BEAD Alternate Technology Guidelines

In an action that falls under, “ You can’t keep track of the game without a scorecard”, NTIA released guidelines on how States are to incorporate alternate technologies into BEAD. NTIA originally ruled that alternate technologies like satellite and unlicensed fixed wireless were not eligible for BEAD. Then last year, NTIA issued voluntary guidelines on how States could allow satellite broadband. This new set of rules is mandatory for all States, other than those that have already made grant awards.

Unlicensed Fixed Wireless (ULFW – a new acronym!). NTIA made it very clear from the start that grant money cannot be used to build unlicensed fixed wireless networks, and NTIA declared from the start that the technology does not meet the reliability test described in the legislation. BEAD still can’t be used to build ULFW. However, there are now circumstances where the presence of ULFW could block another ISP from getting a BEAD grant.

  • BEAD can’t be awarded if there is an outstanding grant award to build ULFW, and that grant includes a requirement for future proof of speeds. This has to be a fairly rare circumstance.
  • Before awarding BEAD grant, a State must look at the FCC map to see if a WISP is claiming unlicensed wireless speeds of at least 100/20 Mbps. If they are, the broadband office must give the WISP an opportunity to prove it is capable of meeting the speeds – and if it can, then BEAD will not be awarded.

I find this to be an outrageous change. My outrage is due to NTIA making this change in January 2025. If this was going to be the rule, it should have been done two years ago. Had this been the rule from the start, then other ISPs and local governments would have taken a harder look at unlicensed fixed wireless providers during the BEAD map challenge. But nobody did, because unlicensed wireless wasn’t part of the BEAD universe. With this change, NTIA has given unlicensed WISPs veto power over competing BEAD grants.

I don’t envy State broadband offices that have to somehow judge the speed claims of WISPs – something that most broadband offices will struggle to do. I’ve seen dozens of counties where WISPS claim huge coverage areas with unlicensed spectrum – and nobody ever bothered to check if the coverage is real since it hasn’t mattered for BEAD. But presto – it now matters since 100/20 Mbps ULFW can block another ISP from winning a BEAD grant. I see this as another last-minute disincentive for ISPs to apply for BEAD.

LEO Satellite (Starlink and Kuiper). States can make BEAD grants to the LEO satellite providers, and the first states to make awards have done so. A satellite provider isn’t eligible to receive the funding until it can certify that it is capable of connecting everybody in a given grant area within ten days of a request for service. The satellite provider has up to four years to make this declaration and to start the funding. The satellite provider will then have to conduct the same ongoing speed tests as other BEAD winners for ten years.

There are two tricky parts to giving BEAD to a satellite provider. The satellite company must demonstrate that it has set aside the capacity to serve the study area – since the cost of reserving the capacity is what BEAD is paying for. I’m doubtful that any broadband office is capable of understanding the complexities of the capacity of a worldwide satellite network to be able to judge the satellite company claims.

I’m also curious about all of the satellite customers already served in a grant area. A consultant for the Fiber Broadband Association recently estimated there are already 215,000 Starlink customers in BEAD areas – I can’t imagine how they could know the number. I’m curious when a State makes a BEAD grant for satellite how it will deal with the existing customers.

6 thoughts on “BEAD Alternate Technology Guidelines

  1. Here we are seeing the fundamental flaw in the Infrastructure Investment and Jobs Act of 2021. As originally drafted, it contained an infrastructure-based standard: fiber to the premise. It was then amended to use a throughput-based standard and this is the result. Claims, controversy, confusion. How many served/underserved/unserved “broadband speed” angels can dance on the head of a pin?

  2. Pretty harsh on wisp coverage areas in this.

    Something to consider is that when the government demands maps be made it should make sure the resources are available to build those maps. In the case of ALL wireless technologies including LEO, appropriate topography and landcover mapping is needed and the most appropriate date is LIDAR data. That is simply unavailable for most of the country in a usable format or done recently enough. ie, houses are built, trees grow, trees are cut, the data needs to be current. LEO orbits are often blocked by tall trees or mountains etc, but there’s no expectation that they show coverage areas accurately. Cell/LTE FWA get’s to use big blobs of map that are well established to be full on ‘BS’.

    Without this data, the map basically MUST be a ‘site survey available’ map. There’s no other reasonable map to publish. With LIDAR and non-free software you can build much more detailed coverage maps with dramatically better accuracy, basically determined by the quality/resolution of the LIDAR data.

    WISP speeds are no different than any other service. You want to see high variance in service, measure starlink hourly. Or check DSL service on sold vs delivered. or check an LTE/5G solution routinely. Or a docsis plant during prime time.

    WISP tech has evolved dramatically. We offer legacy services as low as 25M and premium services up to 1G in rural areas on ‘ULFW’, that’s what we consider legacy ‘airmax’ which can comfortably and realibly deliver 50Mbps (maybe 100M in good environments) up to Tarana gear. These are more stable connections than LTE networks, more consistent latency, professionally installed services. We use 2.4, CBRS 3Ghz, 5Ghz, AFC 6Ghz, 60Ghz in our mix.

    I’ll agree in principal that FWA or wireless of any kind shouldn’t probably be build with gov funds because they are in a sense ‘temporary’ with limited production life of around 10 years or so and I think that is doubly true on LEO with the satellite having a ~5year lifespan. However, I think BEAD and similar monies should be available to build fiber to the tower sites or build long haul fiber to the communities. I want to emphasize that if Starlink stopped launching satellites today, by January 14th 2030 the service is completely offline globally, it’s is a very temporary model with continuout maintenance. For a WISP, the gear I placed 10 years ago can still push 25-50Mbps to a home and likely will do that for another decade with occasional ‘old age’ losses.

    I can tell you with confidence that 10G fiber to a Tarana 3+6Ghz deployment delivers an unlicensed wireless service that competes head to head with fiber to the home and docsis services and can be rapidly deployed. Similarly, a 10G fiber to a Ubiquiti Wave or Tachyon mmWave deployment delivers a fiber equivalent experience to end users. Why not let operators spend those BEAD funds on getting that fiber to the service site?

    so I propose that we say “FIBER ONLY but you can build fiber to access sites for any sort of last mile service, operators just have to fund the wireless bits themselves”.

    • 100% with Daniel here. If we pull back one step from “to-the-home” and leave that last hop up to the local ISP, we would get 20x the mileage out of every gov dollar granted.

      The point about if Starlink stopped launching rockets is extremely valid. We have loads of gear in the field that is pushing 8 year old still 100% satisfying the need. And when it doesn’t, the ethernet going to the gear is 1Gbps capable. I can in ~15 minutes swap that out to Wave or Tarana and be good for another decade.

      • “If we pull back one step from “to-the-home” and leave that last hop up to the local ISP, we would get 20x the mileage out of every gov dollar granted.”

        but even better is the economic gains in those areas from having ‘carrier grade’ fiber, allowing operators from very small to very large to build and compete there, creating jobs and variety and choice to consumers.

        No single vendor markets because it’s relatively easy to compete.

  3. I’m not sure I agree with the interpretation of the guidance here. ULFW is considered an Alternative Technology by NTIA and, I think, can be funded by BEAD. There are the various tests that must be passed (no bid, extremely high cost, etc) to trickle down the BEAD priority list, but in the absence of any other options, funds can be awarded to build ULFW to those locations or to bolster capacity to existing Alt Tech, such as LEO.
    As to existing ULFW providers, my read of section 3 is that they can be overbuilt with BEAD funds (ridiculous!), should the project be for Priority or Reliable technology. In the absence of a “reliable technology” bid, an existing ULFW provider can submit evidence to show they deliver the covered speeds and meet the capacity requirements this guidance sets forth, which allows States to then consider the locations served. Only government could think this makes any sense.
    While I appreciate the additional flexibility NTIA has provided, this is one of the more frustrating parts of BEAD to me. As dandenson notes in his comment, ULFW is now capable of delivering quality speeds and is every bit as reliable as its licensed counterpart. Tarana gear, in particular, has exceptional capabilities from both speed and interference mitigation standpoints and let’s not forget that these are going to be the most rural locations, where there isn’t likely to be much interference to begin with. Locations served at or above the BEAD benchmark by ULFW should not be eligible for funding, IMO, yet monies will be spent to overbuild these locations. The lobbies that won the favor (and pocketbooks) of those that set the BEAD rules are certainly favored in this program.

  4. We’re using both Tarana and UI Wave to beat out Xfinity for local government contracts. The upper management in government needs to talk to the local government pleebs on what actually works well in the field.

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