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Final Proposal (Project Narrative) Broadband Equity, Access, and Deployment (BEAD) Program Final Proposal December 2025 In compliance with the BEAD NOFO, as modified by NTIA’s BEAD Restructuring Policy Notice Contents Final Proposal Data Submission Attachment (Required): Complete and submit the Subgrantees CSV file (named “fp_subgrantees.csv”) using the NTIA template provided. See attachment. Attachment (Required): Complete and submit the Deployment Projects CSV file (named “fp_deployment_projects.csv”) using the NTIA template provided. See attachment. Attachment (Required): Complete and submit the Locations CSV file (named “fp_locations.csv”) using the NTIA template provided. The Location IDs in this list must match the NTIA-approved final list of eligible locations. See attachment. Attachment (Required): Complete and submit the No BEAD Locations CSV file (named “fp_no_BEAD_locations.csv”) using the NTIA template provided. The Location IDs in this list must match the NTIA-approved final list of eligible locations. See attachment. Question (Y/N): If the Eligible Entity intends to use BEAD funds to serve CAIs, does the Eligible Entity certify that it ensures coverage of broadband service to all unserved and underserved locations, as identified in the NTIA-approved final list of eligible locations and required under 47 U.S.C. § 1702(h)(2)? locations. N/A Attachment (Required – Conditional on a ‘Yes’ Response to Intake Question 0.5): Complete and submit the CAIs CSV file (named “fp_cai.csv”) using the NTIA template provided. Although CAIs are not included under (f)(1) deployment projects, to confirm the Eligible Entity’s compliance with the BEAD prioritization framework and identify BEAD-funded CAIs, the NTIA template is required. The Eligible Entity must only include CAls funded via BEAD in this list; the Eligible Entity may not propose funding CAls that were not present on the approved final list from the Eligible Entity's Challenge Process results. See attachment. Subgrantee Selection Process Outcomes (Requirement 1) Relevant Instructions from the Infrastructure Act, 47 U.S.C. § 1702 (e)(4)(A)(i)(I): the eligible entity may submit a final proposal for the remainder of the amount allocated to the eligible entity ... that includes- (1) a detailed plan that specifies how the eligible entity will- (aa) allocate grant funds for the deployment of broadband networks to unserved locations and underserved locations, in accordance with subsection (h)(1)(A)(i); and (bb) align the grant funds allocated to the eligible entity under subsection (c), where practicable, with the use of other funds that the eligible entity receives from the Federal Government, a State, or a private entity for related purposes Relevant Instructions from BEAD Restructuring Policy Notice Section 3.3, Pages 10 -11: ... NTIA is requiring Eligible Entities to conduct at least one additional subgrantee selection round for every BEAD-eligible location (the "Benefit of the Bargain Round"). The Benefit of the Bargain Round must permit all applicants - regardless of technology employed or prior participation in the program - to compete on a level playing field undistorted by the non-statutory regulatory burdens eliminated above. All subgrantee selection conducted after the release of this Policy Notice must comply with the terms of this Policy Notice. Eligible Entities must rescind all preliminary and provisional subaward selections and notify applicants that a further round of applications will be considered before final awards are made. Eligible Entities that have already completed subgrantee selection must conduct at least one Benefit of the Bargain round. Eligible Entities have 90 days to comply with the obligations outlined within this Policy Notice and submit a Final Proposal that reflects the results of the Benefit of the Bargain round. This deadline replaces the deadline extensions previously granted in the Programmatic Waiver of the Final Proposal Deadline Requirements. NTIA will complete its review of each Final Proposal within 90 days of submission. To the extent an Eligible Entity has a prequalification process, it must be reopened to all interested applicants, although the Eligible Entity may make prequalification submissions part of the application package. Existing qualified applicants do not need to resubmit prequalification documentation. If an applicant previously failed the prequalification process, it may choose to update its materials and seek prequalification again. Eligible Entities, however, must still ensure that applicants meet the financial and managerial capacity, technical and operational capability, and other requirements in 47 U.S.C. § 1702(g)(2)(A). Where an applicant elects to stand on an existing subgrantee application received prior to the publication of this Policy Notice, that application shall be rescored under the rubric detailed below and may be awarded during the Benefit of the Bargain round, but no BEAD subgrantee will be permitted to recover costs to comply with the regulatory burdens eliminated in this Policy Notice. Existing applicants may also choose to submit a new application that eliminates the cost of these regulatory burdens in anticipation of competition from additional applicants. Eligible Entities must exclude all non-statutory regulatory burdens as identified above from the application and scoring processes for subgrantee selection. Eligible Entities must also allow applicants to propose to exclude select broadband serviceable locations (BSLs) that the applicant determines are excessively high-cost locations from the project area (or would otherwise make the project economically unviable for the technology being used). Relevant Instructions from the BEAD Restructuring Policy Notice Section 4, Page 14: Eligible Entities must revise their list of eligible Community Anchor Institutions (CAls) to ensure their designations conform with the statutory definition of a CAI as established by IIJA (47 U.S.C. §1702(a)(2)(E)). NTIA hereby revokes the more expansive definition adopted by the NOFO (NOFO, Section I.C.(f), pgs. 11-120). NTIA will closely review all CAI submissions and will narrowly interpret the term "community support organization" as used in the statute. NTIA reserves the right to reject any CAI designation. Text Box: Describe how the Eligible Entity’s deployment Subgrantee Selection Process undertaken is consistent with that approved by NTIA in Volume II of the Initial Proposal as modified by the BEAD Restructuring Policy Notice. If the Eligible Entity has completed or is in the process of completing its Subgrantee Selection Process at the time of the release of the BEAD Restructuring Policy Notice, the Eligible Entity must use this section to describe how it conducted at least one additional “Benefit of the Bargain Round” for every BEAD-eligible location. The Eligible Entity must detail how it conducted the “Benefit of the Bargain” round, including how it addressed prequalification (if applicable) and resubmission of applications. USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box: Describe the steps that the Eligible Entity took to ensure a fair, open, and competitive process, including processes in place to ensure training, qualifications, and objectiveness of reviewers. USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box: Affirm that, when no application was initially received, the Eligible Entity followed a procedure consistent with the process approved in the Initial Proposal. USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box: If applicable, describe the Eligible Entity’s methodology for revising its eligible CAI list to conform with Section 4 of the BEAD Restructuring Policy Notice. USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Question (Y/N): Certify that the Eligible Entity will retain all subgrantee records in accordance with 2 C.F.R. § 200.334 at all times, including retaining subgrantee records for a period of at least 3 years from the date of submission of the subgrant’s final expenditure report. This should include all subgrantee network designs, diagrams, project costs, build-out timelines and milestones for project implementation, and capital investment schedules submitted as a part of the application process. Yes Intentionally Omitted This section is intentionally left blank. The BEAD program Notice of Funding Opportunity does not include a Requirement 2 for the Final Proposal. Section 2 is also omitted from NTIA’s “BEAD Final Proposal Guidance for Eligible Entities (Version 2.1)” (July 2025). Timeline for Implementation (Requirement 3) Relevant Instructions from NOFO Section IV.B.9.b, Page 47: The Final Proposal must include…: 3. A timeline for implementation of the detailed plan and completion of each project and other eligible activity to be funded. Relevant Instructions from BEAD NOFO Section IV.D.2.c., Page 74: Prospective subgrantees must submit a network design, diagram, project costs, build-out timeline and milestones for project implementation, and a capital investment schedule evidencing complete build-out and the initiation of service within four years of the date on which the entity receives the subgrant, all certified by a professional engineer, stating that the proposed network can deliver broadband service that meets the requisite performance requirements to all locations served by the Project. An Eligible Entity shall not approve any grant for the deployment or upgrading of network facilities unless it determines that the materials submitted to it demonstrate the prospective subgrantee’s technical capability with respect to the proposed project. Relevant Instructions from NOFO Section II.B, Page 18: As established in [47 U.S.C. § 1702(h)(4)(C)], subgrantees that receive BEAD Program funds for network deployment must deploy the planned broadband network and begin providing services to each customer that desires broadband service within the project area not later than four years after the date on which the subgrantee receives the subgrant from the Eligible Entity. Text Box: Has the Eligible Entity taken measures to: ensure that each subgrantee will begin providing services to each customer that desires broadband service within the project area not later than four years after the date on which the subgrantee receives the subgrant; ensure that all BEAD subgrant activities are completed at least 120 days prior to the end of the period of performance, in accordance with 2 C.F.R. 200.344; and ensure that all programmatic BEAD grant activities undertaken by the Eligible Entity are completed by the end of the period of performance for its award, in accordance with 2 C.F.R. 200.344. USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Oversight and Accountability Processes (Requirement 4) Relevant Instructions from NOFO Section IV.B.9.b, Page 47: The Final Proposal must include…: 4. Processes for oversight and accountability to ensure the proper use of the grant funds allocated to the Eligible Entity under the BEAD Program consistent with Section IX.G of this NOFO. Relevant Instructions from NOFO Section IV.C.1.b, Page 51: In addition to demonstrating how it expects to satisfy the subrecipient monitoring and management requirements identified in 2 C.F.R. Part 200 Subpart D, each Eligible Entity must include sufficient accountability procedures within its program to ensure subgrantee compliance with all applicable Program requirements. Each Eligible Entity must, at a minimum, include in any subgrant agreement reasonable provisions allowing for recovery of funds in the event of a subgrantee’s noncompliance with the BEAD Program’s requirements, including but not limited to failure to deploy network infrastructure in accordance with mandated deadlines. Each Eligible Entity must, at a minimum, employ the following practices: (1) distribution of funding to subgrantees for, at a minimum, all deployment projects on a reimbursable basis (which would allow the Eligible Entity to withhold funds if the subgrantee fails to take the actions the funds are meant to subsidize); (2) the inclusion of clawback provisions (i.e., provisions allowing recoupment of funds previously disbursed) in agreements between the Eligible Entity and any subgrantee; (3) timely subgrantee reporting mandates; and (4) robust subgrantee monitoring practices. NTIA will review proposed subgrant processes during the Initial Proposal and Final Proposal review phases and will reject Proposals that fail to provide sufficient recourse against subgrantees that do not fulfill their legal and contractual responsibilities. NTIA likewise will pursue clawback of funds directly from Eligible Entities that fail to ensure subgrantee accountability to the fullest extent of the law. Relevant Instructions from NOFO Section IX.G.1, Pages 95: NTIA, Eligible Entities, and subgrantees each have a critical role to play in ensuring that the BEAD Program is implemented in a manner that ensures transparency, accountability, and oversight sufficient to, among other things: Minimize the opportunity for waste, fraud, and abuse; Ensure that recipients of grants under the Program use grant funds to further the overall purpose of the Program in compliance with the requirements of the Infrastructure Act, this NOFO, 2 C.F.R. Part 200, the terms and conditions of the award, and other applicable law; and Allow the public to understand and monitor grants and subgrants awarded under the Program. To that end, NTIA and Eligible Entities shall: Conduct such audits of grantees and subgrantees as are necessary and appropriate, including audit requirements described in Section VII.G. Eligible Entities shall report the full results of any audits they conduct to the appropriate Federal Program Officer. Develop monitoring plans, subject to the approval of the Assistant Secretary, which may include site visits or desk reviews, technical assistance, and random sampling of compliance requirements. Impose specific conditions on grant awards designed to mitigate the risk of nonperformance where appropriate. Each Eligible Entity and/or subgrantee shall, as appropriate: Comply with the reporting requirements set forth in Section I.E of this NOFO. Comply with the obligations set forth in 2 C.F.R. Part 200 and the Department of Commerce Financial Assistance Standard Terms and Conditions. Establish and widely publicize telephone numbers and email addresses for the Eligible Entity’s Office of Inspector General (or comparable entity) or subgrantees’ internal ethics office (or comparable entity) for the purpose of reporting waste, fraud or abuse in the Program. Eligible Entities and subgrantees shall produce copies of materials used for such purpose upon request of the Federal Program Officer. Question (Y/N): Does the Eligible Entity have a public waste, fraud, and abuse hotline and a plan to publicize the contact information for this hotline? Yes Attachments (Required): Upload the following two required documents: 4.2(1) BEAD Program Monitoring Plan See attached BEAD Program Monitoring Plan. 4.2(2) Agency policy documentation which includes the following practices: Distribution of funding to subgrantees for, at a minimum, all deployment projects on a reimbursable basis (which would allow the Eligible Entity to withhold funds if the subgrantee fails to take the actions the funds are meant to subsidize) or on a basis determined by the terms and conditions of a fixed amount subaward agreement; and Timely subgrantee (to Eligible Entity) reporting mandates See attached Agency Policy Documentation. Question (Y/N): Certify that the subgrant agreements will include, at a minimum, the following conditions: Compliance with Section VII.E of the BEAD NOFO, as modified by the BEAD Restructuring Policy Notice, including timely subgrantee reporting mandates, including at least semiannual reporting, for the duration of the subgrant to track the effectiveness of the use of funds provided; Compliance with obligations set forth in 2 C.F.R. Part 200 and the Department of Commerce Financial Assistance Standard Terms and Conditions; Compliance with all relevant obligations in the Eligible Entity’s approved Initial and Final Proposals, including the BEAD General Terms and Conditions and the Specific Award Conditions incorporated into the Eligible Entity’s BEAD award; Subgrantee accountability practices that include distribution of funding to subgrantees for, at a minimum, all deployment projects on a reimbursable basis; Subgrantee accountability practices that include the use of clawback provisions between the Eligible Entity and any subgrantee (i.e., provisions allowing recoupment of funds previously disbursed); Mandate for subgrantees to publicize telephone numbers and email addresses for the Eligible Entity’s Office of Inspector General (or comparable entity) and/or subgrantees’ internal ethics office (or comparable entity) for the purpose of reporting waste, fraud or abuse in the Program. This includes an acknowledge of the responsibility to produce copies of materials used for such purposes upon request of the Federal Program Officer; and Mechanisms to provide effective oversight, such as subgrantee accountability procedures and practices in use during subgrantee performance, financial management, compliance, and program performance at regular intervals to ensure that subgrantee performance is consistently assessed and tracked over time. Yes Local Coordination (Requirement 5) Relevant Instructions from the Infrastructure Act, 47 U.S.C. 1702 § (e)(4)(A)(ii): The local coordination requirements ... shall include, at minimum, an opportunity for political subdivisions of an eligible entity to- (aa) submit plans for consideration by the eligible entity; and (bb) comment on the initial proposal of the eligible entity before the initial proposal is submitted to the Assistant Secretary. Relevant Instructions from the BEAD Restructuring Policy Notice Section 2.4, Page 6: NTIA concludes that an Eligible Entity shall satisfy this requirement [local coordination] by certifying that it observed the Final Proposal public comment requirements and received plan submitted by political subdivisions up until submission of the Final Proposal to NTIA. Text Box: Describe the public comment period and provide a high-level summary of the comments received by the Eligible Entity during the public comment period, including how the Eligible Entity addressed the comments. The response must demonstrate Eligible Entity met the following requirements: The public comment period was no less than 7 days; and Political subdivisions were afforded an opportunity to submit comments during the comment period. USVI is publishing draft Final Proposal for transparency purposes though at the moment it has not run a subgrantee selection process due to no BEAD-eligible locations for deployment projects. This section will be completed following the public comment period. Challenge Process Results (Requirement 6) Relevant Instructions from BEAD NOFO Section IV.B.9.b, Page 47: The Final Proposal must include…: 6. Description of the results of the challenge process conducted by the Eligible Entity under Section IV.B.6. Question (Y/N): Certify that the Eligible Entity has successfully completed the BEAD Challenge Process and received approval of the results from NTIA. Yes Text Box: Provide a link to the website where the Eligible Entity has publicly posted the final location classifications (unserved/underserved/CAIs) and note the date that it was publicly posted. Following approval of the Challenge Process by NTIA, USVI OMB publicly posted the final location classifications on their website on https://omb.vi.gov/bead-challenge-results/. Date publicly posted: August 7, 2025 Unserved and Underserved Locations (Requirement 7) Relevant Instructions from BEAD NOFO Section IV.B.9.b, Page 47: The Final Proposal must include…: 7. Certification that the Eligible Entity will provide service to all unserved and underserved locations, if the Eligible Entity is seeking to use BEAD funding for deployment to CAIs or for other eligible activities. Coverage of Unserved Locations Question (Y/N): Certify whether the Eligible Entity will ensure coverage of broadband service to all unserved locations within its jurisdiction, as identified upon conclusion of the Challenge Process required under 47 U.S.C. § 1702(h)(2). N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box: If the Eligible Entity does not serve an unserved location because it is either financially incapable or has determined that costs to serve the location would be unreasonably excessive, explain and include a strong showing of how the Eligible Entity made that determination. N/A Attachment (Optional): If applicable to support the Eligible Entity’s response to Question 7.2, provide relevant files supporting the Eligible Entity's determination. N/A Coverage of Underserved Locations Question (Y/N): Certify whether the Eligible Entity will ensure coverage of broadband service to all underserved locations within its jurisdiction, as identified upon conclusion of the Challenge Process required under 47 U.S.C. § 1702(h)(2). N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box: If the Eligible Entity does not serve an underserved location because it is either financially incapable or has determined that costs to serve the location would be unreasonably excessive, explain and include a strong showing of how the Eligible Entity made that determination. N/A Attachment (Optional): If applicable to support the Eligible Entity's response to Question 7.5, provide relevant files supporting the Eligible Entity's determination. N/A Question (Y/N): Certify that the Eligible Entity has utilized the provided reason codes to investigate and account for locations that do not require BEAD funding, that the Eligible Entity will utilize reason codes 1, 2, and 3 for the entire period of performance, and that the Eligible Entity will maintain documentation, following the guidelines provided by NTIA, to justify its determination if there is a reason to not serve any unserved or underserved location on the NTIA-approved Challenge Process list through a BEAD project. The documentation for each location must be relevant for the specific reason indicated by the Eligible Entity in the fp_no_BEAD_locations.csv file. The Eligible Entity shall provide the documentation for any such location for NTIA review, as requested during Final Proposal review or after the Final Proposal has been approved. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Intentionally omitted This question is intentionally left blank. Question 7.8 is omitted from NTIA’s “BEAD Final Proposal Guidance for Eligible Entities (Version 2.1)” (July 2025). Intentionally omitted This question is intentionally left blank. Question 7.9 is omitted from NTIA’s “BEAD Final Proposal Guidance for Eligible Entities (Version 2.1)” (July 2025). Question (Y/N): Certify that the Eligible Entity has accounted for all enforceable commitments after the submission of its challenge results, including state enforceable commitments and federal enforceable commitments that the Eligible Entity was notified of and did not object to, and/or federally-funded awards for which the Eligible Entity has discretion over where they are spent (e.g., regional commission funding or Capital Projects Fund/State and Local Fiscal Recovery Funds), in its list of proposed projects. Yes Intentionally Omitted This section is intentionally left blank. Section 8 is omitted from this Final Proposal based on NTIA’s “BEAD Final Proposal Guidance for Eligible Entities (Version 2.1)” (July 2025), which removes Requirement 8 from the Final Proposal per the BEAD Restructuring Policy Notice. Intentionally Omitted This section is intentionally left blank. Section 9 is omitted from this Final Proposal based on NTIA’s “BEAD Final Proposal Guidance for Eligible Entities (Version 2.1)” (July 2025), which removes Requirement 9 from the Final Proposal per the BEAD Restructuring Policy Notice. Intentionally Omitted This section is intentionally left blank. Section 10 is omitted from this Final Proposal based on NTIA’s “BEAD Final Proposal Guidance for Eligible Entities (Version 2.1)” (July 2025), which removes Requirement 10 from the Final Proposal per the BEAD Restructuring Policy Notice. Implementation Status of Plans for Cost and Barrier Reduction, Compliance with Labor Laws, Low-Cost Plans, and Network Reliability and Resilience (Requirement 11) Cost and Barrier Reduction: Relevant Instructions from BEAD NOFO Section IV.B.9.b, Page 48: The Final Proposal must include… : 11. Implementation status of plans described in the Initial Proposal related to: a. Steps that the Eligible Entity has taken or intends to take to promote streamlined permitting processes and cost-effective access to poles, conduits, easements, and rights of way, including the imposition of reasonable access requirements; Compliance with Labor Laws Relevant Instructions from the Infrastructure Act, 47 U.S.C. § 1702 (h)(1)(A)(iv)(IV) (A) IN GENERAL. -An eligible entity, in awarded subgrants for the deployment of a broadband network using grant funds received under this section, as authorized in subsection (f)(1) - ... (iv) shall give priority to projects based on- ... (IV) a demonstrated record of and plans to be in compliance with Federal labor and employment laws. Relevant Instructions from the BEAD Restructuring Policy Notice Section 2.1, Page 4: NTIA hereby eliminates the non-statutory requirements in the NOFO related to labor, employment, and workforce development... Specifically, NTIA hereby eliminates the following sections of the NOFO: "Fair Labor Practices and Highly Skilled Workforce"; "Advancing Equitable Workforce Development and Job Quality Objectives"; and "Civil Rights and Nondiscrimination Law Compliance" (BEAD NOFO, Section lv.C.1.e-g, pgs. 56-62). The related Initial Proposal and Final Proposal requirements and the corresponding reporting requirements are also eliminated (BEAD NOFO, Section IV.B.5.b.11-13, pg. 32, and BEAD NOFO, Section IV.B.9.b.11.b-c, pg. 48 and BEAD NOFO, Section VII.E.2.9,12, pgs. 90-92). The "Contracting with Small and Minority Businesses, Women's Business Enterprises, and Labor Surplus Area Firms" section is also eliminated (BEAD NOFO, Section VII.D.7, pgs. 88-89). Low-Cost Service Option Relevant Instructions from the Infrastructure Act, 47 U.SC. § 1702 (h)(4)(B): DEPLOYMENT AND PROVISION OF SERVICE REQUIREMENTS. - An entity that receives a subgrant under subsection (f)(1) for the deployment of a broadband network-... (B) shall offer not less than 1 low-cost broadband service option for eligible subscribers, as those terms are defined in paragraph (5) this subsection; Relevant Instructions from the BEAD Restructuring Policy Notice Section 7, Pages 6-8: NTIA hereby eliminates the non-statutory requirements in the NOFO related to the BEAD low-cost broadband service option (LCSO). Specifically, NTIA hereby eliminates the "Affordability and Low-Cost Plans" section of the NOFO and the related Initial Proposal and Final Proposal requirements to the extent they are inconsistent with this Policy Notice (BEAD NOFO, Section IV.C.2.c.i, pg. 66-68 and BEAD NOFO, Section IV.B.5.b.16, pg. 32 and BEAD NOFO, Section IV.B.9.b.11.d, pg. 48). BEAD subgrantees must still comply with the statutory provision to offer at least one LCSO, but NTIA hereby prohibits Eligible Entities from explicitly or implicitly setting the LCSO rate a subgrantee must offer (Subgrantees must also still comply with the statutory and NOFO requirements pertaining to service level.) To be clear, NTIA will only approve Final Proposals that include LCSOs proposed by the subgrantees themselves. Finally, NTIA also hereby modifies the eligible subscriber definition (below) to align it with the Federal Communications Commission's (FCC) Lifeline Program and other Federal assistance programs. LCSO Service Requirements Consistent with IIJA, Eligible Entities shall require potential BEAD subgrantees to propose an LCSO as part of their applications that meets certain speed and performance criteria. As required by IIJA and the NOFO, the LCSO must offer speeds of at least 100/20 Mbps and latency performance of no more than 100 milliseconds. Applicants that already offer a low-cost plan that meets these service requirements may satisfy the LCSO requirement by proposing to offer their existing low-cost plan to eligible subscribers. Eligible Subscriber Definition IIJA directs NTIA to define "eligible subscriber" for the BEAD low-cost broadband service option. The NOFO adopted the eligibility requirements of the FCC's Affordable Connectivity Plan which is no longer operational. Accordingly, NTIA hereby redefines "eligible subscriber" to match the eligibility criteria for the FCC's Lifeline Program. This eligibility change aligns the BEAD LCSO requirement with an existing communications affordability program as well as other Federal benefit qualifications for low-income Americans. The definition of an Eligible Subscriber for the LCSO stated in the NOFO is hereby stricken and is replaced with the following: Eligible Subscriber-The term "Eligible Subscriber" means any household seeking to subscribe to broadband internet access service that is eligible for the FCC's Lifeline Program (Lifeline eligible criteria are defined in 47 C.F.R. §54.409). BEAD subgrantees are responsible for verifying LCSO eligibility and may ask potential subscribers to provide the same documentation necessary to confirm eligibility as is required under the Lifeline program. Network Reliability and Resilience Relevant Instructions from the Infrastructure Act, 47 U.S.C. § 1702 (1) SUBGRANTEE OBLIGATIONS. - A subgrantee, in carrying out activities using amounts received from an eligible entity under this section-... (C) shall incorporate best practices, as defined by the Assistant Secretary, for ensuring reliability and resilience of broadband infrastructure; Relevant Instructions from the BEAD Restructuring Policy Notice Section 2.2, Pages 4-5: NTIA hereby eliminates the requirements in the NOFO related to climate change, which prioritized the prior Administration's radical environmental social agenda at the expense of swift and efficient broadband deployment. Specifically, NTIA hereby eliminates the "Climate Resilience" section of the NOFO (NOFO, Section IV.C.1.h, pgs. 62-64.) and the related Initial Proposal and Final Proposal requirements (NOFO, Section IV.B.5.b.15, pg. 32, and NOFO, Section IV.B.9.b.11.e, pg. 48). Subgrantees shall satisfy the statutory requirement to incorporate best practices defined by NTIA for ensuring reliability and resilience of broadband infrastructure by establishing risk management plans that account for technology infrastructure reliability and resilience, including from natural disasters (e.g., wildfires, flooding, tornadoes, hurricanes, etc.), as applicable, as well as cybersecurity best practices (See, e.g., National Institute of Standards and Technology Framework for Improving Critical Infrastructure Cybersecurity, Cybersecurity Supply Chain Risk Management Practices for Systems and Organizations, NIST 800-161 Rev.1 and Key Practices in Cyber Supply Chain Risk Management: Observations from Industry, NIST IR 8276). Text Box: Provide the implementation status (Complete, In Progress, or Not Started) of plans described in the approved Initial Proposal Requirement 14 related to reducing costs and barriers to deployment. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Question (Y/N): Affirm that the Eligible Entity required subgrantees to certify compliance with existing federal labor and employment laws. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box (Optional - Conditional on a 'No' Response to Intake Question 11.2): If the Eligible Entity does not affirm that subgrantees were required to certify compliance with federal labor and employment laws, explain why the Eligible Entity was unable to do so. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Question (Y/N): Certify that all subgrantees selected by the Eligible Entity will be required to offer a low-cost broadband service option for the duration of the 10-year Federal interest period. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box (Optional - Conditional on a 'No' Response to Intake Question 11.4): If the Eligible Entity does not certify that all subgrantees selected by the Eligible Entity will be required to offer a low-cost broadband service option for the duration of the 10-year Federal interest period, explain why the Eligible Entity was unable to do so. N/A Question (Y/N): Certify that all subgrantees have planned for the reliability and resilience of BEAD-funded networks. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Text Box (Optional - Conditional on a 'No' Response to Intake Question 11.6): If the Eligible Entity does not certify that subgrantees have planned for the reliability and resilience of BEAD-funded networks in their network designs, explain why the Eligible Entity was unable to do so. N/A Substantiation of Priority Broadband Projects (Requirement 12) Relevant Instructions from the Infrastructure Act, 47 U.S.C § 1702(a)(1)(I): (I) PRIORITY BROADBAND PROJECT.-The term "priority broadband project" means a project designed to- provide broadband service that meets speed, latency, reliability, consistency in quality of service, and related criteria as the Assistant Secretary shall determine; and ensure that the network built by the project can easily scale speeds over time to- meet the evolving connectivity needs of households and businesses; and support the deployment of SG, successor wireless technologies, and other advanced services. Relevant Instructions from the Infrastructure Act, 47 U.S.C. § 1702 (h)(l)(A)(ii): ... in providing funding under .. , [Eligible Entity] shall prioritize funding for deployment of broadband infrastructure for priority broadband projects Relevant instructions from the BEAD Restructuring Policy Notice Section 3.1, Pages 8-10: IIJA requires Eligible Entities to prioritize funding for "priority broadband projects." The statute defines a priority broadband project as one designed to: provide broadband service that meets speed, latency, reliability, consistency in quality of service, and related criteria as the Assistant Secretary shall determine; and ensure that the network built by the project can easily scale speeds over time to - meet the evolving connectivity needs of households and businesses; and support the deployment of SG, successor wireless technologies, and other advanced services Any applicant may seek to have the Eligible Entity treat its application as a Priority Broadband Project regardless of the technology used. The applicant's project, however, must still meet the required speed and latency standards set forth in the statute and the NOFO and demonstrate that it meets the additional statutory criteria, including that the project can easily scale speeds over time to support evolving connectivity needs and the deployment of SG and successor wireless technologies. Applicants must provide supporting documentation sufficient for the Eligible Entity to assess the network application and determine that the proposed network architecture for each specific project area meets this standard. Eligible Entities may not categorically exclude any given technology and may only reject treatment of an application as a Priority Broadband Project if the project could not meet the statutory definition for a specific project area. As discussed in Section 3.4 below, NTIA reserves the right to reverse an Eligible Entity's determination that a project does or does not meet the standard for a Priority Broadband Project if such determination is unreasonable. Text Box: Describe how the Eligible Entity applied the definition of Priority Project as defined in the Infrastructure Act and the BEAD Restructuring Policy Notice. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Subgrantee Selection Certification (Requirement 13) Relevant Instructions from the BEAD Restructuring Policy Notice Section 3.4, Page 12: Eligible Entities shall score competing applications using the following criteria: Primary Criteria. In deciding among competing applications covering the same general project areas, Eligible Entities must choose the option with the lowest cost based on minimal BEAD Program outlay. Minimal BEAD Program Outlay. The Eligible Entity must select the combination of project proposals with the lowest overall cost to the Program. This may involve selecting a proposal that is not the lowest-cost option for a given set of BSLs but is part of the combination of selected projects with the lowest overall cost to the Program. When comparing competing proposals, Eligible Entities shall assess the total BEAD funding that will be required to complete the project (i.e., the total project cost minus the applicant's proposed match) and the cost to the Program per location (i.e., the total BEAD funding that will be required to complete the project divided by the number of BSLs the project will serve). Secondary Criteria. If an application to serve the same general project area proposes a project cost within 15% of the lowest-cost proposal received for that same general project area on a per BSL basis, the Eligible Entity must evaluate such competing applications based on the following three criteria. The relative weighting of these three criteria shall be at the discretion of the Eligible Entity: Speed to Deployment. The prospective subgrantee's binding commitment to provision service by a date certain that is earlier than four years after the date on which the subgrantee will receive the subgrant from the Eligible Entity subject to contractual penalties to the Eligible Entity. Greater consideration can be awarded to prospective subgrantees promising an earlier service provision date. Speed of Network and Other Technical Capabilities. Eligible Entities may weigh the speed, latency, and other technical capabilities of the technologies proposed by prospective subgrantees. Preliminary/Provisional Subgrantees. For locations where Eligible Entities have already identified preliminary or provisionally selected subgrantees, Eligible Entities may give additional weight to those applications in the Benefit of the Bargain Round. Text Box: Provide a narrative summary of how the Eligible Entity applied the BEAD Restructuring Policy Notice’s scoring criteria to each competitive project application and describe the weight assigned to each Secondary Criteria by the Eligible Entity. Scoring criteria must be applied consistent with the prioritization framework laid out in Section 3.4 of the BEAD Restructuring Policy Notice. The Eligible Entity must describe the following: A summary of how the Eligible Entity applied the "Minimal BEAD Program Outlay" scoring criteria to each competitive application If secondary criteria were applicable according to the BEAD Restructuring Policy Notice, a summary of how the Eligible Entity applied the criteria, (i.e., how points were assigned within each criterion) and identify the corresponding weights assigned to each criterion: Speed to deployment; and Speed of network and other technical capabilities as defined by the Eligible Entity; For locations where Eligible Entities have already completed their subgrantee selection process and identified preliminary or provisionally selected subgrantees, Eligible Entities will give additional weight to Preliminary/Provisional Subgrantees. N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Environmental and Historic Preservation (EHP) Documentation (Requirement 14) Relevant Instructions from NOFO Section IV.B.9.b, Page 48: The Final Proposal must include…: 14. Environmental documentation associated with any construction and/or ground-disturbing activities and a description of how the Eligible Entity will comply with applicable environmental and historic preservation requirements. Relevant Instructions from BEAD Restructuring Policy Notice Section 6, Page 15: To support NTIA's goal of issuing National Environmental Policy Act (NEPA) approvals within two weeks for an estimated 90 percent of BEAD projects and eliminate approximately 3-6 months of environmental processing per project, all Eligible Entities are hereby required to use the Environmental Screening and Permitting Tracking Tool (ESAPTT) within the NTIA Grants Portal. ESAPTT will help Eligible Entities serve as joint lead agencies for NEPA reviews by identifying applicable categorical exclusions and enabling paperless transmission of environmental documents and generation of draft and final NEPA documents. NTIA will generate ESAPTT project records from BEAD subgrant award data, which must identify any awards containing multiple NEPA project areas. Eligible Entities are further encouraged to use ESAPTT's permitting tracking capacity to evaluate and track subrecipient NEPA milestone schedules and escalate Federal right-of-way permitting issues to NTIA for interagency resolution. Attachment (Required): Submit a document which includes the following: Description of how the Eligible Entity will comply with applicable environmental and historic preservation (EHP) requirements, including a brief description of the methodology used to evaluate the Eligible Entity’s subgrantee projects and project activities against NTIA’s National Environmental Policy Act (NEPA) guidance. The methodology must reference how the Eligible Entity will use NTIA's Environmental Screening and Permitting Tracking Tool (ESAPTT) to create NEPA project records, evaluate the applicability of categorical exclusions, consider and document the presence (or absence) of Extraordinary Circumstances, and transmit information and draft NEPA documents to NTIA for review and approval. Description of the Eligible Entity’s plan to fulfill its obligations as a joint lead agency for NEPA under 42 U.S.C. 4336a, including its obligation to prepare or to supervise the preparation of all required environmental analyses and review documents. Evaluation of the sufficiency of the environmental analysis for your state or territory that is contained in the relevant FirstNet Regional Programmatic Environmental Impact Statement (PEIS), available at https://www.firstnet.gov/network/environmental-compliance/projects/regional-programmatic-environmental-impact-statements. Evaluation of whether all deployment related activities anticipated for projects within your state or territory are covered by the actions described in the relevant FirstNet Regional PEIS. Description of the Eligible Entity’s plan for applying specific award conditions or other strategies to ensure proper procedures and approvals are in place for disbursement of funds while projects await EHP clearances. N/A Consent from Tribal Entities (Requirement 15) Relevant Instructions from NOFO Section IV.B.9.b, Page 48: The Final Proposal must include…: 15. To the extent an Eligible Entity’s Final Proposal includes plans to deploy broadband to Unserved Service Projects or Underserved Service Projects on Tribal Lands, the Eligible Entity must submit a Resolution of Consent from each Tribal Government, from the Tribal Council or other governing body, upon whose Tribal Lands the infrastructure will be deployed. Attachment(s) (Required if any deployment project is on Tribal Lands): Upload a Resolution of Consent from each Tribal Government (in PDF format) from which consent was obtained to deploy broadband on its Tribal Land. The Resolution(s) of Consent submitted by the Eligible Entity should include appropriate signatories and relevant context on the planned (f)(1) broadband deployment including the timeframe of the agreement. The Eligible Entity must include the name of the Resolution of Consent PDF in the Deployment Projects CSV file. N/A Prohibition on Excluding Provider Types (Requirement 16) Relevant Requirement from the Infrastructure Act, 47 U.S.C § 1702(h)(1)(A)(iii): (A) In general An eligible entity, in awarding subgrants for the deployment of a broadband network using grant funds received under this section, as authorized under subsection (f)(1)- (iii) may not exclude cooperatives, nonprofit organizations, public-private partnerships, private companies, public or private utilities, public utility districts, or local governments from eligibility for such grant funds .... Relevant Instructions from BEAD Restructuring Policy Notice, Section 2.5, Page 6: Eligible Entities must still adhere to the statutory requirement regarding the non-exclusion of various entities from eligibility for BEAD subgrants. Question (Y/N): Does the Eligible Entity certify that it did not exclude cooperatives, nonprofit organizations, public-private partnerships, private companies, public or private utilities, public utility districts, or0 local governments from eligibility for a BEAD subgrant, consistent with the requirement at 47 U.S.C. § 1702(h)(1)(A)(iii)? N/A - USVI was not able to conduct any subgrantee selection processes due to the RPN restriction on activities not related to last-mile connectivity. Due to previous enforceable commitments, USVI has no BEAD-eligible BSLs or CAIs. Waivers Relevant Instructions from NOFO Section IX.E, Page 95: It is the general intent of NTIA not to waive any of the provisions set forth in this NOFO. However, at the discretion of the Assistant Secretary, NTIA, upon its own initiative or when requested, may waive the provisions in this NOFO. Waivers may only be granted for requirements that are discretionary and not mandated by statute or other applicable law. Any request for a waiver must set forth the circumstances for the request. Relevant Instructions from BEAD Restructuring Policy Notice Section 2, Page 4: Eligible Entities shall eliminate the following non-statutory requirements from BEAD application scoring, subgrantee agreements, and subgrantee reporting requirements. Eligible Entities are hereby prohibited from imposing any of the obligations removed by this Policy Notice on subgrantees as part of the BEAD Program. Where state law conflicts with the requirements of this Policy Notice, Eligible Entities may seek a waiver of that requirement from the Assistant Secretary Text Box: If any waivers are in process and/or approved as part of the BEAD Initial Proposal or at any point prior to the submission of the Final Proposal, list the applicable requirement(s) addressed by the waiver(s) and date(s) of submission. Changes to conform to the BEAD Restructuring Policy Notice should be excluded. If not applicable to the Eligible Entity, note ‘Not applicable.’ USVI’s OMB requested two waivers for the date of the Final Proposal submission. On August 27, 2025, the Eligible Entity requested an extension to submit its FP by 90 days. However, this request was deemed unnecessary due to a September 10, 2025 sua sponte waiver granting an extension to Puerto Rico and the US Virgin Islands. As a result, that request was denied on September 19, 2025.   On October 24, 2025, the Eligible Entity requested an additional extension to submit its FP, to December 18, 2025. That request was approved, as modified, on November 25, 2025.  Attachment (Optional): If not already submitted to NTIA, and the Eligible Entity needs to request a waiver for a BEAD program requirement, upload a completed Waiver Request Form here. If documentation is already in process or has been approved by NTIA, the Eligible Entity does NOT have to upload waiver documentation again. N/A