Challenge process
How Hawaiʻi corrected the map before any money was awarded: who could file, what evidence counted, and how every challenge was resolved.
Headline figures
Challenges received
37,593
Held
August 19 to December 7, 2024
Receipt
“The Hawaiʻi Broadband Equity, Access, and Deployment (BEAD) Challenge Process was held between August 19, 2024 and December 7, 2024.”
UHBO Challenge Process page, p.1Results approved by NTIA
December 20, 2024
Receipt
“Hawai’i received NTIA approval of its Challenge Process results on December 20, 2024.”
UHBO Challenge Process page, p.1Location data used
FCC National Broadband Map, December 31, 2023
Three phases
Challenge phase
August 19 to September 18, 2024
Rebuttal phase
October 7 to November 6, 2024
Final determination phase
November 7 to December 7, 2024
Receipt
“Final Determination Phase: November 7, 2024 – December 7, 2024 (30 days)”
Final Proposal, p.16One total, three ways
Challenges received by challenger type
| Eligible Entity | 24,606 | |
|---|---|---|
| Local government | 180 | |
| Nonprofit | 88 | |
| Service provider | 12,719 |
Rows sum to 37,593, the stated total.
Receipts (4)
- Eligible Entity“Eligible Entity – 24,606”UHBO Challenge Process page, p.1
- Local government“Local Government Challenges Received – 180”UHBO Challenge Process page, p.1
- Nonprofit“Nonprofit Challenges Received – 88”UHBO Challenge Process page, p.1
- Service provider“Service Provider Challenges Received – 12,719”UHBO Challenge Process page, p.1
Challenges received by challenge type
| Availability (A) | 9,812 | |
|---|---|---|
| Business service only (B) | 2 | |
| Enforceable commitment (E) | 15,057 | |
| Planned service (P) | 12,719 | |
| Speed (S) | 3 | |
| Location is a CAI (C) | 2 |
Rows sum to 37,595 against a stated total of 37,593. The six published type counts sum to 37,595; the page's stated total is 37,593. The source does not explain the difference.
Receipts (6)
- Availability (A)“Availability (A) – 9,812”UHBO Challenge Process page, p.1
- Business service only (B)“Business Service Only (B) – 2”UHBO Challenge Process page, p.1
- Enforceable commitment (E)“Enforceable Commitment (E) – 15,057”UHBO Challenge Process page, p.1
- Planned service (P)“Planned Service (P) – 12,719”UHBO Challenge Process page, p.1
- Speed (S)“Speed (S) – 3”UHBO Challenge Process page, p.1
- Location is a CAI (C)“Location is a CAI (C) – 2”UHBO Challenge Process page, p.1
Challenges resolved by disposition
| Sustained (S) | 312 | |
|---|---|---|
| Rejected (R) | 9,408 | |
| Incomplete (I) | 799 | |
| Provider agreed with the challenge (A) | 14 | |
| Provider did not respond within the rebuttal deadline (N) | 27,050 | |
| Moot: another successful challenge for the same location (M) | 10 |
Rows sum to 37,593, the stated total.
Receipts (6)
- Sustained (S)“Sustained (S) – 312”UHBO Challenge Process page, p.1
- Rejected (R)“Rejected (R) – 9,408”UHBO Challenge Process page, p.1
- Incomplete (I)“Incomplete (I) – 799”UHBO Challenge Process page, p.1
- Provider agreed with the challenge (A)“The provider agreed with the challenge (A) – 14”UHBO Challenge Process page, p.1
- Provider did not respond within the rebuttal deadline (N)“The provider did not respond within the rebuttal deadline (N) – 27,050”UHBO Challenge Process page, p.1
- Moot: another successful challenge for the same location (M)“The challenge was not resolved since it was moot due to another successful challenge for the same location (M) – 10”UHBO Challenge Process page, p.1
Who could file
- Nonprofits“Nonprofits, including IRS nonprofit organizations and Native Hawaiian Homestead & Beneficiary Associations registered with the U.S.”UHBO Challenge Process page, p.1
- Units of local government“Units of local government”UHBO Challenge Process page, p.1
- Internet service providers“Internet service providers”UHBO Challenge Process page, p.1
- Members of the public“Members of the public cannot directly submit challenges during the Challenge Process, however, individuals may contribute information through our web portal to help an Eligible Entity submit Challenges.”UHBO Challenge Process page, p.1
- Area challenges“An area challenge reverses the burden of proof for availability, speed, latency, data cap and technology challenges if a defined number of challenges for a particular category, across all challengers, have been submitted for a provider and moved to the Rebuttal Phase.”Challenge Process Guide, p.16
What evidence counted
| Challenge type | Requirement | Source |
|---|---|---|
| Availability | “When filing availability challenges, you will be required to select one of the following reasons and provide evidence for each challenge.” | Challenge Process Guide, p.19 |
| Speed | “Each speed test consists of three (3) measurements, taken on different days.” | Challenge Process Guide, p.25 |
| Latency | “Latency Challenges must provide evidence that the round-trip latency of the broadband service exceeds 100 milliseconds (ms).” | Challenge Process Guide, p.27 |
| Data cap, technology, business service only | “The Data Cap, Technology, and Business Service Only challenge requirements are similar to those for Availability challenges.” | Challenge Process Guide, p.23 |
| Enforceable commitment | “The Enforceable Commitment Challenge allows Permissible Challengers to provide evidence that an unserved or underserved locations have an existing federal, state, or local funding that should make those locations ineligible for BEAD.” | Challenge Process Guide, p.29 |
| Not part of an enforceable commitment | “The Not Enforceable Commitment Challenge allows Permissible Challengers to provide evidence that a location is not covered by an Enforceable Commitment identified by UHBO.” | Challenge Process Guide, p.30 |
| Planned service | “If a provider began building out broadband service to unserved and/or underserved locations, they may challenge under the “Planned Service” subtype and provide evidence that service will be available to the locations by June 30, 2024.” | Challenge Process Guide, p.31 |
| Existing service | “If a provider completed broadband deployment to locations currently designated as unserved and/or underserved locations, they may challenge under the “Existing Service” challenge type and provide evidence that service is currently available.” | Challenge Process Guide, p.32 |
| Location is not a CAI | “If you believe that a location is incorrectly identified as a CAI, you may challenge to have that location removed from the CAI list.” | Challenge Process Guide, p.38 |
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