Expert: Some States Could See Decrease in BEAD Locations Because of Unlicensed Wireless
Broadband mapping expert found that in 11 states, more than 25 percent of likely BEAD-eligible locations could be taken off the map.
WASHINGTON, June 20, 2025 – Some states could see a significant reduction in their eligible locations for the Broadband Equity, Access, and Deployment program after taking into account new wireless coverage, according to a broadband mapping expert.
According to an analysis from J. Randolph Luening, founder of BroadbandToolkit.com, 11 states have the potential to shrink their BEAD-eligible locations by more than 25 percent. In Nevada, Luening found as many as 78 percent of the BEAD-eligible locations have the potential to be taken off the map.
The National Telecommunications and Information Administration handed down new rules for the $42.45 billion BEAD program on June 6. Those rules rescind the few Biden-era approvals on spending plans – including Nevada’s – and require every state to run another bidding round with rules that are less favorable to fiber.
FROM SPEEDING BEAD SUMMIT
Panel 1: How Are States Thinking About Reasonable Costs Now?
Panel 2: Finding the State Versus Federal Balance in BEAD
Panel 3: Reacting to the New BEAD NOFO Guidance
Panel 4: Building, Maintaining and Adopting Digital Workforce Skills
They also require states to partially redo their eligibility maps. States have to solicit input from wireless ISPs using unlicensed spectrum and give them a chance to make their coverage areas ineligible for BEAD funding.
Unlicensed fixed wireless, or ULFW, had been excluded from the previous BEAD challenge processes that determined eligibility because of interference concerns. States would still in some cases have had to verify ULFW coverage, but only if they were funding more ULFW, something of a last resort under the old rules.
CHART: States' BEAD locations could be further reduced by new unlicensed fixed wireless guidance
ULFW providers will have seven days from a state’s public notice to say they intend to defend some of their coverage area. They will then have another seven days to submit evidence their networks can adequately mitigate interference and provide service meeting minimum standards for the next four years.
States can still find that evidence unsatisfactory and keep the locations open for BEAD funding.
Different ways of viewing a decrease in the number of unserved and underserved locations
“Since some states have an abundance of resources and others are running on empty, some view a decrease in the unserved/underserved as negative while others see it as positive (helping them operate within budget),” Luening said in an email.
The analysis used the FCC’s latest broadband coverage and funding data as a starting point, with areas that have no enforceable buildout commitment and no previously qualifying 100 * 20 Mbps coverage being considered BEAD-eligible. Eligible locations where a ULFW provider reported 100 * 20 Mbps service were then subtracted to gauge the potential impact.
States each have their own eligibility maps, which were produced in part by in-state challenge processes and differ from the federal data, but they will have to update those maps with the most recent FCC data as part of the new rules.
It’s not clear how the NTIA will handle situations where a state’s challenge results differ from what an ISP reports to the FCC, but the process will likely impact the eligible location counts. Luening calculated the potential change in eligible locations resulting solely from the impact of reported ULFW coverage.
States are hustling to carry out the new guidance
States are hustling to carry out the new guidance, with a Sept. 4, 2025 deadline to update their maps, take another set of applications, select winners, and submit final spending plans. Many states are already in the process of soliciting ULFW provider input.
South Carolina published its new BEAD eligible location count on Friday afternoon. The state has less than 22,000 homes and businesses to reach, down about 6,000 or 23 percent from April. The state said it included results of an existing process in which every state is trying its best to reduce its eligible location count, and new enforceable commitments that had been made in recent months. FCC data indicated a relatively small ULFW presence in the state.
Eligible location counts have been falling as states improve their mapping and buildouts continue. An NYU study found the total decreased 57 percent since 2023, down to about 5.5 million currently.
