The challenge process conducted by ARConnect will include four (4) phases, spanning approximately ninety (90) days:

1. (1)

   1. (A) Publication of eligible locations.
   2. (B) Prior to beginning the Challenge Phase, ARConnect will publish the locations eligible for BEAD funding, which consists of the locations resulting from the activities outlined in Sections 5 and 6 of the National Telecommunications and Information Administration BEAD Challenge Process Policy Notice (e.g., administering the deduplication of funding process).
   3. (C) ARConnect will also publish a list of ineligible locations, as they may be challenged;

2. (2)

   1. (A) Challenge Phase.

   2. (B)

      1. (i) During the Challenge Phase, a permissive challenger will submit the challenge through the ARConnect challenge portal.
      2. (ii) This challenge will be visible to the service provider whose service availability and performance is being contested.
      3. (iii) The portal will notify the provider of the challenge through an automated email, which will include related information about timing for the provider’s response.
      4. (iv) After this stage, the location be considered challenged.

   3. (C) Minimum level of information sufficient to establish a challenge.

      1. (i) The challenge portal will verify that the address provided can be found in the Fabric and is a BSL.
      2. (ii) The challenge portal will confirm that the challenged service is listed in the National Broadband Map and meets the definition of reliable broadband service.
      3. (iii) The challenge portal will confirm that the email address is reachable by sending a confirmation message to the listed contact email.
      4. (iv) For scanned images, the challenge portal will determine whether the quality is sufficient to enable optical character recognition.
      5. (v) For availability challenges, ARConnect will manually verify that the evidence submitted falls within the categories stated in the National Telecommunications and Information Administration BEAD Challenge Process Policy Notice and the document is unredacted and dated.

   4. (D) Timeline.

      1. (i) Following the publication of eligible locations, the challenge phase will commence on a set date determined by ARConnect.
      2. (ii) Permissible challengers will have thirty (30) calendar days to submit a challenge from the time the initial list of eligible and ineligible locations is posted;

3. (3)

   1. (A) Rebuttal Phase.

   2. (B)

      1. (i) Only a challenged service provider may rebut the reclassification of a location or area, causing the challenge to be designated as “disputed”.
      2. (ii) If a challenge that meets the minimum level of evidence is not rebutted, the challenge is sustained.
      3. (iii) A provider may also agree with the challenge, resulting in the challenge being sustained.
      4. (iv) Providers must regularly check the challenge portal notification method for notifications of submitted challenges.
   3. (C) Timeline. Providers will have thirty (30) calendar days from the end of the challenge phase to provide rebuttal information to ARConnect; and

4. (4)

   1. (A) Final Determination Phase.
   2. (B) During the Final Determination Phase, ARConnect will make the final determination of the classification of the location, either declaring the challenge “sustained” or “rejected”.
   3. (C) Timeline. ARConnect will make all final challenge determinations within thirty (30) calendar days of the onset of the final determination period.