible CAI is allowed.

 

An analysis of State Five-Year plans shows that many states are considering innovative uses of CAIs in their infrastructure plans. Here are some examples:

  • Louisiana’s plan views CAIs as Internet access points during natural disasters, and are prioritizing wired/weather-proof connectivity for their anchors. 
  • Ohio’s plan calls for CAIs to serve as digital hubs with publicly available internet. These digital hubs will be located within 5-10 minute walk of each other, particularly in rural areas.
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How can states, territories and tribal areas include CAIs in their infrastructure plans?

According to the BEAD NOFO and NTIA State Challenge Guidance, Eligible Entities must:

  • develop their own state definition of a CAI (Click here for more details)
  • identify the physical location of each CAI in the state;
  • Assess whether CAIs have access to gigabit service, and identify those that are eligible for BEAD funding;
  • list other institutions that they considered, but decided did not meet their definition of a CAI
 

Furthermore, if Eligible Entities choose to include institutions that fall into categories not explicitly listed in the BEAD NOFO, they must explain how those CAIs provide access to broadband services in marginalized communities. (Source: Section 60102(a)(2)(E) of BEAD NOFO).

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Challenges of identifying CAIs

The BEAD NOFO calls for states to develop an inventory of CAI assets in their states. Most states are aware of larger CAIs, such educational institutions, libraries, health care providers, and government agencies.  Identifying other types of CAIs beyond this group may be harder. SHLB has spoken with several state broadband offices, GIS mapping experts, and other engaged parties, and gathered information about how states are going about identifying their CAIs. Some of the resources that broadband offices are engaging with include:

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Can CAIs be included through the challenge process?

The Initial Proposal must describe a state-led challenge process, whereby certain third party stakeholders can challenge the information an Eligible Entity provides in its Initial Proposal. (For example, if an Eligible Entity describes a location as unserved, and that it intends to deploy infrastructure to it, a challenger can respond by stating that this location is actually already served by broadband, or vice versa.)

 

The time tables for each challenge process varies depending on when NTIA approves the Eligible Entity’s Initial Proposal.

 

Eligible Entities should strongly encourage CAIs to take advantage of the challenge process to self-identify by adding themselves to state inventories, and making officials aware of broadband availability in their communities.

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How can Eligible Entities determine what is or is not a CAI?

According to the BEAD NOFO, “The term ‘‘community anchor institution’’ means an entity such as a school, library, health clinic, health center, hospital or other medical provider, public safety entity, institution of higher education, public housing organization, or community support organization that facilitates greater use of broadband service by vulnerable populations, including low-income individuals, unemployed individuals, and aged individuals”

FROM THE BILL LAW, p. 755: Section 60102(a)(2)(E)

 

SHLB recognizes that the kinds of institutions that might serve as anchors can vary from community to community. For example, in some rural and unincorporated areas, there may not be a school, library, or other traditional form of anchor institution. In those communities, a  business may serve as a primary gathering place, and may be the only option for community members in unserved areas to access the internet. Similarly, some community-support organizations may adopt a for-profit model, although they remain focused on a public service mission. 

 

Here are some examples of how states are expanding the definition of CAIs:

  • Vermont is expanding the definition of CAIs to include houses of worship, correctional facilities and juvenile detention centers, public access television station facilities, and public outdoor spaces
  • Indiana's definition includes religious centers, outdoor parks, hotels, car parks/gas stations, among others
  • Montana is including ranger stations and bar and grills in its defintion of CAIs
  • Ohio is also expanding its definition to include public parks and campgrounds, pre-kindergarden schools, homeless shelters, halfway houses. refugee settlement centers, YMCAs, Jewish Community Centers (JCCs), food banks, places of worship, grocery stores dedicated to specific ethnic groups, hair salons, laundromats, and coffee shops, among others

*Please note that state proposals still need to be reviewed by NTIA and are not final

Click here to learn more about SHLB's model definition of CAIs