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D.C. Memo: ACLP Study Predicts Lutnick's BEAD Rules Will Leave 1 Million Locations Unserved

Analysts Santorelli and Karras Support a BEAD Reserve Fund to Connect Any Remaining Unconnected Locations.

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Ted Hearn
Oct 23, 2025
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BEAD: More than 1 million locations that the FCC classified as unserved were not covered by current BEAD plans or other available federal commitments, according to a new study by the Advanced Communications Law and Policy Institute at New York Law School. ACLP urged states and the federal government to set aside funds for a second round of grants and other projects.

“With more than $20 billion in leftover BEAD funding likely, the ACLP proposes that some amount of those funds should be deposited into a BEAD Reserve Fund and used to connect any remaining unconnected,” the ACLP study said.

In June, Commerce Secretary Howard Lutnick released new BEAD rules emphasizing the lowest-cost bidder and technological neutrality, ending the Biden administration’s thumb-on-the-scale approach in favoring expensive fiber networks. In the end, Lutnick’s plan slashed the $42.45 billion BEAD program in half, triggering a fight over what to do with the “surplus” taxpayer money.

“Ending BEAD with leftover funds and hundreds of thousands of unserved locations would mean NTIA did not accomplish its mission to meet the objective of Congress when it created and funded the program. Fortunately, it is not too late for NTIA to begin making plans to finish the job and make sure every American has access to a robust broadband connection,” said study authors Michael J. Santorelli and Alex Karras. Santorelli is Director of the ACLP and Karras is a Senior Fellow.

In an analysis of BEAD final proposals from 49 states, the District of Columbia, and three territories, ACLP counted 1,063,812 unserved locations outside current plans, alongside $18.3 billion in proposed allocations targeting 3.6 million addresses. (More after paywall.)

Michael J. Santorelli, Director of the Advanced Communications Law and Policy Institute (ACLP) at New York Law School.

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