June 12, 2025 AZBSN Digital Access Task Force Recording
1:05AM Jun 13, 2025
Speakers:
Steve Peters
Mark Goldstein
Henry Goldberg
Rory Conaway
Kelly Krusee
Gordon Fuller
Randy Luening
Reid Sharkey
Frank Martinez
David Ackerman
Rachael Maddock-Hughes
Keywords:
BED restructuring
Commerce Department
broadband office
NOFO
technical assistance
USDA grant
Arizona broadband
project areas
unlicensed wireless
affordability
satellite providers
environmental requirements
timeline
sub grantee selection
community anchor institutions.
Cool. Okay, good morning. Everybody going to go ahead and get started. We'll probably still have other people join us, but we have a lot to cover and to talk about today, so I just want to jump into into the agenda. And speaking of the agenda, here's just quickly what we're going to be talking about today. So we want to get a quick update from the broadband office on what's happening since with all the changes to bead and so Kelly is going to give us a quickie update about that, and then we're going to do a panel discussion today on the impact of the Commerce Department's new NOFO and bead restructuring, restructuring poly policy notice, and we'll get a quickie update from Lucy. How about this CEO force for the Health Source, force for health network that the we're working on with AZ BSM and the force for health and so just quickly, excuse me. So just quickly coming up meeting, come upcoming meetings. Well, first of all, I want to mention that meeting next meetings. The meetings are June 12 and the 19th. There will be no meeting on June 26 since I will be on vacation and traveling, and, gee, I'll have to be on a lake in Minnesota. And, of course, no meeting on July the third, so we'll be back after July the third, so we'll have a two week hiatus. And so just wanted to tell you about that, and then just some upcoming meetings with some dates to be determined on July 17, we are. We're great. It's great to welcome Joey Wender, who's the new executive director of the school's health and libraries broadband coalition, and he has agreed I had a chance to meet Joey at the NTIA conference a few weeks ago, and so he has agreed to come and meet with us. And then several months ago, actually, we had talked about doing a discussion about public networks. What are they? Pros and cons and so forth, and it looks like we're going to do that. Don't have a date yet. Gigi Sohn, who many of you know, is the executive director of the American Association of Public broadband, she's probably one of the most knowledgeable about issues regarding public networks, and so I actually saw her at the conference, and she has agreed to meet with us also, so I will be getting that scheduled after the hiatus when I'm on vacation, and then I'm also going to schedule a time for Ryan Murray, who we, who's been with us before. Ryan is the Deputy Director, and there's chief is the Deputy Director and Chief Information sir, security officer for the Arizona Department of Homeland Security, Ryan has been with us before. If anybody knows what's happening inside our cybersecurity here in Arizona, who were all the players, what people were doing, it's Ryan. So he has agreed also, and I need to schedule a date for him. So those are just some of the things that are coming up in the future, hopefully in July, but we'll see when I get back. We'll see where we are with everything, with bead and everything else so but that's tentatively some of the upcoming meetings. So the next thing quickly, I just want to remind you, and you probably saw this in my newsletter, that last week, we were pleased to again welcome Judy sotro, who is the northern Arizona outreach and constituent services coordinator for Senator Kelly. Judy has been, has tries to participate in this task force whenever she can, and she did ask us to in order to help support the senators advocacy efforts in the Senate. And of course, at that time, we were talking about DEA funding. Now we've got another issue, and talking about bead, so she has asked that we sent emails to the senator, well, to her, for the senator with stories that describe how the funding terminations are impacting your plans, your organization, initiatives and constituents. And her information is below, and she would like that sooner rather than later. And. Because of all the stuff that's happening in Washington these days. So moving on. I want to briefly introduce David Ackerman, who's a CEO of ACG engineering, and they have a grant to be able to provide a technical assistance support and so he's going to take two minutes to tell us who they are. Matt combs is also with or Coombs, is it? Yeah, that's cool. So Matt Coombs and David Ackerman are going to give us a two minute overview, and then we'll have him back at a future time. David, please.
Thank you, Steve, thanks everybody for letting me have this quick moment. I really just wanted to introduce myself and an excellent opportunity that I think everyone on this call will be interested in. So like Steve said, my name is David Ackerman, CEO, founder of Ackerman Consulting Group. We're a broadband consulting and engineering firm. We partner with rural and tribal communities, ISPs, public entities, and our whole purpose is to help get meaningful broadband projects funded and built. So bead is kind of the big topic right now. So if you're looking at bead, whether it's community ISP, whatever, and you need help navigating the federal process or engineering design grant writing, etc. Let's talk. I'll put my info in the chat after this. The main thing I wanted to talk about is we are recently awarded the USDA BTA, which is the broadband technical assistance grant to support efforts in Arizona, specifically nine counties, Apache, Cochise, Coconino, Greenlee, Maricopa, Mojave, Pima, Pinal and Yuma, our team is able to provide end to end support with everything from Pre screening and engineering to permitting and strategic planning. Real quick. We've also partnered with rural prosperity partners. They are on this call Rachel and Joe. They have a similar program that they are running up in Oregon. It's been wildly successful, and we're taking that here to Arizona. So if you or any organization that you know has any needs, as far as technical broadband support, we have federal funding to support that. And again, I'll just drop my info in the chat. Thank you very much. Steve,
sure, so David and Rachel, as long as you're on the call, Rachel, so can you guys talk about now that we've got all these changes to be and pretty tight timeline, are you guys going to be able to help people in the current environment?
So yeah, David, that timing and grant issue. So we're waiting. I think David is waiting for the final go ahead from USDA, as you all know, there's a lot of administrative stuff in there, but I believe that we will be able to so let me just give you a two second rundown. So in Oregon, rural prosperity partners, and we're a technical assistance firm, we focus on rural communities and helping them secure funding. We have a huge focus on broadband, but we do a lot of other things as well that are non broadband. And so basically, we got the first cooperative agreement in the nation from USDA to run broadband technical assistance. The BTA program is actually the competitive one is actually based off of our pilot work in Oregon. And the goals are kind of like, there one is to provide like pre screening training and making sure people are ready to apply for grants and loans, right so internet service providers, whether that's a jurisdiction or an ISP or a triad, and to subsidize the cost of the technical assistance needed to do those applications, because we know It can cost anywhere from 50 to $90,000 to do these things. And so our goal is to help actors in rural communities secure that funding and subsidize that cost. And then another component of this is actually providing training to communities so that your elected officials and other stakeholders have the knowledge that they need to help support and move these issues forward, and so we've leveraged half a million dollar grant in Oregon and secured $30 million in funding for folks to the Oregon pilot. So the The Arizona pilot is based on our learnings and our model from Oregon, and we are super excited, and hopefully we'll be able to move forward with supporting around bead. But what like I think David is just waiting on the final paperwork.
So and Rachel and David, I will actually talk to you. Maybe we need to actually accelerate having you guys do a more detail if you think you need it, maybe as soon as next week, just because of. All the changes now that are happening, B the timelines and so forth. So let's talk offline. I don't want to take time this morning, but thank you guys for being here.
Yeah, real quick, Steve, the the grants that are in jeopardy, the BTA grant, has not been mentioned at all as far as removing funding or whatnot. So we're here to help. So far so good. I think that was one of your main questions there is, how does that affect the grant funding? So it is in force and ready to start helping soon as next
week, and that was a USDA grant, if I remember correctly, that's correct,
you bet. So let's move on. Kelly, you want to give us a quickie update. Obviously, we're going to go into a lot of detail about the recent changes to bead. But can you give us a quickie update on where the broadband office is today? Yes,
of course. Good morning. My name is Kelly cruci Community Engagement Manager for the state broadband office, and I do want to say thank you for sharing about the broadband Technical Assistance Grant. That's great information. We did have a tribe ask us if we had heard anything about that, maybe, like a month ago. So anyway, this is great. Looking forward to connecting on that. Okay, so yes, big, big things are happening, and we sent out an email notification on trying to think of what day it was. It's been a crazy week. So on Tuesday of this week, an email notice went out. I'm going to leave with the email notice, because I, as I am saying in every meeting, if you did not get that notice from the Arizona Commerce Authority, and you would like to please put your email in the chat. I'll pick it up. I will add it really trying to make sure that we're capturing everyone in our communication. So this email went out on Tuesday, and at this point in time, the steps that we are taking, there are a few. The first is that our round two application window, which opened on June 3, just
nine days ago, is suspended. So that application window is suspended. While we are determining what our next steps are, we are also looking at round one. You know? What happens with that? Nick our director, has spent the past few days at a conference learning more information about this and having conversations with people in DC, which is great asking some specific questions. So we're excited to have a webinar tomorrow, and I'll put that link in the chat after I'm done speaking. And this webinar will kind of go over, you know what the changes are, where things are, and you know what are the direction of where we're going, and answer any questions, and I will just say what every state broadband office is saying at this point in time, which is it's a lot of change in a short amount of time. We are all trying to wrap our heads around this and determine the next steps we want to do the best thing for our state, for the tribes, for the counties, for the people in Arizona, the goal remains the same, of 100% connectivity. How we're doing that definitely has changed. So the game has changed completely, and we are trying to quickly respond and be as proactive as we can, while being reactive, but not losing sight of that ultimate goal. And we definitely need the help of the applicants in this, and we don't want folks to lose interest. The intent is the same, and we need the support and the partnership of everybody in this. Don't want to lose those round one applicants. So again, assessing where we are. Join us tomorrow. It will be a good conversation. We will try to get those questions answered, but we also need to know, you know what your questions are, what your thoughts are, and get that input from you as we all work through this and determine the best way to do this. There's 90 days we are to do this, and we are if we're counting down on day 85 so it's happening fast, and we want to be fast, but we want to be smart and strategic in this, and need your input to do that. So tomorrow is the webinar. We'll have some good conversations and share what we've got at that point. And like I said, things will be moving fast. So my ask of this group is, if you didn't get that email, please let me know, put your email in the chat. I will get you added to our contact list, and then I'll put that link in the chat if Erin didn't beat me to it. Thank you, Erin, for tomorrow's webinar, and I'll also get you know whoever attends tomorrow's webinar will be added to our contact list as well.
Thanks, Kelly. Any quick questions for Kelly? So just a reminder can. She mentioned the chat several times, that you can download the chat to your computer at the end of the meeting if you want to there, if you go to chat at the very top, there's three ellipses, three dots, and if you click on that, you can download the chat, and so it'll have all the links and contacts and all of that sort of stuff in the chat, because it's hard to remember everybody. Catch up. Cap, capture all that information. I will try to get that information out. However, I am having major computer problems at the moment, so I'm having a lot of challenges and being able to deal with stuff. But anyway, thank you, Kelly. I appreciate it. So moving on. We're going to do away with a lot of our other updates this morning, because we do have a lot to cover. So we're, I'm pleased to have a panel discussion on the impact of the Commerce Department's new NOFO and bead restructuring policy notice, as Kelly reference. So we're pleased to have Randy and Randy leaning got it right this time, right. Randy, Randy, who is the founder of broadband toolkit, Randy, has been attending pretty regularly our meetings and appreciate his his participation this morning. And then we have Reed Sharkey, who is back again with us, who is the community broadband, the community broadband specialist and research associate at the Benton Institute for broadband and society. And Reid is, you know, obviously following closely on what's happening with bead. And then Mark Goldstein, who's President of International Research Center and chair of the Arizona Telecommunications and Information Council, Mark did an excellent job yesterday at the at IC board meeting in talking about what was happening, and we could have gone on for a lot longer. So this is the time for us to really try and get into some details about what's happening, and, excuse me, where we're going and what the implications are as we know it, as of today or yesterday, as the case might be. So we're going to just jump right into that panel discussion. Any questions or comments before we do that. Okay, so I want to highlight spotlight and where is Randy? Where are you? There's Randy and spotlight and Mark. Hopefully I can add another. There we go. Okay, so here's our panel this morning, and I want to kick it off this morning with Randy, kind of giving us a quick start on where we are, what's going on, what the implications are for this, for all these changes. And to kind of put some things in perspective, there's lots of issues, lots of implications, and so between Randy mark and Reid that hopefully we can give you as much information as we can today and what we know today. You know, this is kind of as you know, we've done a series what we know, what we think we know, what we don't know, and now it's what we know and wish we didn't. And so with that, I'm going to just turn it over to Randy. Randy, did you want to
share? Yeah, I did. No, thank you. Thank you so much, Steve, and
let's see. And I just what I've done
is and this can be flexed and adapted, but what I did is I put together a short series of slides, sort of highlighting the, you know, what to me were the most captivating elements of each section, and talking a bit about the organization. And we could go through all of that, or part of that, but it's designed to be sort of a machine gun introduction to, you know, to what, what is, you know, what jumps out, at least to me, and I think everyone who reads it will will have slightly different takeaways,
Randy, if I can interrupt for one second, yes. So all these guys have very impressive credentials, but just because of time, I'm not going to go into all their background, because it would take up half the meeting being able to do that. So I just wanted to just say that, that it's not that I don't recognize all these guys that just want to, don't want to take the time. So anyway, go on, Randy,
okay, and maybe if I do say five, five minutes of just machine gun and then, and then we can. You can pull back and digest it. So basically, I was going to try to step through just the a little bit about the the organization, you know, what was released in the organization, some of the highlights by section. And then after that, I have some broad sort of integration questions which we could either get to or not, but they're, you know, they're sort of conceptually, put those towards, towards the end, when we, you know, after we've had other discussion. So, so basically, you can tell a lot just from the, you know, the pagination here, basically the the, what's called the NTIA bead restructuring policy notice, which came out last Friday, has a press release, and then a fact sheet, and then, you know, this document is about 23 pages long, and the, you know, the background and purpose is Just very short. There's several pages on elimination of regulation, regulatory barriers, or that's the way it's called, and they're each treating a specific policy and clawing it back. To some extent, a large portion of the document is related to technology, technologies, technology neutrality, some, some sort of presents a conceptual piece and and other sections talk about the implications for broadband offices and so, so we can kind of step through that, that a little bit. So these are the, these are the things that are are regulatory requirements that are changed. And I won't go through them in a lot of detail, but they basically take each area where I think the the new administration is looking back at, you know, the the original NOFO and saying, you know this, you know, expressing the belief that this overstepped regulations or should be clawed back in some fashion. So in each of these areas, you see that happening. And just as an example, in, you know, for instance, with the middle class affordability plan, which is part of the NOFO that's gone things like the low cost service option, you know, is, you know, they, they, they're asking entity to be, to be kind of less specific in terms of pricing and and, for instance, the eligibility is, is shrunken from one that was tied to the affordable connectivity plan to one that's tied to lifeline, which is a has A smaller eligibility window. So these, so I won't go into a lot of detail because but, but we could come back to these, if desired. One of the very interesting pieces is those of you who were intimately familiar with the original NOFO probably remember the concept of a priority broadband project, which in that context, was defined as fiber. So it was 100% fiber. And so every state broadband office, you know, sort of went by and large, went through a process of doing, kind of a fiber bidding cycle, and then things that fell out, you know, subsequent, you know, cycles as part of the broadband the sub grantee selection process. So here they are redefining it. And there's this statement says nothing about fiber. It has the download speed, upload speed, latency, and then it has some text, which is, is potentially consequential, talking about it, can easily scale speeds over time to meet the evolve, evolving connectivity needs of households, households and businesses and again, you know, a household may be fine with 100 down. If you're a hospital with, you know, doing MRIs every day. You know, not, not you know. And then and support the development of 5g so, so, so the idea that the investment now supports other infrastructures, and we'll come, come back to this in a moment there. And then I'm sort of going largely serially through this. And again, it's 23 pages. So just grabbing a few things that are highlights. There's a statement up front here where it says eligible entities may not categorically exclude any given technology. So suddenly a very broad tent in terms of technology. But then it goes on and and talks about, you know, the, you know some some of the caveats there. And the NTIA reserves the right to reverse an eligible entity's determination that a project does or does not meet the standard, you know, for a priority broadband project, if such determination is unreasonable. So what's interesting is this is actually. A two sided sword. So if you said we're going to include all of these, you know, flavors of technology and, you know, and you included people that were not credible, you know, the NTIA could reverse that. On the other hand, if you were, you know, prescriptive and excluded people that they felt should be included. They could, could reverse that too, but it's a so and then. And then, what else is, is interesting is it also goes on to describe the concept of a non priority broadband project. And this is also interesting because, you know, we've already said that, in theory, all technologies are are welcome but, but there are projects that sort of fail to meet this priority definition, and they're called non priority. Okay, so that's that's interesting. It goes on and talks about the extremely high cost per location threshold, which was part of a critical part of the original NOFO. And the idea is you would deploy fiber up until you hit the dollar threshold there, and then you do other technologies. And then also there's the idea that you know that award stop if a if a project cost is excessive. And within the text of the NOFO they actually cite, you know, Nevada was one of the three that had completed, you know, their sub grantee selection. And they, you know, indicated, you know, an extremely high cost threshold of of 200,000 and so, so they actually call that out as as excessive So, but, but again, that's something that is, is just sort of a judgment call. What technologies are available. You have a fiber cable, Leo, satellite license or unlicensed spectrum or hybrid. And this replaces what was previous, previously a tier, a tiered structure of of fiber, and then other, other, quote, unquote, reliable technologies, and then alternative, so, so this is a some conceptual changes, and this I sort of pulled up in terms of sequence. There's a lot, there's a discussion in appendix, a of unlicensed and basically, even though the technology is allowed, there are certain hurdles that people need to go through if that's if they're doing that, and certain demonstrations they need to make. There's Similarly, similarly a section on Leo satellite rules. And one of the interesting pieces is they talk about low Earth, you know, satellite in terms of capacity sub grants, and, you know, part of the concept is, if you're deploying infrastructure, whether it's fiber or or or wireless, you know, the government can have an interest in that physical hardware that they've deployed with satellite, that's not possible. And so what they do is they, they have a, what they call reserved capacity and a 10 year period of performance. They require them to advertise. Adoption is sort of tied into to the methodology, how they're they're compensated, they need to activate in 10 days, like other technologies, and they're required to pay for the installation of the CPE and for the CPE itself, which which? You know, if you're a fiber provider or any other provider, you often do that, but it's not required.
And then one point about satellite. Yeah, it said they would have the same four years, up to four years that other physical infrastructure builders were to reach the capacities needed. They don't need those capacities going in to apply, but like any other applicant, would have up to a full four years. Now, they may choose to commit to shorter time frames. There may be a benefit as a secondary priority. If they do
No, that's a great, great point. And even, like Kiper has, you know, with Nevada, they committed to an in service date of of December, 31 2026, I think so. But, but that, but, you know, there will definitely be new, new and it's very important, new entrance there,
Randy, if I can interrupt, if I can interrupt one second, so mark and Reid, certainly feel free if you need to embellish upon something. But you know, again, I want this to be as interactive as possible. So,
you know, sure, I assume we'll go round robin a little more. But just while he was on satellite, I thought, no,
no, it's fine, Mark. I'm just saying that if you find a place where we need to embellish on something, please do. I don't want us to Okay.
I'm not sure,
okay, and I can. The other thing too is we can. And, you know, we could go, go back, or whatever. So I know there's for everything that I'm saying, there's probably 10 times as much content. So, so I was just trying to, just to blast through this. The other other thing is very consequential, is there's a, you know, what they call the benefit of the bargain round. So they're basically, even though a lot of states have done or either started or completed sub grantee selection, basically they're asking for the process to be to be restarted and and you can take all of your pre qualified applicants and keep them, you know, in the qualification list, but but there, the door needs to be open to new applicants. And there's also a requirement to put together, essentially a revised map. So there are whole bunch of things that need to happen. And what's very consequential here is that there's a 90 day window for, you know, for a state to do this, you know, which is extremely compressed given the year so that that they've had previously. And and there are two, two things that are, are, are related to this. This sort of jump out to me. One is they ask that the the cost for the programs or for the requirements that they disallowed, are essentially pulled out, so they're not going to, let's say, fund someone to do something that was environmental, which there, which was they're now saying is not required, or just, or, you know, felt in one of the other categories. The other thing that's this potentially very consequential is that applicants have the the right to exclude specific broadband serviceable locations if they feel the cost is excessive. So just as a fabric of how do you go in? And you may make decisions this, this, you have priority, and then non priority, and then these excluded bsls,
can I note something there? Randy, yeah, you bet those unallowable costs, you mentioned the applicants that are pre qualified, and then if they submitted an application in an early round, like some states have already run, including Arizona, they somewhere in the notice, they say that you could leave those applications and re adjudicate them under new rules. But because of these excluded costs, it seems to me very unlikely that any such application would succeed. So it's because of these, because you would have factored in these environmental costs that are now unallowable, which would just make the project really expensive under these new rules.
Yeah, and there are a lot of and then that's a great and what's interesting, there are a lot of conflicts, sort of soft conflicts, in terms of the objectives that are are described here. And then, you know, 10 days to deploy. That's pretty standard. The scoring rubric is a new concept which, which is discussed here, and basically it has an emphasis on on low cost, which, again, is juxtaposed against, you know, specific requirements. And also there's what they call secondary criteria, the idea that if, if something's within a 15% margin, you can consider things like speed to deployment, network capabilities, and also give deference to someone who has been an existing applicant. So so this is sort of giving some allowance to the fact that states have spent a year pouring their hearts into this and have a bunch of results, and people have pre qualified and so, so there's some some deference to that, and then just a tiny bit on the map. So basically, you know, if unlicensed are, are are suddenly allowed, you know, then that has implications for what you consider served and unserved and underserved. And also, you know, they they're asking people to go back and revisit enforceable commitments, and are those current? So there are several things that they're asking them to revisit in terms of the map and then to republish that. And again, the the timelines here are astounding, but 14 days, you know, from the you know, from from the public notice, this stuff needs to come out and and also some changes to anchor institutions, and then, and then, just, you know, very simple things that appear in there, non deployment funding is, is, you know, sort of on TBD, and they have a new process for permitting, which, yeah, I know, I think Mark you talked about this, or I think someone did. But anyway, that's a those are things designed to, to accelerate things. So anyway, let me, let me stop. And why don't we rewind to every. Areas of interest, but that was sort of an effort to just get through the overall package and identify what's what's there, if that makes sense, great.
Thank you. Yeah, well done. I guess I'd like to dig a little deeper on what Randy has mentioned about the state's BSL list. What will be the eligible locations for bead because there are two big changes now, the state work from the FCC data as massaged and transformed by cost quest to generate a baseline map, they went through an extensive challenge process, and that challenge process need not be repeated, and I don't expect anyone will given these time frames, but there are two big changes to that established baseline BSL list for the state. One is that I believe NTIA themselves will provide a list of formerly unavailable locations that had what's called an enforceable commitment, an ARD off grant assigned to it, or possibly some other grants that have failed. A lot of rdof has been given back. Lumen just gave back eight states, not Arizona, all of their ardf awards. I'm sure there are some in Arizona. So ardf failures and other grant failures will be identified as specific bsls that the state will have to incorporate, assuming there's no current map data that says that there is a eligible broadband of 100 slash 20 being delivered. But on the other side, the big change in making unlicensed wireless, formerly licensed wireless was an eligible technology, just not favored in the fiber heavy prioritization now that unlicensed wireless is allowed, there are probably 10s of 1000s of bsls in Arizona alone that are receiving or able to receive, I should say, 100 slash 20 service that have been declared under what on an FCC 477, report. I believe it's under code 70. Check Code 70. It's probably going to be the June 30, 2024, data they haven't processed the December 31 2024 data yet. So whatever that snapshot of declared coverage from unlicensed wireless providers from June 2024 that has to be looked at and the state has to basically post a notice that says, Here are all the unlicensed wireless points that we could add to the map unlicensed providers. Do you want them? Do you want to claim them? Basically, they'll have seven days to claim them, and then seven days to provide some detailed justification about the quality of their service, but when you look at how many BSL are, you can actually expect 10s of 1000s of them are likely to become come off the Arizona map. So I think that is an important change. We're going to see that I wanted to drill a little deeper on
and in addition, the list will change for many states on the their Cai list. And he in that note, they revert to the original definition of what can be called a community anchor institution, which is outlined in the original NOFO, but allowed states to expand on the CAI list if they wanted to be more inclusive and include other kinds of organizations. They've now said that that's not allowed. So states who had adopted a more expansive view of what acai can be
will now have community centers or senior facility
or a hunting lodge, right? They'll need to go back and remove them from the list. So all, and we've, we've talked about lots, lots of these things that are going to just create a burden for states. And I commend you all at the ACA for getting, you know, moving really quickly and getting communications out and scheduling ways to do outreach. But the timeline, the way I see it is, is just it's, it's an insane ask, because you're asking 30 days for a new initial proposal. You're going to have to redo your map. You're going to have to. To have a 30 day public comment period when you finish your sub grantee selection and all this while you're running your entire sub grantee selection process. So it's, we're, we're really, it's going to be interesting to see the different approaches that states take to try and meet the ask, I think, and maybe the kind of loosening of the requirements will allow for sub grantees to submit applications really quickly, because they will have to factor less in in terms of the labor requirements and the environmental requirements into their bids. But that's kind of one of the big takeaways for me, is this timeline is it's just, it's the math is not so simple to me
on the CAIS, though, and read you, you know, you raised the legitimate point about them going to be more strict in the definition of CIS. What I don't see in here is any mention of the gigabit per second service capabilities that I believe in were in NOFO one, and since there's no non deployment funding likely to be available when they finally define their tbbd, but I'm guessing that's the way they'll go. The states are likely to have a lot of leftover money that's subject to clawback or other processes, but they may have more flexibility in Cai investment, infrastructure investment at the back end based on the excess funding. And so I don't yet understand if that's going to play that way, but I have kind of it could well be that states then have a lot of money to look at Cai direct connections at the gigabit rate. I'm quite uncertain. I doubt ACA even has that answer yet, but if Kelly does, you know that, that would be great. I'm sure Nick and she are closer to NTIA direction, but there may be an upside on the CI equation from that?
Yeah, that's a great point. That is a great point.
I think Reid, you mentioned too some conflicts in objectives here, right? Like, I think you know there, that would probably be something for us to unpack when we look at the overall set of requirements are the things that sort of seem to stand in opposition to one another.
Yeah. And then Randy touched on the affordability, but I think we should go just a little deeper on that. There's no longer a middle class affordability. It wasn't in statute, and this, NTIA has eliminated that on the low cost option for community consumers. They have changed from allowing the states to have some or a good bit of leverage in trying to enforce and get a low price or the low cost plan to saying hands off, neither explicitly or implicitly can the state influence or demand or request specific rate points, and it's totally up to the provider. So a terrestrial provider that's wireless could come in and say, Well, I have a $30 plan. A satellite provider could say, my normal plans, 125, low cost is $90 and there's no scoring benefit, even either in the primary or secondary criteria that says that any affordability that's better than another project can be considered in the scoring. So there's really a, you know, a torpedo in the whole idea of affordability and having any policy influence to totally leaving it at the applicant's discretion what a low cost plan would consist of. Yeah,
that's a very good point to bring up. And I would even maybe go further. The way I read it is, if the satellite providers regular Plan option is $120 that that's the low cost plan option. I don't, I don't want any way that they couldn't just specify whatever happens to their be their bonus cost plan at, 120 megabits per second. That's that qualifies, that meets the statutory requirement. So affordability took a big hit on this, on this policy notice, I think you're right to bring that up. I if there are any questions or want to dig deeper on. Satellite that's kind of in the what we know about, kind of the way that satellite providers have been applying in the bead program, to the extent that we know, and previous programs, like the main program i That's one focus I've had over the past couple days, is trying to now understand, because of this one sole focus on on cost, it seems there is, if satellite wants to serve a group of vocations, they're going to be able to win in most cases, maybe in some areas where, You know, for example, Starlink in the Pacific Northwest, where they have limited capacity, maybe they struggle to reserve capacity there at an affordable level to them, and maybe a different maybe a terrestrial provider can win out. We don't know, but from what we can tell, the there's a pretty large variance in cost per location and applications that Leo providers have made Kuiper and Starlink kind of ranging between an ARD off Starlink was around just over 1500 I think, per location. Yeah, 16, 1600 per location. But then in other areas, are over $5,000 Kuiper is has been between $3,000 and then in Louisiana, their alternative technology proposal and bead was $10,000 per location. So there's this really large range of of cost per location on satellite applications, and that could be due to a number of things. I think we're still learning exactly what they're factoring in, and now we know a little bit more because of this policy notice of what exactly they're going to have to pay for in terms of the CPE and what they can what they're going to be responsible for over the period of performance. But it still seems to me that in almost all cases, Leo providers should they want a group of locations will be able to get them under these new rules.
I'd like to push back on that just a bit. So one, I think their pricing was based on competing head to head with fiber only. Now they're going to have to compete with terrestrial wireless, even with cable systems and hybrid have hybrid fiber coax systems and and so on. And I somewhat disagree about the that there could be the lowest cost option anywhere, anywhere that unlicensed or licensed or hybrid wireless providers already have some vertical assets in place. Their cost to deployment per customer can be very aggressive, and they in my mind, well, there's two things. One is, what is the capacity and interest of a satellite company going after 56 states and territories. You know, what is their capacity to do that? What is their interest to do that in these short time frames? Where do they want to play? What is their business model going to drive? Right? They they may go after 10% of the bead bsls. They may go after 80% of the BB SLS, big bugaboo and unknown about their strategic positioning, but on the ground, on a head to head cost basis, I think terrestrial wireless providers, in many cases, can be competitive, and it's going to be a pricing War, a reverse auction, almost between those two entities. But the net result, in my mind, is an initial estimate of 80 plus percent being fiber deployment, now being 80 plus percent non fiber deployment. I don't know if the two of you agree on that flip flop in the 8020
I can definitely and, yeah, too strong saying any location they want, the remote locations, I think, is would be a more sensible way of saying that, right. Yeah, I agree. If,
if I could jump in Gordon fuller in Tucson, astronomy, Space Science, capital here of the world. The solar threat to satellites is so huge, it's so ridiculous. The idea of using this as our primary central infrastructure is a single point of failure, which is just so unacceptable. If you look at recent discoveries by the Max Planck Institute, who run the big solar telescope up on. Kid peak, they discovered, after looking at 56,000 suns like our own, that these things erupt with super flares every 100 years. Not every 10,000 is what the satellite industry spent on. And so it's it's the worst possible idea. Doesn't give us any infrastructure that we can count on as far as the future. And I'll put an article in the chat for about this
great point, and
I'll weigh in just very briefly too, is we put out a white paper on satellites a few weeks ago. And one of the things is it's very tempting to look at the dollar figures and say, Oh, satellite is better here, or will dominate. But the problem is, where satellite shines is in areas that are extremely sparse. It's the most rural areas in Arizona and Nevada. You know, that's where it's a phenomenal solution. As you get into more denser areas, a satellite system, you know, essentially has a certain capacity per unit area. And so, you know, so to be cost effective, it serves very remote areas in the US and then similarly, in Sub Saharan Africa and Asia and, you know, and it's literally just visible for a few minutes. The other thing with interesting with satellite is, is, you know, with infrastructure on the ground, basically you have a capital cost. You know what that is, and so the reimbursement, reimbursement mechanism is very straightforward. With satellite, you got, you know, many, many billions of dollars of investment that those assets are made before the first customer goes live. And so it's almost like a fiber provider or wireless provider that already covers everyone that could be covered. And so there's a philosophical question of, why are you funding satellite providers, and what's the basis for giving them extra money. But also it's something where, if you didn't have them, and you needed to put fiber into the most rural areas, then you're into the $100,000 or $200,000 per location. And so that's sort of the balance. So I think, you know, it's a, you know, sort of looking at it just in dollars and cents. Is there a lot of other factors that need to be considered in that balance. Reid, maybe
you would have some insight on this. To me, it seems like in the old model, the last mile costs and the middle mile costs were really separate. Your high cost threshold was for last mile connections and your middle mile costs had kind of a weird capping formula, but it wasn't when we talked about when we talked about a per location fiber cost, and now they seem to have bundled those costs together into a bucket that then divides by the Number of bsls, and thus, if you were bidding, you know, as fiber 5000 of BSL, but you might have had another 2000 or 5000 in middle mile cost. That same proposal is going to show as a seven to $10,000 per BSL cost, not a $5,000 one is, is that? How you would read that?
I think that's, I haven't thought specifically very deeply about that that, but it makes sense to me. And then you factor in the middle mile program that ran a few years ago, right? Those investments were made with bead in mind. You know, we built this fiber backbone, and now we're going to have to have this asset to use to expand fiber to even more places, whether it be directly to locations or to be the backbone for fixed wireless networks or 5g or whatnot.
So I think this is a big pricing change for fiber projects on the per location math has changed for me reading this new guidance.
Yeah, and I want to highlight you brought up we brought up ARD off a few moments ago, and the design and art off of a reverse auction. I think it would be remiss to not identify that's what led it to be a failure of a program. The
lowest cost, lowest cost, yeah, drive to the lowest cost has led us to the yard off failures we're
seeing, and that's what we're that's what we're looking at now. Part of the
yard off failure was the fact that they required yard off providers to provide phone service, and a lot of the companies that were actually already covering those areas did not have that phone service in place two years ago, which is what, which, which eliminated a lot of companies, and then from being able to bid
good point back to Gordon Fuller and satellites vulnerability. To certain sky events, be they solar flares or or unfriendly nations interfering with satellite capability and space debris and all those other factors. Those space debris is not going to take out enough satellites, necessarily, but an unfavored actor you know could damage satellite capabilities. More broadly, there is in for the priority projects. The low cost scoring doesn't allow for any other consideration other than low cost. But when you have at least one proposal within 15% of the lowest in the secondary criteria, there's a time to market consideration which satellites can excel at though fixed wireless provider with infrastructure already in the area might also be quick to service, but There is also then the ability for states to weigh and score against the qualities of the technology, and so it's only when project areas fall into the secondary scoring criteria where the states now have new flexibility To figure out on their side that reliability and scalability of a fiber network can can play in the state scoring on a TBD basis.
Hey, I wonder. Hey, Steve. Just as a quick question, Should we are there maybe? Or should we ask? Are there any questions, or just whole topic areas that we've completely missed that just other folks in the audience are would like to have covered because that that would I know we're we're consuming our hour very quickly.
You beat me. You beat me to that Randy. I was going to just get to that. I have a couple of quick comments, and then want to open it up for any questions or comments that people have. We only have about 15 minutes left in our meeting today. Obviously you can see that it's a very complex kind of issue. So two things I want to remind people that the broadband office is having their webinar tomorrow, and would encourage you I assume they're going to be more focused on what's happening in Arizona and the broadband office and so forth. So I would really encourage you to attend that webinar. And secondly is what Randy was just saying. Are there any questions comments from the audience. I mean, we could probably go on, go on and on. As you can all see, this is really a complex issue. It's not a just, oh, let's just make a few changes here and we'll go on our merry way. And of course, the biggest issue is the time frame that has been placed on the broadband office to be able to come up with a whole new plan. But anyway, I want to open it now to any questions or comments that people might have.
I have some questions. One is the whole area of unlicensed fixed wireless. What are the drawbacks of allowing those solutions? Because it seems to me, when you have an unlicensed fixed wireless solution, it doesn't guarantee that you can provide reliable service in the future. If so Randy,
why don't you bring up that slide would add the criteria that it they are requiring that they have multi path and interference and other and a minimum of five megabit per second, dedicated per customer, scalable and other factors like that. Randy, why don't you go through that in response? Okay,
and I see Rory is on the call too, and he actually had some some what's happening here. Let's see some great thoughts on that specifically as well. Let me just, let me just pull off the here it is, okay,
and Henry, I'll tell you that that's what you just stated is unequivocally false. It's easy to engineer that in unlicensed.
No, I'm not talking about engineering. I'm talking about the fact that if you're unlicensed anyone, they could make that that spectrum available for auction in the future, for example, and then if some carrier buys that spectrum, then your service is no longer valid. I
doubt that's going to happen. Henry, not the not the Wi Fi frequencies you're now. You're talking about battling every white, everybody in the in the world who uses it. And that's not, that's not realistic. And in fact, there's actually a push now to add seven gigahertz into that spectrum too, because they found that the economic benefit to the US is in the bill in the 100 billion dollar plus range. For Wi Fi, because they have opened up so many new companies and our opportunities. So they're not going to give away the existing Wi Fi frequencies, whether they add more or not. Is, is that's going to be a political battle,
right? But there is
licensing. The reason it's unlicensed is because it's cheap and because you don't have to pay for a license. But if, if someone wants that spectrum, and they request an auction be put on it to buy it, then your unlicensed coverage is no longer, you know, valid, they
can't just request, you know, yeah, it's, it's way that doesn't happen that way. Henry
A T and T is trying to do that right now with CBRs, and it's an absolute war. There's just too much money against making existing changes. Wi Fi itself is never going away, because that's a worldwide that spectrum is worldwide. Nobody's going to request it and take it away from, you know, the existing, you know, in the 2.456 gigahertz. That's pretty safe, you know, at this point.
And Rory say, say something about Baba and and just the equipment availability, and the other stuff that you've mentioned that sort of is outside of the the text, but is actually a big issue here.
So
the what they've listed, I'll start with the baba requirement, build America. Buy America. Build America. There is zero wireless equipment built in America right now in any of any product line that we use. It's built in Mexico, Lithuania, Manila, so forth, and obviously China. So I know some of the US vendors where, even though their home offices and their core engineering is here in the US, the manufacturing is out of the country, I don't know how many of them are going to be able to get exceptions to this, to the rule. The second part of that, I originally read the mitigating potential interference as being a requirement, and now I'm starting to think it's just a suggestion, in which case it won't affect it, it won't affect what we do. Everything we have covers most of that. Most of those issues are or we have ones that are not even in here, and some techniques that are better than what they're suggesting. The real question is whether or not the build America, Buy America, is going to be the stopping point of that. If that is the case, where, literally, there will be no unlicensed vendors able to bid on this project, I will tell you I'm working with three of them now trying to, you know, trying to find out where they stand on this.
I think, sorry, this thing needs to be debated. Because, I mean, this is this, this whole area is, is very nebulous, in my opinion, about what Henry,
can I stop you one second? Do you understand that we're also using 60 gigahertz spectrum, and that's not going to be ever covered by by license. I mean, there's, there's multiple frequencies involved in
here. There's shortage of spectrum in the United States, so I don't know. No thing is correct.
No, yeah, this, this isn't the, this isn't the hill you want to, you want to battle on. There's other ones that are more important in this particular
situation. That's one aspect of it. Then the other aspect of it is, you're saying in seven days, these service providers have to claim these locations are being served by unlicensed wireless. And then is it seven days the state has to present
sufficient evidence. Yes,
we already have that in our B filings, every six months. We used to be every quarter. Now it's every six months. All of that is already on file with federal government. There's nothing new that we have to do, Henry, except and it won't cover. We just won't be able to put new areas in like Mark pointed out from last that they're using data from last year, so it's already on file. There's nothing special we have to do for that.
So just a second, Randy, can you stop sharing? I want to go, Oh, you bet. Yeah, you bet to be able to share with everybody.
What is the extra seven days for? What is the state going to do in the seven days after the unlicensed wireless providers? There'll
be a seven day window for wireless providers to to respond and and attempt to claim their BSL service locations, to take them out of the bead eligible map. And then, having done that, they'll have seven days to provide quote, unquote air quotes, notice evidence that they do serve those locations adequately. And then
has to evaluate all that right to determine they largely already have.
They. These are customer areas they're serving. They have propagation maps. They're going to have to write a couple of page narrative about why they meet those few technical proposals with the equipment they have. They're probably going to have to package up their existing propagation maps. They may have ukla or other speed testing from real customers in those areas, right? These are areas they're serving. They'll have the data already. And if they're smart, they'll have, you know, worked on packaging it in advance, not waiting for that seven day window. Yeah, but
doesn't the state have to confirm that all this evidence is correct?
Sure? But well, these are declared on the FCC map. The state had no input on the original FCC map other than the challenge process. There will not be another challenge process. So if it's on the FCC map, declared and registered there, you're right, the state will have to review the evidence provided. Could object to it, but likely, not likely to so
then they'll have to redefine all their project areas, won't they, based on
No, they'll just have to, they'll have to have different numbers of bsls added ones from art off and other failures will will come into the map and claimed unlicensed wireless locations will come out of the map. But I imagine the project areas will remain the 67 in Arizona, identical,
one, one interesting piece that I think the broadband offices will need to think about is, is a particular applicant can look at one of these project areas and say, I'll take all of these urban pieces, but I'm going to decline to cover these other 10 areas that would have cost a ton of money. So that's that's something that I know, you know, in a lot of states have have carved out project areas that have a mixture of urban and and remote, you know, with the idea of getting everything covered with fiber. So that philosophy of how you approach the mapping process is suddenly under, under fire a little bit, right?
There's no, there's no guidance here, other than low cost. About, you know, if someone claims an urban area at a lower cost and not the surrounding areas, but then someone claims them all at a higher cost, what is the process of of differentiating and discerning and deciding between two proposals like that great point Randy, I think
they haven't even, they haven't even said that you have to serve the whole project area. They said you can exclude location.
They've relaxed those rules, right, right? So
there aren't project areas are, are not really very relevant, because you don't have to serve the whole project area. You only have to serve certain locations that you decide you want to serve. So how are they going to assign who wins a project
area? Well, I believe the state is going to have to propose their processes and their decision matrix and how they're going to evaluate and compare projects like that as part of their response to this guidance. To do that,
I need to interrupt because we I need to know if there's any other questions or comments. Sure, Henry, I know you've got a lot of good questions, but we also need to, we've only got about four minutes left in this meeting, and so I need to see if there's any other questions or comments from others,
I take that to not be the case.
Okay? Henry, more questions, no.
I mean, I have, like I said, I think there's a lot of questions about what these project areas really what these project areas really mean? Or, you know, because they're not they're not required to be served. There's a lot of questions about how you identify unlicensed fixed wireless issues that are not being addressed discussed properly, in my opinion, because, you know, there's a lot of concern about the reliability of this in the future, and what the spectrum allocation issues are. There's, there are whole issues about whether this, this whole process, is going to be litigated, because is well,
point will have some waiver capabilities within the process. What the litigation? That's a great point, Henry, is that we're bound to see litigation relative to. This?
Yeah, so, I mean, it's a very confused situation, in my opinion, all these states whether they want to go ahead with this rushed, 90 day process where they don't know answers to these questions and or whether they want to have this litigated before they go ahead with a new process. You know, because there's a lot of it seems to me, it's being rushed, like Reed is saying, with all sorts of uncertainties, and
we're all nodding our heads, Henry, we don't have the clear answers. The states don't have the clear answers. It's going to be sausage making, you know, and we're going to watch it. We're going to watch it roll out the next 90 days. And I absolutely, I
think one last piece on the timeline is it's not only going to be it's not only difficult for states that 90 day period, but NTIA has given themselves 90 days to adjudicate it all so that, and that hasn't been the case in, you know, prior approval processes for the initial proposals or the final proposals. It's taken much longer than 90 days. So it's there's uncertainty, both at the state and federal level for this.
So can I? Can I interrupt because we're almost out of time? Frank Martinez, I know you're online. You have anything regard to what you're seeing, regard to the tribes at this point in time.
Are you talking about for
bead specifically, yep, yep, for what's happening right now?
I think Oksana might be on the I was she on the call
earlier. She was, I don't think she's still here.
Yeah, I don't have anything recent or current to add to what's already been published. She would try to be the best person for Arizona that I would point to.
Okay, thank you. I'm sorry. Okay, so any other questions comments before we end for today? So again,
one, one thing, Steve, I do want to go back to the environmental that Randy raised. They are offering an unprecedented and Reed's point about their responsiveness. They are saying that with their new mapping tool and data sets, they expect to be able to clear 90% of the bead projects for environmental in two weeks. This is unprecedented and and a little unbelievable. I mean, it would be welcomed by the provider community. It may not be welcomed by some environmental, you know, advocates, but that also is a unprecedented sea change in how environmental may, you know may work, versus historically.
So. Couple couple of quick things again tomorrow. I assume Nick is going to be on that call tomorrow and talking about Arizona, and we'll kind of see where things are, and I'll talk with Nick, and maybe we'll see if we can get him also as early as next week. It's just everything is is is time critical at this point in time, so I'll see if, if he might be available next week, because it's important to know what the state's plan is at this point in time. Any other closing comments before we move on?
Really appreciate the discussion today. Learned a lot. Sorry.
Well, if Well, thank you. Randy, Reid and Mark, you guys did a great job today. It was a great, great panel. So you guys were awesome. Thanks. Thank you. You.
