Technology-Neutral Framework for BEAD Restructuring Policy Notice
Assessing Network Scalability for State Broadband Offices
The NTIA has issued a BEAD Restructuring Policy Notice that underscores a technology-neutral approach, with performance and scalability requirements.
The policy and statute states that a Priority Broadband Project network must:
“Ensure that the network built by the project can easily scale speeds over time.”
SBOs must evaluate whether proposed networks are easily scalable…
However, as NTIA recognized in adopting special notice appendices for LEO satellite and Unlicensed Fixed Wireless, there are fundamental differences in broadband technology projects’ capabilities and potential scalability.
Cartesian has developed a technology-neutral framework that enables SBOs to assess the scalability of networks, regardless of technology. The framework is designed to account for key differences across network types, including:
- The initial “day 1” capacity
- Network reach, i.e., how many locations are served
- Capacity constraints, such as spectrum limitations
- Upgrade path to meet increasing bandwidth demands

Please note: SBOs are also required to determine whether the network can easily scale to support 5G/6G and other advanced services. We have not addressed how to implement that requirement in this analysis.
Applying the Scalability Framework to an Illustrative LEO Satellite Example
We have applied the Scalability Framework to an illustrative LEO Satellite example by:
- Selecting a single, representative service group of Broadband Serviceable Locations to apply the framework
- Providing a worked example of the required capacity calculations
- Demonstrating key scalability considerations and factors for assessing the upgrade strategy
