A $42.5 billion program to improve high-speed internet access for rural Americans must prioritize fiber-based technologies and other types of designated reliable broadband service and only fund alternative technologies “as a stopgap measure,” NRECA told federal regulators.

The association filed comments Sept. 10 in response to the National Telecommunications and Information Administration’s proposed guidance for alternative technologies under the Broadband Equity, Access, and Deployment (BEAD) Program. The program, created through the bipartisan infrastructure law of 2021, provides grant money to states to expand broadband access in unserved and underserved locations, including rural areas.

More than 200 rural electric co-ops are working to provide broadband service, either on their own or through partnerships with affiliated or unaffiliated internet providers.

NTIA’s final technology guidance “should recognize that BEAD support for alternative technologies will disincentivize investment of RBS [Reliable Broadband Service] network infrastructure to serve those locations,” NRECA Senior Regulatory Affairs Director Brian O’Hara said in the comments. “BEAD support for alternative technology to serve a given location should therefore last only as long as RBS is unavailable at that location.”

Further, alternative technology funded areas should remain eligible for other federal and state funding to bring reliable broadband service, he said.

NTIA has recognized that alternative technologies, such as satellite and unlicensed spectrum service, are substandard and should only qualify for BEAD money in very limited circumstances, O’Hara said. NRECA supports that interpretation, noting that some very remote broadband serviceable locations may need low earth orbit (LEO) satellite or unlicensed wireless in the near term.

But the association wants more clarity in NTIA’s final guidance to promote development of RBS “as much as possible.” Under the infrastructure law, RBS must be a fixed broadband service that is available with a high degree of certainty for the foreseeable future and can include fiber-optic, cable modem/hybrid fiber-coaxial, and digital subscriber line technologies.

“As a general matter, NRECA is concerned that the Policy Notice may enable use of BEAD funding to support alternative technologies well in excess of what is anticipated or proper,” O’Hara said.

For example, the draft guidance suggested that alternative technologies could qualify for BEAD funding in locations that did not receive an offer to serve from any RBS provider—broader criteria than in the NTIA’s notice of funding opportunity for BEAD, which said alternative technologies may only be funded in areas where all RBS proposals exceed a certain high cost threshold.

To address its concerns, NRECA asked NTIA to:

• Clarify the specific circumstances when BEAD funding can support alternative technologies.
• Ensure that BEAD support for alternative technologies is “stopgap” only.
• Give further guidance on required technical capabilities of LEO satellite service, including how to verify that such systems meet BEAD’s speed requirement of 100/20 megabits per second.
• Clarify BEAD-eligible costs for LEO service.
• Structure the BEAD subaward process to maximize reliable broadband service and minimize alternative technologies, including by prioritizing RBS proposals and encouraging flexibility in the bidding areas for hard-to-serve locations.

BEAD funding was allocated to states and territories in June 2023, and NTIA expects to approve all state initial proposals by this fall.