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Unlicensed Spectrum and BEAD Grants

There is a growing controversy brewing about the NTIA’s decision to declare that fixed wireless technology using only unlicensed spectrum is unreliable and not worthy of funding for the BEAD grants. WISPA, the lobbying arm for the fixed wireless industry, released a press release that says that the NTIA has made a big mistake in excluding WISPs that use only unlicensed spectrum.

I’m not a wireless engineer, so before I wrote this blog, I consulted with several engineers and several technicians who work with rural wireless networks. The one consistent message I got from all of them is that interference can be a serious issue for WISPs deploying only unlicensed spectrum. I’m just speculating, but I have to think that was part of the reason for the NTIA decision – interference can mean that the delivered speeds are not reliably predictable.

A lot of the interference comes from the way that many WISPs operate. The biggest practical problem with unlicensed spectrum is that it is unregulated, meaning there is no agency that can force order in a chaotic wireless situation. I’ve heard numerous horror stories about some of the practices in rural areas where there are multiple WISPs.  There are WISPs that grab all of the available channels of spectrum in a market to block out competitors. WISPs complain about competitors that cheat by rigging radios to operate above the legal power limit, which swamps their competitors. And bad behavior begets bad behavior in a vicious cycle where WISPs try to outmaneuver each other for enough spectrum to operate. The reality is that the WISP market using unlicensed spectrum is a free-for-all – it’s the Wild West. Customers bear the brunt of this as customer performance varies day by day as WISPs rearrange their networks. Unless there is only a single WISP in a market, the performance of the networks using unlicensed spectrum is unreliable, almost by definition.

There are other issues that nobody, including WISPA, wants to address. There are many WISPs that provide terrible broadband because they deploy wireless technology in ways that exceed the physics of the wireless signals. Many of these same criticisms apply to cellular carriers as well, particularly with the new cellular FWA broadband. Wireless broadband can be high-quality when done well and can be almost unusable if deployed poorly.

There are a number of reasons for poor fixed wireless speeds. Some WISPs are still deploying lower quality and/or older radios that are not capable of the best speeds – this same complaint has been leveled for years against DSL providers. ISPs often pile too many customers into a radio sector and overload it, which greatly dilutes the quality of the broadband that can reach any one customer. Another common issue is WISPs that deploy networks with inadequate backhaul. They will string together multiple wireless backhaul links to the point where each wireless transmitter is starved for bandwidth. But the biggest issue that I see in real practice is that some WISPs won’t say no to customers even when the connection is poor. They will gladly install customers who live far past the reasonable range of the radios or who have restricted line-of-sight. These practices are okay if customers willingly accept the degraded broadband – but typically, customers are often given poor broadband for a full price with no explanation.

Don’t take this to mean that I am against WISPs. I was served by a WISP for a decade that did a great job. I know high-quality WISPS that don’t engage in shoddy practices and who are great ISPs. But I’ve worked in many rural counties where residents lump WISPs in with rural DSL as something they will only purchase if there is no alternative.

Unfortunately, some of these same criticisms can be leveled against some WISPs that use licensed spectrum. Having licensed spectrum doesn’t overcome issues of oversubscribed transmitters, poor backhaul, or serving customers with poor line-of-sight or out of range of the radios. I’m not a big fan of giving grant funding to WISPs who put profits above signal quality and customer performance – but I’m not sure how a grant office would know this.

I have to think that the real genesis for the NTIA’s decision is the real-life practices of WISPs that do a poor job. It’s something that is rarely talked about – but it’s something that any high-quality WISP will bend your ear about.

By contrast, it’s practically impossible to deploy a poor-quality fiber network – it either works, or it doesn’t. I have no insight into the discussions that went on behind the scenes at the NTIA, but I have to think that a big part of the NTIA’s decision was based upon the many WISPs that are already unreliable. The NTIA decision means unlicensed-spectrum WISPs aren’t eligible for grants – but they are free to compete for broadband customers. WISPs that offer a high-quality product at a good price will still be around for many years to come.

4 replies on “Unlicensed Spectrum and BEAD Grants”

As is often the case, Doug, your blog post addresses questions that have been on my mind lately.

Though I usually find myself nodding in agreement as I read your posts, in this case I think you went too easy on NTIA’s unlicensed spectrum BEAD restriction. The main reason is that I recently began learning about Tarana, a fixed wireless equipment vendor that has taken a from-the-ground-up design approach that has yielded what seems to be a fundamentally better FW system, especially in terms of dealing with the combination of interference, multipath, line of sight and other technical issues that have constrained WISP performance, especially when it relies on unlicensed spectrum.

Tarana and its customers claim they are delivering rock-solid 250-500+ Mbps download and 100+ Mbps upload speeds using unlicensed 5 and 3 GHz spectrum with very impressive non-line-of-site coverage range, and with plans to push this to gigabit speeds in the future.

Though I’m neither a WISP nor a wireless engineer, my impression is that Tarana’s FW technology (which they spent more than a decade developing, including their own ASICs) could help a lot of unserved and underserved communities and community-focused ISPs deploy FW networks that can reliably deliver well over the minimum 100/20 BEAD speed threshold at modest cost relative to fiber. If that can be demonstrated (and it seems that it has already been so many times, often quite dramatically), the NTIA rule strikes me as very counterproductive in terms of resolving the agency’s sometimes conflicting priorities of maximizing the number of unserved locations reached by BEAD-funded networks, while also prioritizing these networks’ download and upload speeds and reliability.

Though I’m guessing that Tarana base stations and CPE are priced at the high end of the range for FW gear, comments by ISPs using Tarana’s equipment suggest that this may be more than offset by other factors (e.g., fewer towers, much more efficient spectrum sharing, more customers per tower and base station, easier installation, lower maintenance costs, faster and more reliable service, etc.). These comments suggest that Tarana gear has allowed these ISPs to fundamentally rethink and streamline their network designs and operations, and dramatically improve and expand the scope of their business models (e.g., they can cost-effectively bring high-performance broadband to underserved rural areas while also providing much needed competition in nearby communities that have only one (often-overpriced) broadband option, provided by their local cable operator).

While I’m certainly not qualified to make claims about Tarana gear with any confidence, I’d recommend that you and your readers–and, yes please, NTIA–investigate their technology. A good place to start is the Tarana website (https://www.taranawireless.com/).

And if anyone from Tarana or a service provider that’s deployed their technology reads Doug’s post, I encourage them to post a comment here.

Hi Doug. I’m not a WISPA representative but from my perspective the biggest issue isn’t if BEAD will fund a future project using FWA technology but the fact that they threw the baby out with the bath water on all existing unlicensed fixed wireless networks by deeming any territory they served as unserved and eligible for BEAD funds to overbuild them. It’s not about the future as much as about what exists. Why is 25Mbps x 3Mbps DSL ok and considered served but 50Mbps x 10Mbps FWA not and eligible to be overbuilt?

As the previous commenter said, there is new technology from Tarana available that is a game changer in tough RF environments. I have a link to my home and see 500M x 100M service over the Tarana link. It is expensive though. The BEAD rules ignore any quality and speed metrics of a given network in a given unique area. That is the tough pill to swallow for me because I do own and operate a WISP and in my opinion a quality one at that. It just seems arbitrary based on technology vs based on facts of how the operation deployed that technology. You even admit you had a good experience with a WISP and that other technology could be deployed poorly.

Your sentence “But the biggest issue that I see in real practice is that some WISPs won’t say no to customers even when the connection is poor.” I suppose there could be greed involved on the WISP’s part, as I’m assuming you are implying, but I’ve seen first hand many times this happens out of desperate pleas from the customer to be connected due to lack of better (any) options available to them. New entrants to the market might be helping to change that and provide more options to consumers. To be given a black eye for trying to do right for the people in a rural community without options rubs me the wrong way. I know why we have done this exact situation and it was to help people. I’ve had people plead with us to not take their Internet away when we couldn’t provide it anymore. The extra $59/mo isn’t what it’s about. We go through great lengths to spend money to make connections to people, sometimes to the detriment of profitability and AP efficiency. It will be nice to not have to chase those toughest situations out of a sense of obligation to our neighbors and let them go to Starlink.

The country is large and the issues we face at a national level are very nuanced and everyone has their own truth that doesn’t make someone else’s truth wrong. Being in the middle is never fun. Generally I read and agree with a lot of your posts but wanted to comment on a few items. Thank you for all of your efforts on documenting our industry in your blog.

I will begin by noting that I am a P.E. with an Electrical Engineering degree and have been in telecommunications for the majority of my career, spanning cellular, satellite, terrestrial microwave, FWA, and wireline service. Prior to joining WISPA, I served as COO of a major WISP in the USVI which operated in an environment served by multiple WISPs utilizing unlicensed spectrum. I have been impressed by the capability and agility of unlicensed spectrum network infrastructure to manage capacity to deliver broadband to subscribers with excellent grade of service in any environment. Having seen and heard it all, my experience is simply not aligned with the picture you have painted of WISPs.

The WISP industry provides reliable broadband to millions of Americans, using a flexible toolbox – the right technology for the right job. That includes the judicious use of fiber, even though WISPs are obviously known best for fixed wireless access (FWA) solutions using licensed as well as unlicensed spectrum.

Unlicensed spectrum, like it or not, is the uniquely available, deployable and resilient asset that has consistently, rapidly and reliably brought service to the unserved. It should be no surprise, then, that WISPA’s members have long been the first to push forward to close the digital divide by serving truly unserved and underserved areas – precisely those evolving frontiers that WISPs have always run toward and NTIA now targets with the BEAD program. Household-name providers using wireline technologies have either tended to avoid these markets altogether, or readily abandoned them when profit considerations shifted their priorities. That is why no discussion about “reliable broadband service” can be complete without the concept of “reliable broadband operators,” and in this arena WISPs outshine the others. One reason: WISPs, which typically invest their own capital to grow and operate their businesses, tend to prefer and manage their business models right-side up. Wireline technologies, on the other hand, have generally been poor fits for unserved areas because their associated business models start, and typically remain, upside down.

But enough about WISPs for a moment. Let’s talk about BEAD, and why WISPA is concerned about NTIA’s approach.

As currently envisioned, NTIA’s exclusion of unlicensed spectrum from its definition of “reliable broadband service” will effectively declare those markets to be unserved, opening them to overbuilding by operators that cannot otherwise sustain their businesses without BEAD subsidies. Overbuilding a served market takes money away from the truly unserved and underserved markets. Why? The same operators that could not make a go of wireline service in unserved areas prior to BEAD will not be in a hurry to attempt that again, especially when denser, juicier target markets are available under BEAD. In addition, fiber supply chain issues mean that to whatever extent the truly unserved markets receive funding, they will be waiting for years – well into the next presidential administration (and who knows what that will mean for NTIA) – before seeing any progress on closing the digital divide. FWA, and especially unlicensed spectrum, can solve for that today.

If it is a question of speed, fiber certainly delivers but very few residential or business customers can actually consume gigabit broadband today. The demands of applications such as videoconferencing, streaming, and even gaming are well within the performance scope of FWA customer premise equipment presently in use, and equipment manufacturers in the WISP space continue to develop innovative and remarkable technology advancements that have already extended WISP capabilities well into the gigabit range and above. But if you examine the backhaul utilization of major, even fiber-based, providers, do not be surprised to see an actual, sustained aggregated bandwidth demand, per customer, in the 5 Mbps range. We all might love the idea of gigabit speeds for our periodic iOS updates, but WISPs have found that their customers prefer packages topping out at around 50 Mbps, even when higher speed packages are offered at competitive pricing.

The FCC has recognized that FWA, including unlicensed spectrum, is equivalent in resiliency to aerial fiber *on composite poles*. The FCC found aerial fiber on wooden poles to be *inferior* to FWA; only buried optical fiber scores higher in resiliency. Do you foresee, in unserved or underserved areas, massive investment in buried optical fiber under BEAD? Aerial fiber on composite poles? NTIA’s exclusion of unlicensed spectrum, therefore, is not aligned with the FCC and appears to be grounded in politics, not reality.

Industry analyst Roger Entner recently found that “fixed wireless customers would recommend their service more than that of any other service… This should be a wake-up call for the providers of every other technology.” Entner added, “But NTIA deciding to ignore strong customer preference for fixed wireless access puts the BEAD effort on a troubling path. It is true that fiber and its related technologies are robust solutions for closing digital divides, but wireless fixed access also has an important role to play by providing cost effective access with speeds that stretch dollars further than they otherwise would go.”

The industry has grown precisely because FWA technology works so well, and its purveyors – WISPs – adeptly know how to use and configure it so it delivers the experience customers want and expect. None of this could be achieved without technically competent, market-facing operators, which aptly describes the WISP community. WISPs are broadband’s first responders. Nine million Americans obtain their broadband service from 2,800 WISPs. Banks, private equity and other financial establishments have provided FWA providers billions of dollars to grow their FWA networks. And, a $10 billion+ hardware, software and services industry has emerged to support FWA’s growing connectivity.

There are many reasons to be excited about closing the digital divide, bringing service to truly unserved and underserved markets, and the promise of significant federal dollars to stimulate these priorities. Overbuilding served markets is not one of them, and has no place in a program with such broad ambitions. Fiber has its place, but FWA gets it done. Even, and especially, using unlicensed spectrum. Let’s leave the anecdotes about nefarious operators out of the discussion, unless we are also going to talk about ILEC/CLEC shenanigans, fiber cuts, slow response to wireline outages, and core competencies of municipal broadband initiatives. Go with the first responders to triage any challenge requiring urgency: WISPs.

David M. Zumwalt
President & CEO
WISPA

David, I would like to know why you haven’t made a statement about the issues with the position of the NTIA(and the FCC) regarding unlicensed fixed wireless until yesterday, July 25th?

The FCC has not released a statement contradicting that of the NTIA specifically regarding unlicensed fixed wireless, so it’s pretty obvious that they share the position with the NTIA.

Not that you care, but your answer will determine whether or not we stay a member of the joke that WISPA has become.

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