Use Alternative Technologies Only as a Last Resort
September 11, 2024—ACA Connects–America’s Communications Association and NTCA–The Rural Broadband Association submitted comments yesterday to the National Telecommunications and Information Administration (NTIA) regarding the agency’s proposed guidance on the use of alternative broadband technologies in deployment projects funded by the Broadband Equity, Access, and Deployment (BEAD) Program.
To meet the goal of providing unserved locations with reliable, high-speed internet, ACA Connects and NTCA asserted that NTIA’s alternative technology guidance should neither be seen nor taken as an excuse to water down the strong priority for scalable networks established by the Infrastructure Investment and Jobs Act and BEAD Notice of Funding Opportunity, which recognize that fiber can deliver speeds necessary to meet the evolving connectivity needs of households and businesses over many decades. Rather, states and territories should only use alternative technologies to reach eligible locations where no provider is willing to deploy fiber or other reliable technologies on a reasonable basis, as measured over the economic life of the network.
Accordingly, ACA Connects and NTCA urged NTIA, in enabling the use of alternative technologies, to:
- Prioritize fiber to as many BEAD locations as possible before turning to other reliable broadband technologies and then finally, as a last resort, looking to the use of alternative (i.e., non-reliable) technologies like unlicensed spectrum and low-earth orbiting (LEO) satellite systems;
- In choosing alternative technologies, select projects that deploy fiber closest to unserved locations before considering alternative technologies that do not use fiber; and
- Issue a follow-on notice seeking further comment on how paying for service on LEO satellite systems would fit within the IIJA’s mandate to promote “infrastructure investment” and how theoretically “reserving capacity” on such systems might work given the shared nature of that capacity across multiple jurisdictions (and even countries). If NTIA were to move forward without seeking further comment, the associations stated the agency should adopt their alternative proposal to use BEAD funds only to procure LEO terminal equipment and should enter into an agreement that allows consumers at locations where a LEO provider wins support to obtain service at reasonable prices over a 10-year term.
“NTIA is right to direct States and Territories to leave no stone unturned in connecting unserved locations to fiber and other reliable technologies. This will help ensure participation from small and rural providers, who have vast experience connecting hard to reach locations with high-speed internet,” said ACA Connects President and CEO Grant Spellmeyer. “Only as a last resort should States and Territories turn to using non-reliable technologies. Importantly, low-earth orbiting satellites, which have a narrow market niche, will not give people in more remote areas access to the same robust and reliable connectivity most all Americans enjoy.”
“The BEAD program provides an historic opportunity to address deployment barriers in a lasting way,” said NTCA CEO Shirley Bloomfield. “While alternative technologies can be used to help fill discrete gaps where specific locations are too costly or too difficult to reach with a scalable network, the underlying law makes clear that their usage must be a narrow exception rather than the general rule. We encourage NTIA to implement a policy that scrutinizes at a granular level where unlicensed fixed wireless and LEO-based technologies may be the only choice for connectivity so that as many Americans as possible realize an enduring benefit from the investments prompted by the BEAD program.”
NTIA Comments (w/ NTCA) re Broadband Equity, Access, and Deployment Program: Alternative Broadband Technology Policy
Published September 10, 2024
About ACA Connects: America’s Communications Association –America’s Communications Association – ACA Connects is a trade organization representing more than 500 smaller and medium-sized, independent companies that provide broadband, video, and phone services covering 31.9 million households, 7.3 million of which are located in rural and smaller suburban markets across America. ACA Connects Members operate in every state, providing advanced communications to connect homes, companies, main street, schools, hospitals and more. America’s economic prosperity in smaller communities and rural areas depends on the growth and success of ACA Connects Members, who believe a connected nation is a prosperous nation.