Understanding the New BEAD Map: Including Unlicensed Fixed Wireless and RDOF Defaults in BEAD Could Further Reduce Eligible Locations by ~13%
Key Takeaways
- Among its many changes, NTIA’s recent BEAD Restructuring Notice permits unlicensed fixed wireless (ULFW) to compete for BEAD grants. In addition, locations served by ULFW with adequate speed (and some additional technical requirements) are no longer eligible for BEAD funding.
- An ACLP analysis of data from 49 states (all but WV) and DC found that this change could reduce remaining eligible locations by as much as 15%. This varies greatly by state, with some seeing a potential 30% decrease, and others almost no effect.
- The ACLP also analyzed the potential impact of RDOF defaults, which, by itself, could boost eligible locations by about 3%.
- The combined potential effect of ULFW inclusion and RDOF defaults into new BEAD maps could result in a total increase in eligible locations of around 13%.
- These estimates involve several caveats, detailed in this post, and should be considered illustrative of potential impacts, and not exact figures.
- However, “final” post-Notice mapping updates in South Carolina and Nebraska suggest that expected reductions are real and may be even larger than estimated, thanks to FCC map updates and other compounding changes.
BEAD Restructuring Notice
Among the numerous modifications within NTIA’s recent BEAD Restructuring Notice is that “unlicensed fixed wireless providers (ULFW) providers are now permitted to compete for BEAD subgrants on a level playing field with all other applications.” The notice directs Eligible Entities (i.e., states) to “ensure that locations already served by an ULFW service that meets the technical specifications [detailed in the Notice] are not included in awards for BEAD deployment projects.” In other words, if ULFW meeting speed and technical requirements provides service at a location, it is not eligible for BEAD funding.
The technical specifications included in the Notice are intended to mitigate “concerns regarding the reliability of ULFW services.” Specifically, these involve providers presenting “sufficient evidence” regarding mitigation of interference with other spectrum users and of “sufficient capacity to meet the statutory speed requirement of 100 Mbps download and 20 Mbps upload.” Already, numerous states (at least 38 per ACLP tracking) have issued notices seeking input from ULFW providers about the robustness and reach of their offerings and whether there is sufficient data to warrant removing locations served by these entities from the BEAD map (two states – NE and VA – previously conducted a similar challenge process for ULFW and have indicated they will not issue notices reopening that process).
Findings
ULFW
Our analysis, combining data from state BEAD challenge processes and the FCC’s National Broadband Map, found that approximately 15% of remaining eligible locations would no longer be eligible for BEAD funding, should all existing ULFW connections meet NTIA’s technical specifications. The full, state-by-state results of this analysis are provided here. We caution that these are top-end estimates and assume that all ULFW connections in FCC data that report 100/20 Mbps or faster speeds would both (1) meet technical requirements and (2) be recognized by states as they work to incorporate them into their location lists. This also assumes that all ULFW providers respond to state notices seeking data.
The potential impact of the inclusion of ULFW varies drastically between states. In some states, like California, Colorado, Nebraska, and Wyoming, the reduction of eligible BSL could exceed 30%, while in others, like Connecticut, Maine, and New Jersey, the impact is nearly zero. Nationwide, this effect would compound upon what has already been a drastic decrease in eligible BSL since BEAD was first announced, and would further increase the amount of funding available for each remaining location in states where unlicensed fixed wireless has a notable presence (the ACLP will crunch these numbers in a separate post).
Indeed, if all locations served by ULFW meet the NTIA criteria and are removed from BEAD maps, the total number of eligible BSL across the country would drop by about 699,054 (this excludes any additional decreases in West Virginia, for which data was not available at the time of publication).
RDOF Defaults
In addition to analyzing the potential impact of ULFW inclusion, the ACLP also analyzed the latest data on defaults in the Rural Digital Opportunity Fund to determine how they might impact BEAD eligible locations. RDOF grants in a census block constitute an “enforceable commitment” and, ostensibly, mean that a location in that block is not eligible for BEAD.
Based on the ACLP’s analysis of RDOF default data, including RDOF defaulted locations that are not served with qualifying 100/20 Mbps service in BEAD would increase the number of eligible locations by 116,331, an increase of about 2.5%.
Combined Effects
When combining our estimates of ULFW inclusion and RDOF default locations, we estimate a decrease of about 595,367 locations, or 13%. RDOF somewhat counters the large potential decrease from ULFW inclusion, though some of those defaulted locations are themselves (potentially) excluded due to ULFW service (about 12,645 BSL).
How State Results Align with Estimates
As of this writing, at least two states have released data showing how ULFW (and other factors like RDOF defaults) have impacted location counts. In both states, we see an impact of ULFW and other factors even larger than the already significant effect estimated in our analysis.
South Carolina
South Carolina recently announced the availability of its “final” dataset of BSLs. Included within are 22,000 eligible locations, about 10,000 less than the 32,351 estimated by the ACLP. The final dataset uses the latest FCC data and “integrates results from the SC BSL Eligibility Cleanup program along with additional enforceable commitments that have been made over the last few months,” which are likely responsible for this even-larger-than-estimated decrease.
Nebraska
In Nebraska, a recent presentation from the Nebraska Broadband Office shows that changes to the state’s BEAD map result in about 15,000 eligible BSLs, about 4,000 less than the 19,165 estimated by the ACLP. Like in South Carolina, this larger-than-estimated decrease is likely driven in part by the additional impact of a newer FCC Fabric version compared to the post-challenge list utilized by the ACLP.
Takeaways
This analysis underscores once again just how different the broadband map looks now versus when BEAD was being devised by Congress and rolled out by the Biden NTIA. With significantly fewer locations to serve, most states, in theory, should have more than enough BEAD funding available to close remaining gaps in availability. As mentioned, in a separate post, the ACLP will offer estimates of just how much BEAD funding might remain after states achieve their deployment goals. These remaining locations will not be easy or cheap to serve, and the emphasis placed on “lowest bid wins” by the Trump NTIA in its recent Notice increases the chances that many of these locations will be served by LEO satellite or ULFW instead of more robust terrestrial networks.
Methodology
This analysis builds upon a dataset containing a list of remaining eligible Broadband Serviceable Locations (BSLs) generated as part of a previous ACLP analysis. This dataset contains BDC Fabric location IDs for all states except for West Virginia, which, at the time of this writing, did not have those location IDs available for download.
ULFW
These locations were merged with a dataset, obtained from the FCC’s National Broadband Map data download, which contained all locations where:
- Service was available via unlicensed fixed wireless (technology code 70),
- Service was advertised as offering 100Mbps or greater download speed, and
- Service was advertised as offering 20Mbps or greater upload speed.
Locations present in both datasets represent those which, contingent on meeting the technical specifications discussed above, would no longer be eligible for BEAD funding.
RDOF
Data on RDOF defaults is provided at the census block level, which is the minimum grantmaking geographical unit for the program. Utilizing the latest list of RDOF default census blocks from the FCC (as of 6/6/2025), we aggregated a list of all BSL in those defaulted census blocks which did not have 100/20 Mbps service from a qualifying technology as of the latest FCC National Broadband Map data.
These locations were then merged with data on post-challenge eligible locations. Any “new” locations, i.e., those not already present in the post-challenge data, are those which are potentially BEAD eligible following RDOF defaults.
Caveats
While our calculations are fundamentally a simple exercise, numerous caveats are present, and our estimates should be taken as illustrative of potential effects, and not exact figures. These caveats include, but are not limited to:
- ULFW service must meet additional technical specifications, which could potentially decrease its effect on eligible locations, compared to our estimate.
- State broadband offices are currently scrambling to incorporate ULFW and will likely utilize a variety of processes to do so. This is also likely to decrease its effect on eligible locations versus our estimate based on FCC data.
- Locations we identified as potentially BEAD-eligible following RDOF defaults may have been excluded from eligible location lists not because of RDOF commitments, but for other reasons, like challenges from ISPs or other enforceable commitments. In other words, our RDOF default locations may still not be BEAD eligible.
Notes on Others’ Analyses
At least two other entities have released their own estimates of ULFW’s impact on BEAD. While these differ from the ACLP’s both methodologically and in their exact estimates, they both came to the same fundamental conclusion: inclusion of ULFW in BEAD will likely have a significant negative effect on the number of eligible locations.
One analysis, from J. Randolph Luening of BroadbandToolkit.com, looked at data in 11 states and found that “more than 25 percent of likely BEAD-eligible locations could be taken off the map.” Indeed, depending on which states are included in that set of 11, this generally aligns with the magnitude of the ACLP’s estimates.
Another analysis, from the Systems, People, Infrastructure and Networks Lab at Virginia Tech (SPIN@VT), estimated a “a 12% decrease in the number of un/underserved locations nationwide,” very close to the ACLP’s estimate of 15%. The SPIN@VT analysis differed from ours in that, instead of utilizing post-challenge location lists, it utilizes lists of potentially eligible BSLs from FCC data. Despite this methodological difference, both SPIN@VT’s estimate and the ACLP’s estimate are, on aggregate, very similar.