Two industry trade groups are urging the NTIA to ensure states fund fiber for as many locations as possible through the $42.5 billion Broadband Equity Access and Deployment (BEAD) program. The groups, ACA Connects and NTCA–The Rural Broadband Association, further said that low-Earth orbit (LEO) satellite services, like Starlink, should be funded as "a last resort."

The commentary was filed in response to the NTIA's request for comment on its guidance issued last month on when and how BEAD funds can be used for "alternative" technologies, including LEO satellite and unlicensed fixed wireless access (FWA) services. While the NTIA's guidance was issued to address ongoing pushback from the wireless industry and some states on the BEAD program's fiber focus, both ACA and NTCA urged the agency to continue to prioritize fiber when reviewing state BEAD proposals.

Acknowledging that "various technologies will of course have a place in ensuring 'Internet for All,'" the groups said that the NTIA and states should first "pursue all avenues in prioritizing the deployment of fiber infrastructure to as many locations as possible, before turning to other reliable broadband technologies to eligible locations where necessary and then finally looking to the use of alternative (i.e., non-reliable) technologies in very limited circumstances."

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The letter – filed September 10, and signed by Brian Hurley, chief regulatory counsel at ACA Connects, and Michael Romano, EVP at NTCA – added: "Where non-reliable technologies are supported, Eligible Entities should first fund those that bring fiber closest to eligible locations, and then, only as a last resort, turn to providers using low-earth orbiting satellite ('LEO') systems."

Specific to LEO systems, the groups further suggested the NTIA open a separate inquiry to answer "the many complex questions" about "how subsidizing shared connectivity on LEO systems could work as a practical matter and fit within a statutory construct intended by its terms to promote 'infrastructure investment.'"

In addition to LEOs, the groups also cautioned the NTIA against approving fixed wireless over unlicensed spectrum if fiber is a viable option.

"With respect to broadband services delivered via unlicensed spectrum, factors beyond even the most capable provider's control can render connections unreliable for consumers," said the groups, adding that both FWA and LEO will require "reinvestment cycles," unlike fiber projects.

"Fiber networks present a stark contrast – fiber technology can support both existing and future applications for many decades without infrastructure changes and with far less additional investment as compared to alternative technology platforms," states the letter.

Learn from past mistakes

ACA Connects and NTCA further urged the NTIA to pursue a fiber focus for the BEAD program in order to avoid repeating the mistakes of other federal broadband programs, including the Connect America Fund (CAF) and the Rural Digital Opportunity Fund (RDOF).

Referring to RDOF, the groups noted that "satellite providers received nearly $2.5 billion in support, and the FCC wound up clawing back more than two-thirds of that award and in doing so noting that higher capacity and more affordable (for users) fiber deployments should take funding priority."

SpaceX's Starlink was specifically approved for $885.5 million to cover 642,925 estimated locations in 35 states through RDOF, but the FCC reversed course on that decision in 2022, with FCC Chairwoman Jessica Rosenworcel noting that the technology is "still developing" and that its end-user terminals carry a hefty expense.

ACA and NTCA in their letter reiterated that the purpose of BEAD is to connect unserved and underserved locations with "future-proof broadband service that will stand the test of time."

"Put plainly, funding incremental builds over and over again has a terrible track record – wasting time and money alike. NTIA and Eligible Entities should learn from those expensive and avoidable broadband funding missteps, rather than repeat them," wrote the parties.