“ARPA is the first federal program that provides funds to these governments (states and localities) for broadband deployment. Importantly, the interim rule defines standards for state and local programs that use federal funds but does not include words such as “shall” and “require.” The absence of such imperatives allows recipients to determine funding priorities based on their understanding of the problem, not the federal government’s. This represents a historic moment in broadband policy and affirms the role of states in closing broadband gaps.”