Commenters Mostly Supportive of Satellite, Fixed Wireless as BEAD Alternative Technologies

Which technology is best for a location "depends on a number of factors," said the Wireless ISP Association, whether it's licensed spectrum, fiber, unlicensed fixed wireless technology, or a combination of technologies. WISPA "very much appreciates NTIA's acknowledgment of these realities" and should adopt its proposed guidance with the inclusion of free-space optics as an allowed alternative technology.

Let states use fixed wireless and low earth orbit satellite broadband to "fill coverage gaps" in areas where eligible entities determine it's "cost-effective and relatively rapid to deploy," said New America's Open Technology Institute. NTIA should recognize that "all states and territories will have rural, remote and topographically difficult locations that are unserved and must be part of the initial approved implementation plan," OTI said. "Any additional federal funding that can be freed up for state and local digital adoption efforts could have a substantially larger impact on narrowing the digital divide than would holding out for fiber-to-the-home connections in outlier locations with exorbitant costs and delays."

The proposed guidance would "provide an approved solution for states to adopt when confronted with non-viable locations as opposed to wrongfully requiring providers to serve non-viable locations with fiber at their own cost," said USTelecom. NTIA should require states to disclose their extremely high cost per location threshold (EHCPLT) and "engage in good faith negotiations with service providers regarding BEAD deployment opportunities before utilizing funding for alternative technologies."

It's "well understood" that the $42.5 billion BEAD funding "will not deliver fiber to all unserved and underserved locations across the nation," said CTIA, adding that many states "have made clear that the BEAD program's fiber-first approach, which an EHCPLT set to advance fiber builds to unserved locations, will deplete their BEAD allocations and leave them short of delivering internet for all." The group backed fixed wireless access as an alternative, noting it can "often be deployed faster, at lower cost than fiber, and with higher levels of reliability than alternative technologies." CTIA also supported 5G fixed wireless, saying it offers "tremendous potential across rural America." R Street Institute encouraged the use of lose earth orbit satellites and fixed wireless technologies. "After years of uncertainty about the BEAD program, it is clear that these alternative technologies are the only way for NTIA to make real progress on its stated endeavors of connecting more Americans," the group said.

ACA Connects and NTCA raised concerns about LEO satellite systems in joint comments, urging NTIA to allow them "only as a last resort." LEO systems may be "unworkable" and "fail to meet the public interest objectives of the BEAD program," the groups said. NTIA should "negotiate a master agreement with a LEO provider that an eligible entity would then use and that would enable consumers at eligible locations to purchase terminal equipment on a supported basis." The groups also suggested 10-year performance assurances on an unsupported basis and asked NTIA to issue a separate notice seeking additional comment on "how subsidizing shared connectivity on LEO systems could work as a practical matter."