Prepared for the Board of Commissioners & General Manager · and for the public record
The four arguments for the pause — tested against the evidence.
The May 4 letter and the discussion around it rest on four claims. The record contains no analysis
supporting them — so we did the analysis, both directions: for each claim, the strongest case FOR it (researched
and cited), what the District's own records show, and an honest grade.
Save Local Broadband · an independent ratepayer effort · July 2026savelocalbroadband.com/flyer-business-case.php
First, the board position — because this is not market entry. The District
already owns the asset, the customers, and the sales channel. Every competitor must build what it already has:
$9.2M
Already built — the 2010 federal build: ~158 access points across 46 published sector areas, RF-proven for 25 years
2,700
Already connected — billed connections today, sold and supported by seven local storefronts at $0 acquisition cost to the District
$0
Backhaul already bought — every tower rides the District's own fiber (400G switching just added, Res 1858); upstream transit costs nothing via NoaNet
1.5 yrs
Refresh already affordable — of the segment's audited surplus ($808K, 2024) covers the whole ~$1.2M upgrade in cash
The four claims, and where the evidence lands:
01 “NCI is investing — it will take the market; our providers can't compete.”PARTIAL — self-fulfilling only
02 “Starlink is cheaper for more bandwidth, and only getting better — it will flood the market.”STRONG — vs a 20 Mbps network
03 “Combined, the competition is too much — market share will spiral.”PRESSURE REAL — SPIRAL UNSUPPORTED
04 “The system has been in active decline for years.”HALF TRUE — THE TRUE HALF IS THE CASE FOR INVESTING
The pattern, up front
All four arguments share one property: each is true only in the scenario where the District follows its own
recommendation. Freeze a 20 Mbps network while every rival improves, and NCI wins, Starlink floods, the
combination overwhelms, and the decline becomes real. Upgrade it, and five years of the District's own records say the
opposite. The fears are not findings — they are forecasts of the pause itself.
Save Local Broadband — an independent community advocacy effort; not affiliated
with Okanogan PUD. Every claim cited; sources on each page and page 6. · Page 1 of 6
Four arguments, answeredPage 2 · Claim 01 — NCI
Claim 01GRADE: PARTIAL — TRUE ONLY IF THE NETWORK STAYS FROZEN
“NCI is investing in its own network — it will take the market, and our providers won't be able to compete.”
The strongest case for it — we went looking
NCI launched fiber in Omak in October 2024 — symmetrical 500 Mbps at $65 up to 2 Gbps at $125, with a
published promise to expand — and advertises fixed wireless to 600/50 Mbps across a six-county footprint,
including towers everywhere the District's are and places they aren't (Tunk). Its owner, Heritage Holding, is a serial
consolidator: 50+ acquisitions, six ISPs unified under the Core Fiber brand, with a stated thesis of buying
rural Pacific-Northwest providers in towns of 1,000–20,000. Industry analysts expect exactly this kind of scaled platform
to out-compete subscale operators.
What we could not find, anywhere: Heritage/Core Fiber's capital scale (private, undisclosed) · any
Okanogan expansion announcement after October 2024 · any Washington broadband grant to NCI/Core Fiber · a single documented
case of a Heritage ISP displacing an incumbent network.
What the District's own records show — the experiment already ran
While competing with a faster network…
…the audited record shows
NCI's purchases from the District
Grew, $400K → $471K/yr (2021→2024) — rising after the acquisition; still ~$188K/yr of transport & bandwidth today
NCI's PUD reseller book
642 → 815 through May 2024 — the fastest-growing reseller, with its own faster towers standing — then a wireless-only wind-down (its PUD fiber resale grew throughout, 141 → 210)
The six local providers, capped at 20 Mbps
2,299 → 2,180 (−5% over 5½ yrs) — held on ground NCI contested everywhere (no uncontested territory exists in the upgrade footprint); active sellers grew (Will Connect +63%)
NCI's own retail price record
All tiers +5–6% within weeks of the Feb 2023 announcement; two tiers up again in 2025 (the 2024 restructure did cut per-Mbps — the whole sequence, cited)
The structural economics don't change with the branding: investor
capital must ultimately price for return plus income tax; the District is barred by law from pricing above cost
(RCW 54.16.330), and its seven storefronts sell at $0 acquisition cost to it. A challenger can beat a frozen
20 Mbps network — the record shows nobody profitably out-competes an invested, at-cost one.
Verdict
Partial merit — and self-fulfilling only. The investment is real; the conclusion isn't, on five years of evidence.
Head-to-head at a thirty-fold speed disadvantage is the floor, not the ceiling: a network that held at 20 Mbps has no
reason to do worse at 250. The one scenario where this claim comes true is the pause itself.
Four arguments, answeredPage 3 · Claim 02 — Starlink
Claim 02GRADE: STRONG — AGAINST A 20 MBPS NETWORK
“Starlink offers lower prices for more bandwidth, and it's only getting better — it will flood the market.”
The strongest case for it — and it is genuinely strong
12 million customers (June 2026; +4.5M in 2025 alone, targeting 25M) · U.S. median download ~118 Mbps and
rising every quarter (Ookla) · next-gen V3 satellites rated ~1 Tbps each, ~60 Tbps per Starship launch,
first test hardware flown May 2026 · a $55/mo 100 Mbps tier offered specifically in low-demand cells — which
rural Okanogan's are · rural cells show open capacity, not waitlists · $43.4M of Washington's federal BEAD money now
goes to Starlink (26% of the state's funded locations) · and a Virginia rural ISP publicly lost 3,000 subscribers to
Starlink promotions in one quarter. We grade this claim STRONG. It deserves to be taken seriously — and it is
strongest against exactly one thing: a network capped at 20 Mbps.
What the record shows — here, and in the best market-level data on earth
Here: across three local providers' cancellation logs, Starlink
is ~15% of cancellations — the biggest single name, still a minority — and it wins where the local link is congested
20 Mbps gear. Its pricing tracks leverage, not cost: in June 2026 alone it raised U.S. residential tiers $5–10,
dropped the hardware-purchase option for a $10/mo perpetual kit fee, and it charges congestion fees up to $1,000
where customers are captive. Abroad: New Zealand's regulator — the cleanest natural experiment anywhere — found
Starlink became the #1 rural ISP (27% share) while local wireless providers were still net-gaining customers:
satellite sweeps the unserved and the badly-served; where a good local option exists, local holds.
Verdict
STRONG — and it argues for the upgrade, not the pause. One more thing the claim misses: these are different
products. Starlink is a do-it-yourself utility — self-install, self-support, no guaranteed speeds, no one to call.
The local product is installed, supported, bundled, and accountable — a lot more service for about the same monthly
dollar, in a county whose demographics make DIY a barrier, not a perk. That's why even a broken 20 Mbps local
product held ~85% of its leavers away from satellite, and why NZ's locals net-gain under 27% Starlink share: satellite
sweeps the unserved; full service holds the served — when the service works. The letter reads Starlink's rise
as a reason to concede the field. It is the reason to contest it.
Four arguments, answeredPage 4 · Claim 03 — the combined-competition spiral
Claim 03GRADE: PRESSURE REAL — “SPIRAL” UNSUPPORTED
“Even if no single competitor wins, the combined competition is too much — our market share will spiral.”
The strongest case for it
Analysts do describe a real two-front squeeze on rural wireless ISPs — LEO satellite from above, fiber from below — with
some subscale WISPs selling or exiting; the cable/telco “duopoly era” is over. And one true collapse exists in
adjacent technology: Viasat's U.S. consumer satellite base fell 596K → 205K in four years once a superior substitute
arrived — proof a rural base can evaporate.
What we could not find: a single documented case of a
rural WISP or public network death-spiraling under combined satellite-plus-fiber pressure. The best market-level dataset
(NZ, under maximal Starlink pressure) shows local providers net-gaining.
What the record shows — both fronts were already here, for five years
Starlink has sold county-wide since 2021. NCI ran faster towers the
whole time. Under both at once, the local providers grew to their peak, plateaued for three years, and only
drifted as the District stopped supplying radios (installs 229/yr → 2). And a spiral needs a mechanism — fixed
costs forcing rate hikes as customers leave. This network's build is sunk and federally paid, its rates
cost-based by law, its sales channel free. The arithmetic that makes networks spiral doesn't exist here.
Our 200,000-run model stacks these fears together — near-certain NCI reseller exit, Starlink churn, a reseller
collapse, cost overruns — and the county still comes out ahead in ~99% of futures (88–98% even in the
deliberately pessimistic world).
Verdict
The pressure is real; the spiral is a choice. The only true spiral on record — Viasat — was a service with no
local support that stopped improving while a better option arrived. The pause recreates those exact conditions
locally. Five years of the District's own data show what prevents it: a network someone invests in, sold by people
who answer the phone.
Sources: monthly "Wireless" report cuts, 65 months (records request) · RCR Wireless (Wave7, May 2026) ·
frankrayal.com (Feb 2025; Viasat figures) · NZ Commerce Commission (Jun 2026) · Monte Carlo methodology at
savelocalbroadband.com/how-we-modeled-risk.php. · Page 4 of 6
Four arguments, answeredPage 5 · Claim 04 — “active decline”
Claim 04GRADE: HALF TRUE — THE TRUE HALF IS THE CASE FOR INVESTING
“The system has been in active decline for years.”
The strongest case for it — and we agree with the true half, loudly
Subscriber counts did fall — about −16% from the 2022 peak, faster in 2024–26. The fleet averages ~17 Mbps
down — below the federal 100/20 definition of served. And the hardware's maker, Cambium Networks, is in genuine
distress: a going-concern warning, default on ~$66.5M of debt, delisted to OTC in March 2026, with the platform's
edge product lines already end-of-life (support ends 2027). Two of those three facts are about the hardware, not the
demand — and they are the strongest facts in this entire debate. They just point the other way.
What the records show — what actually declined, in what order
The budgets moved first. Wireless reinvestment was cut
~92% ($330K → $26K) starting in 2022; the subscriber slide began roughly 18 months later. The District then
effectively stopped connecting new customers — its billed installs, year by year:
229
2021
123
2022
98
2023
84
2024
51
2025
2
2026 · Jan–May
Meanwhile, what demand did: revenue grew into the District's
largest single telecom line ($1.08M → $1.14M, +5.8%, with zero rate increases) · customers climbed toward the
20 Mbps ceiling (top tier 635 → 1,033) · total last-mile connections, wireless plus fiber, rose +2.3% ·
more than half of the recent subscriber drop is one reseller's wireless-only channel exit — NCI winding down
its resale program while keeping its PUD fiber customers and transport · and part of the loss was never market at all:
in a county whose deaths have run ~20% above the pre-COVID baseline since 2021 and whose 75+ population grew
31% in 2020–25 (OFM/Census), a share of cancellations are simply customers who passed away.
A demand collapse doesn't grow revenue, climb tiers, and concentrate in a single account plus an actuarial table.
A supply ration meeting an aging service area does exactly this.
Verdict
Half true — and the District is citing the wrong half. The demand didn't decline; the hardware did, on the
schedule the budgets wrote. With the vendor itself collapsing, “the system is in decline” is not a reason to
stop — it's the deadline. Aging, orphaned gear is precisely what the ~$1.2M replaces.
Sources: budget workbooks 2021–2026 & by-Code billing, 65 months (records request) · ispreports.org /
BroadbandNow (fleet speeds) · Cambium Networks 10-K going-concern disclosure & Nasdaq delisting notices (2025–26) ·
Cambium PMP 450 EOL notice (community.cambiumnetworks.com) · deaths/aging: WA OFM components of change & age estimates
2020–25; U.S. Census county components, FIPS 53047. · Page 5 of 6
Four arguments, answeredPage 6 · The pattern, and the ask
The pattern
All four arguments are true in exactly one scenario — the one the District chose.
The claim
Grade
Frozen at 20 Mbps
Upgraded to 250 Mbps
01 NCI takes the market
PARTIAL
Comes true — nobody chooses 20 over 600
Five years of records say local holds — and wins
02 Starlink floods it
STRONG vs 20 Mbps
Comes true — it beats congested 20 every time
≈$50/250 + a person nearby beats $55–130 + kit fee
03 The combination spirals
UNSUPPORTED
Becomes possible — Viasat's path: stand still, fall
No mechanism: sunk build, at-cost rates, free channel
04 Active decline
HALF TRUE
Accelerates — orphaned gear, vendor collapsing
The declining half — the hardware — is replaced
And the asset advantage is the part no competitor can copy. The
District isn't weighing market entry — it owns a $9.2M federally-built network, 2,700 billed connections, seven
self-funded storefronts, tower leases at $34,700 a year, and backhaul it already upgraded to 400G. Rivals must build all of
that at 2026 prices and investor rates of return, then beat an at-cost price. The District's only cost to stay is a
refresh it can pay for with 1.5 years of one segment's audited surplus.
The ask
Scope
Capital
Gate
1 — Workshop
The session the Board agreed to on June 22 — providers, this document, and the District's numbers at one table
$0
A date
2 — Prove it
One tower (Jackass Butte — field-tested at 243–946 Mbps), by budget amendment — the Res 1858 instrument
~$118–157K
Take-rate & churn targets set jointly in the workshop
3 — Scale on evidence
The remaining sites as gates are met, to the full 1,035-radio build
~$1.2M cum.
Trajectory — the Board's own word
Our standing offer
Every number here is open: the model runs live on our site, every lever draggable, O&M included (audited ~45% cash
margin, stress-tested 28–58%). If the District has evidence for any of the four claims that we didn't find, bring it
to the workshop — we will publish it and re-grade. That's what an honest business case looks like from either side.
Check our work
Run the model live — savelocalbroadband.com/how-we-modeled-risk.php: three scenarios, every lever, on your device.
Trace every figure — audited statements, budget workbooks, 65 months of billing, all indexed: /documents.php
Bring us the wireless O&M split — the one number only the District has. We'll rerun everything with it, publicly.
the live model
Scan to drag every assumption yourself.
Save Local Broadband — an independent community advocacy effort; not affiliated with
Okanogan PUD. Full source set: WA SAO audited statements (Note 9) · District budget workbooks 2021–2026, Tarana cost
workbooks & field-test deck, 65 monthly billing reports (records requests) · published board minutes 2023–2026 & the
June 22, 2026 recording · FCC ULS/ASR · ncidata.com + Wayback · heritage-holding.com · plexuscap.com · Ookla via trade press ·
NZ Commerce Commission (Jun 2026) · Cambium SEC filings & EOL notices · Telecompetitor/Quilty (WA BEAD). · Page 6 of 6