WISPA's David Zumwalt Tells Doug Dawson NOFO Overbuilding a Bad Deal

I will begin by noting that I am a P.E. with an Electrical Engineering degree and have been in telecommunications for the majority of my career, spanning cellular, satellite, terrestrial microwave, FWA, and wireline service. Prior to joining WISPA, I served as COO of a major WISP in the USVI which operated in an environment served by multiple WISPs utilizing unlicensed spectrum. I have been impressed by the capability and agility of unlicensed spectrum network infrastructure to manage capacity to deliver broadband to subscribers with excellent grade of service in any environment. Having seen and heard it all, my experience is simply not aligned with the picture you have painted of WISPs.

The WISP industry provides reliable broadband to millions of Americans, using a flexible toolbox – the right technology for the right job. That includes the judicious use of fiber, even though WISPs are obviously known best for fixed wireless access (FWA) solutions using licensed as well as unlicensed spectrum.

Unlicensed spectrum, like it or not, is the uniquely available, deployable and resilient asset that has consistently, rapidly and reliably brought service to the unserved. It should be no surprise, then, that WISPA’s members have long been the first to push forward to close the digital divide by serving truly unserved and underserved areas – precisely those evolving frontiers that WISPs have always run toward and NTIA now targets with the BEAD program. Household-name providers using wireline technologies have either tended to avoid these markets altogether, or readily abandoned them when profit considerations shifted their priorities. That is why no discussion about “reliable broadband service” can be complete without the concept of “reliable broadband operators,” and in this arena WISPs outshine the others. One reason: WISPs, which typically invest their own capital to grow and operate their businesses, tend to prefer and manage their business models right-side up. Wireline technologies, on the other hand, have generally been poor fits for unserved areas because their associated business models start, and typically remain, upside down.

But enough about WISPs for a moment. Let’s talk about BEAD, and why WISPA is concerned about NTIA’s approach.

As currently envisioned, NTIA’s exclusion of unlicensed spectrum from its definition of “reliable broadband service” will effectively declare those markets to be unserved, opening them to overbuilding by operators that cannot otherwise sustain their businesses without BEAD subsidies. Overbuilding a served market takes money away from the truly unserved and underserved markets. Why? The same operators that could not make a go of wireline service in unserved areas prior to BEAD will not be in a hurry to attempt that again, especially when denser, juicier target markets are available under BEAD. In addition, fiber supply chain issues mean that to whatever extent the truly unserved markets receive funding, they will be waiting for years – well into the next presidential administration (and who knows what that will mean for NTIA) – before seeing any progress on closing the digital divide. FWA, and especially unlicensed spectrum, can solve for that today.

If it is a question of speed, fiber certainly delivers but very few residential or business customers can actually consume gigabit broadband today. The demands of applications such as videoconferencing, streaming, and even gaming are well within the performance scope of FWA customer premise equipment presently in use, and equipment manufacturers in the WISP space continue to develop innovative and remarkable technology advancements that have already extended WISP capabilities well into the gigabit range and above. But if you examine the backhaul utilization of major, even fiber-based, providers, do not be surprised to see an actual, sustained aggregated bandwidth demand, per customer, in the 5 Mbps range. We all might love the idea of gigabit speeds for our periodic iOS updates, but WISPs have found that their customers prefer packages topping out at around 50 Mbps, even when higher speed packages are offered at competitive pricing.

The FCC has recognized that FWA, including unlicensed spectrum, is equivalent in resiliency to aerial fiber *on composite poles*. The FCC found aerial fiber on wooden poles to be *inferior* to FWA; only buried optical fiber scores higher in resiliency. Do you foresee, in unserved or underserved areas, massive investment in buried optical fiber under BEAD? Aerial fiber on composite poles? NTIA’s exclusion of unlicensed spectrum, therefore, is not aligned with the FCC and appears to be grounded in politics, not reality.

Industry analyst Roger Entner recently found that “fixed wireless customers would recommend their service more than that of any other service… This should be a wake-up call for the providers of every other technology.” Entner added, “But NTIA deciding to ignore strong customer preference for fixed wireless access puts the BEAD effort on a troubling path. It is true that fiber and its related technologies are robust solutions for closing digital divides, but wireless fixed access also has an important role to play by providing cost effective access with speeds that stretch dollars further than they otherwise would go.”

The industry has grown precisely because FWA technology works so well, and its purveyors – WISPs – adeptly know how to use and configure it so it delivers the experience customers want and expect. None of this could be achieved without technically competent, market-facing operators, which aptly describes the WISP community. WISPs are broadband’s first responders. Nine million Americans obtain their broadband service from 2,800 WISPs. Banks, private equity and other financial establishments have provided FWA providers billions of dollars to grow their FWA networks. And, a $10 billion+ hardware, software and services industry has emerged to support FWA’s growing connectivity.

There are many reasons to be excited about closing the digital divide, bringing service to truly unserved and underserved markets, and the promise of significant federal dollars to stimulate these priorities. Overbuilding served markets is not one of them and has no place in a program with such broad ambitions. Fiber has its place, but FWA gets it done. Even, and especially, using unlicensed spectrum. Let’s leave the anecdotes about nefarious operators out of the discussion, unless we are also going to talk about ILEC/CLEC shenanigans, fiber cuts, slow response to wireline outages, and core competencies of municipal broadband initiatives. Go with the first responders to triage any challenge requiring urgency: WISPs.

The original response can be viewed here.