Tag Archives: technology neutral

Technology Neutral

I cringe every time I see the term “technology neutral”. Over the last few years, NTIA has morphed the phrase into a euphemism to mean we should favor the cheapest technology over the best technology.

And it clearly is a euphemism meant to disguise the true nature of the broadband policy discussion from those not involved in the topic every day. Governments have gotten so good at developing such phrases that the euphemisms replace the right language and become common usage. We routinely hear phrases like revenue enhancement instead of tax increase, or negative growth instead of losses without fully realizing what is not being said.

The phrase technology neutral didn’t start as a euphemism. It comes from a policy paper issued during the Clinton Administration, “Framework for Global Electronic Commerce“, which used the term “technology-neutral” to warn that governments shouldn’t get involved in trying to steer the technology direction for the budding Internet industry. The Administration at the time believed that a hands-off market approach would best allow the Internet to develop. It turns out they were right.

It seems pretty clear that the term was tossed into the IIJA legislation as a bone for WISPs. They badly wanted to participate in BEAD and used the term technology-neutral to plant the idea that all technologies that could deliver speeds of 100/20 Mbps were all equivalent. Until Tarana came out with much faster radios, the fixed wireless technology at the time didn’t deserve to be considered for long-term grants – and sure enough, five years later, the older radios have already joined DSL and other older technologies in the obsolete technology trash bin.

I’ve been searching for a good analogy for the current use of technology neutral and think I have one. Consider a tiny village that is not connected to the power grid. There is a wide range of technology solutions for providing homes with heat and light. The village could be given a self-sufficient solar power farm. They could be connected to a nuclear power plant. They could be given an obsolete coal-powered plant being decommissioned from somewhere else. Each home could be given a gas generator. They could be provided with the low-tech option of fireplaces and axes to chop firewood.

The various technology choices are clearly different in terms of cost and effectiveness. The NTIA technology neutral position would say that all of these options are acceptable, as long as they deliver heat and light to the homes today and also will deliver heat and light in the foreseeable future. If there were a government grant to bring heat and light to the towns that operated under the NTIA rules, the decision would be made on cost, since all of the solutions are considered to be technology-neutral. I don’t think the rural residents would be thrilled with their government-subsidized axes.

Don’t mistake this as a rant for building fiber instead of other broadband technologies. In the example, it would be extreme to build the most expensive solutions, like a nuclear power plant. I don’t know anybody who supports the idea of spending huge amounts of money to bring broadband to a small number of places. Going back to the village in my example, there are a lot of options between a nuclear power plant and fireplaces.

The real problem I have with the term technology neutral is that it says that all broadband technologies are the same, and they clearly are not. Starlink is not equivalent to fiber for a small community. For one thing, fiber can be used for a lot of other purposes that can benefit the community beyond bringing home broadband. Using a euphemism is a way to disguise the real discussion that should be held at State Broadband Offices – what can be afforded for the funding that is available. I think States were mostly doing that, but the shift to the lowest-cost solution ended all logical deliberation.

As we saw in the first BEAD award from Louisiana, which was done under the original BEAD rules, the State still awarded satellite technology for some locations, because that was the most sensible solution for those places. But when the rules got reshuffled to impose technology neutrality, deliberate decisions of the broadband office were replaced with a simple cost comparison.

Full Speed Ahead

State Broadband Offices have seemingly aligned to put pressure on the federal government to get the BEAD awards made and the construction process started this year. While there might be a few exceptions, most State Broadband Offices have accelerated the grant review process and are either ready to make BEAD awards now or soon will be in a position to do so.

This is an interesting strategy because it seems to be coupled with getting State and local officials to lobby for a rapid conclusion of the grant process. County Boards and governors have been asking federal elected officials to let the BEAD process play out.

This is not to say that folks don’t want to see some changes in BEAD. For example, there are popular ideas in the federal SPEED for BEAD Act that would make it easier for ISPs to build. Those kinds of changes could be incorporated into BEAD contracts with grant winners without slowing down the process. Grant Offices and local officials fear a total reshuffling of the rules will force States to start the process all over again. If the decision at NTIA is to change grant scoring metrics, then it probably means changing the BEAD Volume 2 rules and having ISPs file all over again for the BEAD grants. It’s hard to imagine that a change like that won’t add six months to a year to making grant awards and would kill the chance of any broadband construction in 2025.

One of the most convincing things I’ve seen on the topic is a letter published by Broadband Communities Magazine. The letter was written by Josh Etheridge, the Co-Owner of EPC, a fiber construction firm. He pleads with officials to release the BEAD funding in Louisiana and says that delays have already forced him to start laying off some of his 160 full-time staff and an equal number of subcontractors. He makes the convincing argument that BEAD money ultimately gets spent supporting jobs in local communities – which was the stated purpose of the IIJA legislation that created BEAD.

NTIA says it will hopefully be ready to provide new guidance on BEAD around mid-May. So far, everybody associated with the NTIA BEAD process has been completely noncommittal about what changes might be coming. The only thing of substance that has been hinted at is that BEAD awards ought to be more technology-neutral to cut down on amount of grant funding needed. It’s that statement that has the whole industry on edge and on hold.

The BEAD grants were allocated to States in an extremely uneven manner since money was allocated using faulty FCC maps. Some States have enough BEAD money to mostly fund a fiber solution, as has been done in Louisiana. But even there, some of the money went to alternate technologies to serve remote locations. Other states are going to have to make substantial grants to non-fiber technologies to make the numbers work.

Broadband Offices and State and local officials all want to see the grant funding awarded to their states to build as much fiber as possible while still assuring that all BEAD-eligible locations get some better broadband solution. I think the big fear is not only that more funding will go to satellite, but that ‘excess funds’ will be reclaimed by Treasury and not spent on broadband. The phrase ‘once in a generation’ funding has probably been used too often for BEAD, to the point that people don’t really hear what it means. States are doing a magnificent job of spreading the BEAD money to bring as much public benefit as possible – and they are all asking to be left alone to finish the job.

We’ll find out in a few weeks if the strategy of plowing forward will be convincing. It’s certainly the fastest way to turn BEAD grants into construction projects.

Technology Neutral

The term technology neutral has been around for a number of years related to federal grants. The first program that included the term that I remember was RDOF, although it likely was used earlier. The term is used among the folks who create grant programs as a way to not dictate technology choices – any technology that can meet the requirements of a given grant program should be considered.

The term is taking on significant new meaning in the BEAD grant process. The BEAD legislation said that the BEAD program was supposed to be technology neutral. However, the NTIA adopted a principle that States should favor fiber whenever possible, while acknowledging that other technologies are going to be needed to reach everybody.

Interestingly, most States did not need to be prodded in the direction of fiber. State broadband programs that were in place before BEAD largely favored fiber, even though some funding was made to other technologies like fixed wireless. If you examine the grant awards made by States from the Capital Project Funds, the large majority of awards went to fiber.

It makes sense that States have favored fiber because that’s what they’ve heard from elected officials around their state. I’ve worked with dozens of counties in the last few years, and every one of them is hoping to get rural fiber. They have become convinced that this is the technology that will carry them for the next fifty years.

It’s not hard to understand the reasons for the preference for fiber. If we go back even a few years, preferring fiber was clearly the best goal for most counties. Fixed wireless technology has gotten magnitudes better in the last few years, but the radios that were available five years ago did not compare well to the capability of fiber. FWA cellular wireless is also new to the rural market and didn’t exist before a few years ago. Nobody took satellite broadband seriously a few years ago because almost every part of the country had long waiting lists for folks hoping to get satellite service.

It’s clear that the new head of the NTIA is going to eliminate the NTIA’s preference for fiber. The NTIA had already started down that road over the last half year in making it easier for States to make BEAD awards to alternate technologies.

The question that every State broadband office is getting tired of being asked is if they are still going to be allowed to make awards to build fiber, and if so, under what parameters. Will the NTIA dictate specific rules for choosing fiber or will it modify the guidelines on how to evaluate alternate technologies?

There will be a lot of pushback from States if they can’t build much fiber, because governors and state officials have been promising to build as much fiber as possible. A large number of counties have made local matching grants to ISPs that are proposing to build fiber.

To a large degree, any significant change that limit the amount of fiber that will be built by BEAD feels like a political decision more than a policy decision. That’s interesting because the biggest recurring theme I’ve witnessed in the push for better rural broadband is that it has been nonpartisan everywhere. I remember being at a County Board meeting five years ago when the Board members joked that it was a pleasure to finally be working on a topic where they all agreed.

Nobody knows how BEAD will change. There are parts of the program that every ISP would like to see changed. However, there are a lot of county and state officials hoping to see fiber being funded, as was done in the recently announced awards in Louisiana.

Lets Stop Talking About Technology Neutral

A few weeks ago, I wrote a blog about the misuse of the term overbuilding. Big ISPs use the term to give politicians a phrase to use to shield the big companies from competition. The argument is always phrased about how federal funds shouldn’t be used to overbuild where an ISP is already providing fast broadband. What the big ISPs really mean is that they don’t want to have competition anywhere, even where they still offer outdated technologies or where they have neglected networks.

Today I want to take on the phrase ‘technology neutral’. This phrase is being used to justify building technologies that are clearly not as good as fiber. The argument has been used a lot in recent years to say that grants should be technology neutral so as not to favor only fiber. The phrase was used a lot to justify allowing Starlink into the RDOF reverse auction. The phrase has been used a lot to justify allowing fixed wireless technology to win grants, and lately, it’s being used more specifically to allow fixed wireless using unlicensed spectrum into the BEAD grants.

The argument justifies allowing technologies like satellite or fixed wireless using unlicensed spectrum to get grants since the technologies are ‘good enough’ when compared to the requirement of grant rules.

I have two arguments to counter that justification. The only reason the technology neutral argument can be raised is that politicians set the speed requirements for grants at ridiculously low levels. Consider all of the current grants that set the speed requirement for technology at 100/20 Mbps. The 100 Mbps speed requirement is an example of what I’ve recently called underbuilding – it allows for building a technology that is already too slow today. At least 80% of folks in the country today can buy broadband from a cable company or fiber company. Almost all of the cable companies offer download speeds as fast as a gigabit. Even in older cable systems, the maximum speeds are faster than 100 Mbps. Setting a grant speed requirement of only 100 Mbps download is saying to rural folks that they don’t deserve broadband as good as what is available to the large majority of people in the country.

The upload speed requirement of 20 Mbps was a total political sellout. This was set to appease the cable companies, many which struggle to beat that speed. Interestingly, the big cable companies all recognize that their biggest market weakness is slow upload speeds, and most of them are working on plans to implement a mid-split upgrade or else some early version of DOCSIS 4.0 to significantly improve upload speed. Within just a few years, the 20 Mbps upload speed limit is going to feel like ancient history.

The BEAD requirement of only needing to provide 20 Mbps upload is ironic for two reasons. First, in cities, the cable companies will have much faster upload speeds implemented by the time that anybody builds a BEAD network. Second, the cable companies that are pursuing grants are almost universally using fiber to satisfy those grants. Cable companies are rarely building coaxial copper plant for new construction. This means the 20 Mbps speed was set to protect cable companies against overbuilding – not set as a technology neutral speed that is forward looking.

The second argument against the technology neutral argument is that some technologies are clearly not good enough to justify receiving grant dollars. Consider Starlink satellite broadband. It’s a godsend to folks who have no alternatives, and many people rave about how it has solved their broadband problems. But the overall speeds are far slower than what was promised before the technology was launched. I’ve seen a huge number of speed tests for Starlink that don’t come close to the 100/20 Mbps speed required by the BEAD grants.

The same can be said for FWA wireless using cellular spectrum. It’s pretty decent broadband for folks who live within a mile or two of a tower, and I’ve talked to customers who are seeing speeds significantly in excess of 100/20 Mbps. But customers just a mile further away from a tower tell a different story, where download speeds are far under 100 Mbps download. A technology that has such a small coverage area does not meet the technology neutral test unless a cellular company promises to pepper an area with new cell towers.

Finally, and a comment that always gets pushback from WISPs, is that fixed wireless technology using unlicensed spectrum has plainly not been adequate in most places. Interference from the many users of unlicensed spectrum means the broadband speeds vary depending on whatever is happening with the spectrum at a given moment. Interference on the technology also means higher latency and much higher packet losses than landline technologies.

I’ve argued until I am blue in the face that grant speed requirements should be set for the speeds we expect a decade from now and not for the bare minimum that makes sense today. It’s ludicrous to allow award grant funding to a technology that barely meets the 100/20 Mbps grant requirement when that network probably won’t be built until 2025. The real test for the right technology for grant funding is what the average urban customer will be able to buy in 2032. It’s hard to think that speed won’t be something like 2 Gbps/200 Mbps. If that’s what will be available to a large majority of households in a decade it ought to be the technology neutral definition of speed to qualify for grants.