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Overbuilding Concerns

WISPA Chief Sees Challenges and Benefits From BEAD Program

David Zumwalt, who became president of the Wireless ISP Association in June 2022, told us during an exclusive Communications Daily Q&A that the NTIA’s broadband, equity, access and deployment program shouldn’t be used to inject artificial competition into markets that WISPA members already serve. WISPA has fought to have BEAD fund projects that rely partly on using unlicensed spectrum (see 2302090063).

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Zumwalt came to WISPA from industry and was most recently chief operating officer at Broadband VI, an ISP in the U.S. Virgin Islands. The following interview was edited for length and clarity.

What is the biggest problem WISPs see when competing against other providers? Are most WISPs satisfied with the state of competition?

Most WISPs are actually deploying a variety of technologies. I'm certainly of a mind to think that WISPA members and the WISPA community probably have as much or more fiber deployed in the digital divide than any other association at this point. WISPs have grown their businesses on the backs of their own capital capabilities. They've been serving their communities for a while.

Until COVID-19, internet service was welcomed in these rural communities because the larger providers weren't active there. The WISPs got started serving communities that way. They've been kind of the first responders in the sense that they're the ones who have been most active in deploying broadband capabilities. And now, post-COVID, we're seeing a lot of interest in coming in with subsidy programs to build additional capacity, or in some cases overbuild, what's already happened.

For the most part, [WISPs] are privately funded, active in their communities, and now they see federal programs, in particular, encouraging subsidized overbuilding in areas that they're already serving. So that's the competitive challenge that they have. Based on the way they have been performing in the communities they serve, they have very high acceptance rates … and so they're not concerned about being able to provide and continue to provide quality service. I think the question is, what is this going to do to have more competition, some of it subsidized?

WISPA recently held its annual conference. What was the mood?

From what I saw, the mood is great, it's upbeat. The challenges are certainly there related to the BEAD program. Certainly as long as I've been associated with the WISP industry, there have been existential challenges when it comes to providing broadband services in these markets, because there has always been competition. So I think that the mood was what can we learn about what's happening now with BEAD rollout [and] with the things that have been coming forward with the BDC [broadband data collection] program at the FCC? How do we make sure that we're pivoting to be able to not only continue to compete but to outcompete other providers that may be entering our markets?

Have you seen other changes in the WISP market during the past couple of years?

As a result of this shift during COVID, from being a nice-to-have service to now being a national priority -- and that happened in a very short period of time -- WISPs are now looking at what kinds of expectations are we going need to be able to meet next year or a year from now, and what does the landscape look like given that there’s so much private equity that is now in this space, recognizing that there are opportunities for consolidation or for acquisition. In some cases, we'll see our members acquiring other WISPs or other ISPs. In some cases, they'll be part of a consolidation, which we’ve seen in every other market segment. So that's not strange. That's just what's coming.

Embracing Fiber

To what extent are WISPAs looking to become fiber players?

Last count, about 30% to 40% of our members have major deployments of fiber already in their network. So they are not new to fiber at all. If you look at our shows, look at the exhibitors of our shows, you'll see a blend of technologies. And the mindset is we're using the right tool for the right job. As someone with network design background, I think that that's exactly the right play. If you're deploying a network with your own capital or with some subsidization, you're still looking for a way to make sure that you can provide the capacity that's demanded, but at the best possible cost. It's a blend of technologies, and WISPA members are using it.

The availability of spectrum has always been a concern. How well positioned on spectrum are WISPs today?

It's a lot better with the opening of the 6 GHz band. That's 850 MHz of spectrum that's now available. And that's unlicensed, but our members are using a combination of licensed and unlicensed. When you go into the licensed regime, what WISPs are looking for, and what we advocate for, is making sure that the parceling out in a spectrum auction is done at a level where WISPs can compete, [that is in] as small a regional area as possible to allow them to be able to compete and serve, that helps the smaller operators.

The small to medium operators are the majority of the members of WISPA. But it's not just that: it's spectrum sharing that we're seeing in [the citizens broadband radio service band]. … CBRS is working really, really well. This is a little tangential to your question, but there was, over the last year, sort of an open debate about whether or not GAA [general authorized access], that aspect of CBRS, was going to be considered licensed spectrum or not for the purposes of BEAD. The FCC determined with our encouragement that, yes, it had to be treated as licensed because of the precedent that they had set. Only recently the NTIA came and said the same thing. …

Other than priority access licenses, the licensed tier of CBRS, what are the other bands where you’re seeing broad use by WISPs?

We're seeing interest in the 60 GHz band, but we're also following closely what the national spectrum strategy that was just announced will have to say about areas of interest for our members … The big picture is that, like everyone else using spectrum, we want more of it.

It sounds like relative to five years ago, WISPs are better positioned with spectrum, but how does that play versus the increasing data demands that they're seeing?

We look at data demands at the subscriber level. There was a report recently that underscores what we already know, for example, about telemedicine. Telemedicine applications are not as demanding as many others in the industry would suggest that they are. They're in line with what you would expect for gaming and for streaming. And so, 120 [Mbps] service at the residential level, and even in some commercial applications, is more than enough to be able to support heavy use of those sorts of applications and technologies.

In commercial settings, enterprise, academic, then obviously the capacity requirements are higher. But this is why you want to make sure that your middle-mile and backhaul services have the capacity to be able to feed those end-user paths, whether you're delivering it wirelessly or through a wired technology.

What do you see as sort of the evolving view of spectrum sharing, and how much is that going to be part of the equation for WISPs over the next 10 years?

There are a lot of voices in the room when it comes to spectrum sharing. For example, the Department of Defense has spectrum that may be available or is becoming available for certain sharing regimes, CBRS included. Most of the applications that WISPs care about are going to be lower power regimes. I was talking earlier about having smaller serving areas, smaller areas where this type of access is permitted. Those are the sorts of things that we're looking for in spectrum sharing, even if it's dynamically handled.

We're looking for better [spectrum access systems] or frequency coordination capabilities that can provide some assurance that the spectrum can be used for a longer period of time. Those are some of the concerns that we have from a spectrum sharing perspective. But I think it's important to remember that a few years ago, we really didn't have the ability to even imagine what a spectrum sharing regime would look like. We're not making more spectrum … so being able to use the spectrum that we have more effectively is going to be really, really important.

BEAD Participation

What's the outlook at this point for WISP participation in the BEAD program?

That's a really good question. The primary irritant for WISPs has been that unlicensed spectrum applications to last mile locations were not included in the fundable aspect of BEAD, except on a very low priority basis. So preference was given to fiber. The BEAD program basically is a fiber subsidy program. And when it's understood to be that, then everything else kind of makes sense. But what we've been able to do is look at the practicalities of rolling out BEAD subsidies across all 50 states.

There's plenty of room for unlicensed spectrum. There's plenty of room for licensed spectrum as well. As long as the implementation of BEAD is not used as a means of simply overbuilding an existing network. The WISP industry really got started in many places as a result of the cable operator, or whoever the broadband operator was at the time, having enough money to build out to a certain pole. And then not having a capital plan to take it further than that. And so, if you lived on the wrong side of that utility pole, then you couldn't get service.

WISPs came up as a result of that. Leaving subsidies aside for a minute, the folks within basically the capital investment side of those operators were always looking for how they were going to extend the edges of their networks. There would be a justification process. So, if it were all their money, then as they were getting a return on investment in their current plant, and they saw the community continue to grow, then they would go and continue to build out from the edges.

My concern is that BEAD is going to be used by operators to go build out from their edges in areas where there are already providers, primarily WISPs. The mission of BEAD very clearly states, serve the unserved. We've got to provide service to everyone. But the implementation might be, we're going to build out from the edges and then just have to explain that we didn't have enough money to go build out to the unserved after all.

In every case, you're going to want to be sensitive to how much it costs to deploy [broadband]. And that's what brings unlicensed spectrum back into the room. BEAD is a really important program, and our members know that it's important, and they want to see the implementation done in a way that is consistent with what the aspirations of the program were, what the legislative intent of the program was.