See the first article in this series, The Sky is Falling!!!! (or Maybe Not)

Many have speculated about the impact of the recent decision of the National Telecommunications and Information Administration (NTIA) to administer the landmark $42 billion Broadband Equity, Access and Deployment (BEAD) Program on a technology-neutral basis. While some were quick to assume NTIA’s new “lowest cost wins” approach would doom fiber applicants, that’s not the case.

I recently posted a blog setting forth a roadmap for how states should evaluate whether satellite applicants would qualify as “Priority Broadband Projects” under the new BEAD Restructuring Policy Notice. I firmly believe that satellite shouldn’t be classified as Priority Broadband. Period. End of story. In this post, I’ll address how fixed wireless applicants, particularly those using unlicensed spectrum, should be evaluated in the “Benefit of the Bargain” round.

Fiber applicants shouldn’t give up on BEAD. There’s a path forward.

First, a quick recap on the background: In the June 6th Policy Notice, the Trump Administration abolished the program’s prior preference for fiber, opened the program to bids from all technologies, rescinded all prior provisional awards, and directed the states to hold another round of bidding — the “Benefit of the Bargain” round — to select the lowest cost option, with Final Proposals due in 90 days.

So, does this mean fixed wireless applicants will prevail over fiber throughout the country? I’d say no, and here’s why.

Priority projects win over non-priority projects.

As I’ve previously explained, all technologies are now permitted to compete for BEAD funding, but that doesn’t mean all applicants should qualify as Priority Broadband Projects. The states are the ones who decide which projects qualify as Priority Broadband Projects. Cost comparisons will not be done between Priority and non-Priority Broadband Projects seeking funding for the same geographic area.

Under the 2021 bi-partisan Infrastructure Investment and Jobs Act, which created the BEAD program, a “Priority Broadband Project” is one meeting the BEAD performance standard of 100/20 Mbps with no more than 100 ms of latency, while also being capable of easily scaling speeds over time to meet the evolving connectivity needs of households and businesses and support the deployment of 5G, successor wireless technologies, and other advanced services.

As one industry observer notes, this fundamentally is an engineering question.

States must decide which applications meet these statutory criteria. NTIA has decided that the Biden Administration erred by adopting a blanket presumption that only fiber could qualify as a Priority Broadband Project. It would be equally inappropriate for a state broadband office to make a blanket decision that all fixed wireless applications qualify as Priority Broadband Projects.

Indeed, NTIA expressly recognized in the latest version of BEAD FAQs (version 10) that a state could conclude that a given application is not a Priority Broadband Project for a particular project area because the relevant technology cannot easily scale to meet evolving connectivity needs, while at the same time deciding that a different application in a different project area using the exact same technology is a Priority Broadband Project.

Engineering matters. As one WISP CEO said at a conference several years ago, there is a big difference between a well-engineered fixed wireless network and one that is not so well engineered. The specifics matter — a lot.

The recent Policy Notice states that BEAD applicants must provide supporting documentation sufficient for the state to determine that the proposed network architecture for each specific project area meets the statutory definition of Priority Broadband Project.

Supporting documentation is more than checking a box on an application to self-certify “Priority Broadband Project.” If all applications are rubberstamped as “Priority,” that would turn the statutory scheme envisioned by Congress on its head.

I know it will be challenging given the 90-day clock, but states need to kick the tires on these applicants’ assertions.

For the upcoming Benefit of the Bargain bidding round, state broadband offices can and should release information indicating what information they need to properly determine that the statutory criteria are met. Priority Broadband Projects must demonstrate they will be easily capable of delivering speeds in the future, both download and upload, well above today’s BEAD minimum of 100/20 Mbps. To scale a network, fixed wireless applicants must demonstrate their plan for faster speeds and greater bandwidth usage — likely requiring additional investment in fiber technology for backhaul.

As one example, the Georgia Broadband Office recently released BEAD application templates, including templates for unlicensed fixed wireless applicants. One of the questions is “Describe how the proposed network will meet the following performance targets five years after initial deployment: (1) Provide at least 240 Mbps download and 48 Mbps upload capacity to each Broadband Serviceable Location (BSL), (2) Support simultaneous 12 Mbps throughput for all connected users (BEAD and non-BEAD users).” My point is not to endorse these specific criteria — other states may have differing views on what applicants must demonstrate to qualify as a Priority Broadband Project — but rather to emphasize that all states should be transparent about what information they are looking for in the upcoming “Benefit of the Bargain” round.

State broadband offices have a responsibility to consider the particular attributes of their localities that make it more difficult for a fixed wireless network to perform robustly. I’m no engineer, but I’ve heard that fixed wireless can be challenging in geographies with a lot of trees, particularly pine trees. What works in one state, and one environment, will not necessarily work in others. Listen to local voices telling you what’s feasible and what isn’t, given the topology and density of the target areas.

Access to capital matters. Any applicant proposing a Priority Broadband Project needs to demonstrate it has access to capital sufficient to build and operate that scalable network. A network that easily scales to meet the needs of tomorrow is going to be largely fiber, with fixed wireless used just to connect individual locations. Applicants that are seeking BEAD funding without demonstrated access to capital should not be viewed as financially qualified. As many have noted, while fixed wireless networks may initially be less costly to build, those networks need to be upgraded more frequently, with significant additional costs down the road to swap out older radios for newer models. To be worthy of the Priority Broadband designation, applicants need to show they are financially qualified not just to build a network that can deliver service meeting the BEAD minimum standards, but also that they have a solid business plan to upgrade the network years in the future to deliver more. Those offering vague promises of future private sector investors or assuming there will be additional public funding in the future to finance such upgrades should be questioned.

Scope and scale matter. NTIA has made it clear that states are to determine whether each project qualifies as a Priority Broadband Project, without making any categorical exclusions based on technology. Part of the analysis must be the scope and scale of what an applicant proposes to do.

Applicants promising a scalable network must demonstrate that proposed network will provide evolving service to each and every one of the locations in the proposed project area. Hats off to the Georgia Broadband Office for recognizing that BEAD applicants need to be able to show how they will simultaneously service all connected users. A fixed network that is just delivering 100/20 Mbps (and some argue they cannot even do that consistently) simply isn’t enough. Under the new NTIA construct, 100/20 Mbps via any technology is reliable broadband — but it’s not Priority Broadband. Demonstrating continuous access to sufficient spectrum and backhaul must be part of the showing.

Priority Broadband Projects must serve business needs, as well as residential homes. Congress defined a Priority Broadband Project as one that meets the evolving connectivity needs of households and businesses. State broadband offices should be thinking about the community development needs of their state, as well as the needs of residential homes. Reliable symmetrical bandwidth for many businesses is table stakes. State broadband offices should be looking at whether Priority Broadband applicants will be offering redundancies sufficient to meet business needs, and whether the applicant demonstrates any understanding of community economic development plans. The ability of Priority Broadband Projects to support AI data centers and IOT should be top of the mind.

I’m not a wireless expert and not in a position to offer a checklist of everything a state broadband office should be looking for. Some ideas I’ve been hearing are that state broadband offices should be thinking about whether Priority Broadband Project applicants will support advanced services like LoRaWan and similar distributed IOT/sensor networks — which may require a significant number of access points. State broadband offices should be asking whether Priority Broadband Applicants will support substantial offloading of 5G traffic as well as providing tower/picocell backhaul.

Aside from qualifying (or not) as a Priority Broadband Project, there are several other reasons why fixed wireless won’t displace all fiber applicants.

New fixed wireless applicants will be challenged to demonstrate their qualifications.

Up until now, fixed wireless has been relegated to second class status in state BEAD programs, with many states limiting their initial solicitation round to only fiber applicants. Well organized and well-resourced fixed wireless applicants that have been competing thus far for BEAD grants should be able to repurpose existing applications and resubmit. Companies that have not yet bid for BEAD grants will find it challenging to put together an application that demonstrates their financial, technical and managerial capabilities in the extremely short time frame that states will set for their “Benefit of the Bargain” round.

States are under no obligation to — and indeed, more importantly, should not — award funding to an applicant that doesn’t demonstrate the fundamentals. The recent Policy Notice and latest version of FAQs make clear that states still must ensure that applicants meet the financial and managerial capacity, technical and operational capability, and other requirements set forth in the statute. That is a separate consideration, aside from any evaluation of which application is the lowest cost.

Fixed wireless may not compete everywhere.

There are certain areas of the country with a number of existing fixed wireless providers, and there are other areas of the country where there aren’t many. At this late date, it’s unlikely any new fixed wireless companies that don’t already have some operations in a nearby area will emerge.

Some fixed wireless providers may prefer to take locations off the map and not compete for funding. In the months after Commerce Secretary Lutnick’s confirmation hearing, there was much speculation about what NTIA’s revisions would entail. NTIA’s decision to let unlicensed fixed wireless providers take eligible locations off the map was a curve ball that a lot of people didn’t see coming. It’s too early to know how many locations will be removed from the list of BEAD-eligible locations, but one analysis indicates there could be a more than 25% reduction in the number of eligible locations in ten states. At a recent conference, the Oklahoma broadband office indicated unlicensed fixed wireless could potentially decrease the number of BEAD eligible locations in Oklahoma by half. It’s too soon to know how this is all going to play out, but the upshot is it’s not clear to what extent fixed wireless providers will seek BEAD funding.

In sum, I predict some fixed-wireless applicants will qualify and win BEAD awards for some project areas. But not everywhere.

Fiber applicants shouldn’t bail on BEAD. Fiber needs to stay in the game.

Stay tuned for “The Sky is Falling (Part III)” addressing the new guidance on how states are to select the lowest cost application.

Carol Mattey is a former senior official from the Federal Communications Commission, where she led teams working on initiatives to modernize the FCC’s $9 billion Universal Service Fund to support broadband. She is currently the principal of Mattey Consulting LLC, which provides strategic and public policy advisory services to broadband providers and other entities seeking funding for broadband.

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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