As I work with clients who are thinking about applying for the BEAD grants, I keep stumbling across new issues that I see as problems. Today’s blog talks about how the BEAD grants in a given location could go sideways because of the NTIA’s decision to declare facility-based wireless technologies that use licensed spectrum to be considered as a reliable technology that is eligible for BEAD grants. I can foresee two different problems that might result from this decision.
There are two kinds of wireless carriers that could qualify under this new definition. First, cellular carriers like T-Mobile and Verizon are aggressively marketing FWA fixed wireless for homes using licensed spectrum. In the not-too-distant future, we can expect AT&T, Dish Network, and probably many of the smaller cellular carriers like U.S. Cellular to deploy the technology using licensed spectrum. The carriers are largely advertising this as 5G, but the actual technology being used for now is still 4G LTE.
The other set of facility-based wireless providers are the fixed wireless WISPs that use a mix of licensed and unlicensed spectrum to deliver broadband from towers. Most of these WISPs are using the licensed portion of Citizen Band Radio Spectrum (CBRS), but they can use other licensed spectrum like 700 MHz or other cellular spectrum purchased at auction in the past.
The first problem I foresee is that these wireless carriers can use the upcoming FCC broadband mapping update to lock down huge areas of real estate from eligibility for BEAD grants. Anywhere that these carriers claim speeds of 100/20 Mbps in the next set of FCC maps will be initially declared by the BEAD rules to be served and ineligible for grants.
Unfortunately, the new mapping rules allow for this since ISPs can claim marketing speeds in the FCC mapping. I’m positive that many WISPs will declare the speeds that will classify their areas as served, because many of them already have been reporting these speeds in the past. In just the past year, I’ve worked with at least thirty counties where at least one wireless ISP claimed countywide coverage with broadband – in some cases at speeds of 100 Mbps or faster. These WISPs might have the 100/20 Mbps capability for some customers close to a tower, but it’s impossible to be able to deliver those speeds to everybody across an entire county.
To use an example, I talked to a farmer recently who is thrilled to get the new T-Mobile FWA product at the farm. The tower is on his property, and he is getting 200 Mbps downloads. But the stories from his neighbors are quite different. One neighbor less than a mile away is seeing 75 Mbps download speeds. A few other neighbors two miles or more away claim the broadband is unusable. If T-Mobile was to claim a fairly wide coverage for this technology in the FCC maps, it would be blocking BEAD grant money inside whatever areas it claims.
But let’s say that T-Mobile reports honestly. Under the new FCC mapping rules. a wireless ISP is supposed to input a wireless propagation map like the one below. This map is typical of wireless coverage in that the wireless signal travels further in directions where it is unimpeded. But this example propagation map doesn’t tell the whole story because you might imply that the speeds are the same over the whole propagation area. My farmer example shows that wireless speeds can drop off rapidly with distance from a tower. A map of a 200 Mbps coverage area or even a 100 Mbps coverage area will be tiny for a wireless ISP. The map that should be input to the new FCC maps is just the areas that can get good broadband speeds. In the propagation map below, probably 80% of the green areas probably don’t even see one bar of broadband. It’s also worth noting that the propagation map is not fixed – the coverage area changes with temperature, precipitation, and more mundane factors like the amount of backhaul provided to a given tower.This raises the second issue. If the wireless carriers with fast licensed spectrum report properly in the new maps, there are going to be splotches of areas around every rural cell tower that will be off-limits for grants. In the same way that the swiss cheese RDOF awards goofed up anybody else from bringing a fiber broadband solution, these fixed wireless or cellular blotches will make it hard to build a coherent network in areas that have to avoid the wireless areas. In a real deployment, An ISP will likely build to everybody in an area – but because of the mapping rules, they won’t get grant funding everywhere. I can’t even begin to imagine how somebody building a fiber network is going to properly account for assets that are inside and outside of areas that are supposedly already served.
I wonder if the NTIA understands what it has done. The agency seems to have worked very hard to avoid the problems the FCC caused in the RDOF reverse auction. But this ruling brings in one of the most damaging aspects of RDOF – incoherent grant serving areas. I know there is a challenge process for the maps used for BEAD, but it’s going to be extremely difficult to dispute an ever-changing propagation map around every cell tower or fixed wireless radio. I fear this is going to be one of the newest nightmares to pop out of the revised FCC maps.