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������Ƶ’s Open Technology Institute (OTI) submitted in response to the National Telecommunications and Information Administration’s (NTIA) Public Notice inviting comment on proposed guidance to Eligible Entities “regarding the use of alternative technologies to serve unserved and underserved locations in their jurisdictions.” OTI strongly supports the NTIA’s goal of ensuring that in every state and territory (“eligible entity”), Broadband Equity, Access, and Deployment (BEAD) funding is implemented to achieve reliable, affordable, and high-speed internet coverage at every location that is today unserved or underserved, thereby promoting universal access to high-speed internet coverage.

Moreover, in many states, we believe it may be possible to achieve this goal and still have BEAD funding available to put toward the equally essential need for adoption assistance and other digital inclusion activities. It is also vitally important to extend high-speed broadband access to unserved households as quickly as possible—as the opportunity costs imposed on K-12 students stuck in the homework gap, and on adults denied access to online information and services, has a corrosive effect on social equity and productivity

Accordingly, we encourage the NTIA to amend its guidance on alternative broadband technologies to give states more flexibility in encouraging the early use of fixed wireless and Low Earth Orbit (LEO) satellite broadband to fill coverage gaps. In recognition of the difficult challenges, opportunity costs, and trade-offs involved, OTI suggests the following changes to the NTIA’s proposed alternative broadband technology guidance for states and other BEAD grantees:

• First, OTI agrees that locations with no offer of Reliable Broadband Service below the Extremely High Cost Per Location Threshold (EHCPLT), but which do have ready access to existing deployments of qualifying unlicensed fixed wireless (ULFW) broadband service, should be treated as “served.”
• Second, the NTIA should reconsider its proposal that states should only reimburse LEO satellite broadband subgrantees based on the number of households in the funded service area that actually subscribe to service during an extended deployment period.
• Finally, in areas where LEO satellite is employed, we believe LEO operators should be required to reserve capacity to meet the actual average household usage (either in that state or household) along with a factor that adjusts for future growth (which has been running at nearly 10 percent per year)

OTI commends the NTIA’s effort to craft Guidance that will help states and territories anticipate the inevitable need to fill coverage gaps in extremely high cost locations with alternative technologies, namely unlicensed fixed wireless and LEO satellite broadband service. We strongly agree that all providers must meet the minimum technical requirements for high-capacity broadband and offer these suggestions in the hope that the NTIA will find a balance that delivers this broadband service rapidly and in a cost-effective manner.