Prepared for the Okanogan County PUD Board of Commissioners
Stepping back from the wireless network is easier for the District. That is not the same as better for the county. Every figure in this brief is drawn from the District's own audited statements, billing records, and engineering workbooks — and together they make a different case than the one the May 4 letter assumes.
On May 4, 2026 the District told retail providers it would make no further investment in the wireless network unless subscriber counts rise first — a direction the Board approved with no market analysis and without consulting the providers. Yet the District's own audited books show the telecom segment thriving — its net worth more than doubled, $4.9M (2019) to $10.5M (2025), profitable every year but one. The one-time ~$1.2M upgrade (about 1.5 years of surplus) was always affordable; the wireless platform was simply never funded, and its hardware is now end-of-life. A decision of this consequence — and this premise — deserves a full, public review.
The letter says
"Subscription rates have steadily declined."
The record shows
Most of the decline is one reseller — not the market. Of the past year's 355-subscriber drop, 52% is NCI Datacom alone, whose RSP numbers collapsed after an out-of-area Core Fiber restructuring. Every other provider declined gently. The network proved resilient through Starlink's cheapest-ever pricing — a drop concentrated in one reseller's account is the case for modernizing, not against it.
The letter says
"A highly competitive marketplace."
The record shows
It's competitive because the District makes it so. The 7+ local providers — plus NCI on its own towers — all compete on the District's open-access network. Step back and the "marketplace" collapses toward one out-of-area private operator plus satellite, billed out of county. In the providers' own logs Starlink is the largest single competitor but a minority — about 15% of cancellations; most leave for moves, nonpayment, or seasonal vacancy. A market that depends on the District isn't a reason to leave it.
The letter says
"Required to set rates to recover full cost… does not compete on price."
The record shows
True — and that settles recovery in the District's favor. Cost-based ratemaking already recovers equipment cost, the same way it recovered the 2010 build. The District needn't compete on price; its retail providers do, at no cost to the District — several are ready to match Starlink. Keeping the wholesale network running is all that's required.
The letter says
Invest only "should future subscriber enrollment reach a level sufficient to offset the costs."
The record shows
That condition can never be met by waiting. Subscribers will not climb on an end-of-life, 20 Mbps network — so inaction, not investment, is the larger risk: a one-time ~$1.2M outlay set against a recurring ~$1.1M/yr revenue line and a federally-funded public asset. "Wait and see" guarantees the very decline it's trying to avoid.
This network didn't appear on a spreadsheet. It was built over two decades, with real financial risk, into something most rural counties can only envy: fast, local, competitive broadband that keeps the dollars and the accountability at home. That history is the context the May 4 letter leaves out.
Public infrastructure, built for this county — on ground that took decades to claim.
Okanogan helps found NoaNet — one of about ten Washington utility districts building open-access fiber, because private ISPs served the I-5 corridor and skipped the rural east.
The District builds an 82-mile backbone from Pateros to the Canadian border and lights up fixed wireless for homes, farms, and businesses.
A $5.5M grant and a $3.7M loan build ~170 wireless sites — debt the District took on and is steadily paying down. The network that still serves the county today.
Eight competing local providers, ~3,800 customers, cost-based prices, and a real person to call — more choice than most cities. "One of the leading rural broadband solutions in Washington."
Capital spending flattens to $159K and the Cambium hardware reaches end-of-life. The slow decline begins.
The Board pauses further wireless investment. After 25 years and real financial risk, the legacy is on the line.
Both charts below are built from the District's own monthly "Telecom Report by RSP" files. The first overlays the cause: the network's funding was cut years before subscribers fell — not when Starlink arrived. The second shows the recent slide is concentrated in a single reseller whose RSP book dropped sharply after its Core Fiber restructuring.
Reinvestment (left axis) was cut 34% by 2023 — while the subscriber base (right axis, zero-based) was still at its all-time peak. Customers didn't begin leaving until mid-2024 — about 18 months later. And Starlink arrived in 2021, yet the base grew for three years after. The District's own spending cut set the slide up first — the satellite and NCI's RSP decline came later. The deepest cut landed while the base was healthiest, so it was a choice — and the $1.2M platform upgrade was never budgeted at all.
NCI Datacom alone is 52% of the entire 355-subscriber decline — after its tie-up with Core Fiber, an out-of-area, investor-owned consolidator. Every other reseller declined far more gently, and Will Connect ended the year flat. This is not broad collapse of demand; it is one company's RSP book shifting after a change of ownership — the strongest possible argument that the platform is healthy and worth modernizing.
The history matters too — because it changes what "risk" means here. What this District built is, frankly, a rural marvel: more competition and local choice than most American cities have, on infrastructure other rural counties wish they had. It exists because earlier leaders took real financial risk when rural broadband was anything but a sure thing.
A founding pioneer
In February 2000, Okanogan was one of about ten Washington utility districts that founded NoaNet — now the state's largest open-access network, 3,800+ miles of fiber — created precisely because private ISPs served the I-5 corridor and skipped the rural east. The District then built its own backbone and launched fixed wireless in 2002.
Real risk — not free money
This wasn't all grants. For the 2010 build the District took on a ~$3.7M federal loan alongside a $5.5M grant — debt it took on and has steadily paid down — and it reinvests its own telecom earnings into the network. Earlier boards bet real money on an unproven model, and the bet paid off.
What the bet produced
Eight competing local internet providers serving ~3,800 customers — more real choice than most U.S. cities, where one or two providers dominate. Cost-based prices, local accountability, a stable market, a $16.9M public asset — and, in the District's own words, "one of the leading broadband solutions for rural communities in Washington State."
The risky, expensive, pioneering work is done — and largely paid down. What remains is a routine ~$1.2M equipment refresh: a fraction of the original bets, on infrastructure that already exists, already earns ~$1.1M a year, and is already de-risked. Against that, the larger risk is the one the letter never names — letting a 25-year, federally-funded public asset decay on end-of-life hardware, and forfeiting the choice, competition, and market stability it took two decades and real financial risk to build. Stepping back doesn't avoid risk; it takes the one risk you can't undo: losing the legacy. That capacity is a 25-year stock, not a switch — let it go and it doesn't come back: Provo, Utah sold this same open-access model for $1 once its providers were left to collapse.
Today's commissioners weren't the ones who founded NoaNet in 2000 or built the network in 2010 — but they inherited the reward, and they're now the stewards of whether that legacy continues. That isn't a spreadsheet decision; it's a decision about whether to protect what this county built.
This decision isn't about protecting a monopoly; the District doesn't have one and never did. NCI has competed for years with its own towers — it even pulled ahead on speed, advertising at least 600/50 Mbps on Eder Mountain while the District sold 20 Mbps. The District's customers stayed — the base held at peak levels through late 2023 — anyway. The real asset is the thing that made that competition possible in the first place.
What the District provides
An open-access public backbone — an 82-mile fiber line, Pateros to the border, feeding wholesale wireless that 7+ local providers resell and compete over on price and service. That's real competition and local choice — more than most American cities have — and it keeps rates honest. (The District leases its tower sites; the asset that matters is the public fiber and the open-access model on top of it.)
What the pause leaves
Freeze the network on end-of-life gear and the District drops out of the competition. What's left is one out-of-area, investor-owned operator (NCI/Core Fiber) as the dominant player — with no public alternative to keep rates in check. That isn't a stable market; it's a monopoly risk, and the rates that come with it.
Keeping that market competitive and rates fair is the PUD's mandate — the reason public utility districts exist. Modernizing keeps the District in a competition that has served ratepayers for two decades; the pause forfeits the market to a single private operator.
Satellite suits the truly remote and is a fine backup, but it is not an equivalent substitute for a network the public owns. To be candid, congestion isn't the concern in a county this sparse — the concern is dependence, control, and cost. Starlink is a subscription to a fleet one out-of-state company must relaunch indefinitely (satellites deorbit in ~5 years; even "gigabit" rides on a rocket still in testing); its price is set with no local rate board, the service is sold "as is" and "not mission-critical," and a single software fault took ~6M users in 140 countries offline on July 24, 2025. Every dollar leaves the county. Starlink is already a minority of departures here (~15%); a modernized local tier matches its cheapest plan with a local technician and dollars kept in-county. Investment holds the ground; retreat cedes it to one distant company.
Competition with NCI is healthy — it has been the status quo for years, and ratepayers benefited from it. The danger isn't that NCI competes; it's that without the District, NCI becomes the only option — a single, out-of-area, investor-owned operator (now folded into Core Fiber) with no public network to keep its rates honest. Open access — multiple local providers competing on one public backbone — is the opposite of that, and it's what the pause throws away. And note: most of the recent decline is concentrated in NCI's RSP book after the Core Fiber restructuring — one reseller's account, not a platform-wide loss of demand. If the rationale rests on a specific Okanogan wireless grant to NCI, that award isn't in the public record — the District should put the document forward.
NCI Datacom owns its own towers and competes across the District's footprint — head-to-head on the same ridgetops in the south, and on shared, leased sites elsewhere (it advertises at least 600/50 Mbps on Eder Mountain, where the District sold 20 Mbps — and the District's customers there stayed anyway). Every one of the District's seven sites is leased, not owned. This is a real, long-standing competitive market, and the District's open-access network is what keeps the county's other providers in it. Here is where NCI's own towers reach the seven.
| PUD tower | Customers | Nearest NCI own-tower | Competitive status |
|---|---|---|---|
| Jackass Butte | 132 | Jackass Butte ~0 km | NCI on same ridgetop |
| Coleman | 170 | Coleman Butte ~0 km | NCI on same ridgetop |
| Nortons | 83 | Tonasket Tower ~0 km | NCI on same ridgetop |
| Shellrock | 44 | Omak (KOMW) ~1.3 km | NCI on same ridgetop |
| Eder | 241 | Eder Mt (co-located) ~0 km | Shared site · NCI competes |
| Number Hill | 83 | Eder Mt (co-located) ~3.5 km | Shared site · NCI competes |
| Pickens | 125 | Tonasket Tower ~9.9 km | Shared site · NCI competes |
The District leases all seven of these sites — it owns none of its towers. Three are co-located head-to-head with NCI on the same ridgetop (Coleman, Jackass Butte, Nortons). The rest are shared / leased: Eder is private land where NCI runs its own tower advertised at least 600/50 Mbps; Pickens is the Okanogan County TV-district mountaintop (shared with translators and a Day Wireless tower); Number Hill is leased from the City of Oroville. NCI also runs sites near Twisp (~41 km) and in Ferry County. Fixed-wireless access points use unlicensed bands that don't appear in FCC license data, so siting is from the resellers' direct local knowledge plus FCC records where available.
We want all seven built; in principle the whole network should be modernized. But as a phased compromise that meets the Board's risk concern head-on: start where the payback is fastest — the towers with the lowest capital cost per customer: Eder, Jackass Butte, Coleman. That's 543 of 878 customers (62%) for about $658,597. It's anchored by Eder — the District's single biggest site, and the place where NCI's own tower — at least 600/50 Mbps — already proves people will pay for real speed. Modernize there and the District can finally compete for that demand instead of conceding it. Prove the model on the fastest-payback sites, then extend to the rest — where the District's open-access network is what keeps the county's other providers able to compete with NCI at all.
The pause weighs one thing: whether the wireless line pays back fast enough. But a public utility holds responsibilities a balance sheet can't show — and on three of them, stepping back costs the county far more than the upgrade ever would. These are the reasons public utility districts exist in the first place.
Washington created its PUDs in 1930, in a Grange-led ballot measure, because private power companies were charging rural families more than double the urban rate and skipping the countryside altogether. A District's founding purpose is to stabilize a market the private sector under-serves — and this District has done exactly that for 25 years; what changed isn't the mission, only that the gear fell behind. Broadband is the same story: where the local network fades, the only option left is a satellite priced and controlled from out of state — no local rate board, free to raise prices at will. If it doubled or tripled its price tomorrow, a county with a working local network has an answer; one without it simply pays — the District can't set Starlink's price, but a public, at-cost option is what keeps the squeeze in check.
Across much of Okanogan County — the largest county in the state, about eight people per square mile — there is no reliable cell signal and landlines are mostly gone, so home internet is the phone: Wi-Fi calling, VoIP, and 911. And this is wildfire country. The 2014 Carlton Complex was the largest single wildfire in Washington history; in the 2020 Cold Springs Fire a cell tower burned to the ground and 911 was rerouted out of county for about twelve hours. No one knows this better than the District — after the 2014–15 fires its own crews reported radio, phone, cell, and fiber "all down," with sixty miles of its fiber and wireless lost. No technology is fireproof — but a locally owned, maintained network is a layer of resilience this county has needed before.
This network isn't one company's product; it's a marketplace the District built. Because Washington law for two decades allowed PUDs to sell broadband only at wholesale (retail authority came only in 2021), the District created an open-access network that eight independent local providers compete on — public infrastructure, private competition. It's the model Washington is known for nationally: open-access markets here average about seven providers, and Okanogan has eight — more real choice than most American cities. Seven of them resell on these wireless towers, with no other way to reach those customers. A utility doesn't only serve customers; it stewards the market it created — over twenty-five years, here.
The deeper question — the one only the Board can answer — is whether Okanogan County PUD still sees itself as the steward of a market, a safety net, and a quarter-century public legacy, or as the operator of a line item it can switch off.
Jefferson County PUD put about 40% of its 2026 capital budget (over $15M) into broadband; Kitsap is building on a $15M federal award plus a state match; Pend Oreille County PUD — a rural open-access PUD like Okanogan, built on a federal stimulus grant — was just awarded a fresh ~$12.4M federal award plus a state match to expand fiber, and still runs a wireless layer of its own. All are open-access public utilities, like Okanogan — and all are growing their networks. Okanogan is the one pausing its wireless layer. (And its own $30M fiber grant? $0 spent in two years, now moving to rescind it (Res. 1863, June 2026) — so "we're still investing" doesn't cover the ~2,700 customers on wireless.)
Asked what it would take to reinvest, the District said it would consider it only if customers "signed contracts." Fair as a condition — but the May 4 letter defined no commitment, set no threshold, and gave no one a way to sign anything. Yet the demand is already there: more than 100 former customers told a local provider they would return if the network were modernized — most citing its lack of any forward trajectory, not a single speed or price. A "commitment" can take several forms, and every one of them works here.
Who carries the risk? Pick any — or split it three ways.
The customer
A small construction adder on the monthly bill once it's built — about $5–$15/mo over 12 yrs. It rides the account, not the property, so renters qualify. Nobody pays until it's delivered.
The providers (RSPs)
The District's actual customers — the local ISPs — guarantee the wholesale purchase per tower and take the demand risk themselves; households commit to nothing. They've said they're willing. The cleanest fit for a wholesale network — and it removes the District's capital risk outright.
The District
It simply does the upgrade, as it has for 25 years: a one-time ~$1.2M from a profitable segment (~1.5 yrs of surplus), recovered through ordinary wholesale revenue — bounded, one-time, against a recurring ~$1.1M/yr line.
All three
Split it: the District funds the shared towers (~$371K); providers commit to a minimum take per tower; customers cover only their own radio (~$5.50/mo). Divided three ways, every piece is small.
| Tower site | Customers | Per customer | If customer-funded (~/mo) |
|---|---|---|---|
| Eder | 241 | $1,139 | ~$8/mo |
| Jackass Butte | 132 | $1,187 | ~$8/mo |
| Coleman | 170 | $1,338 | ~$9/mo |
| Number Hill | 83 | $1,361 | ~$9/mo |
| Nortons | 83 | $1,504 | ~$10/mo |
| Pickens | 125 | $1,509 | ~$10/mo |
| Shellrock | 44 | $2,122 | ~$15/mo |
| All seven | 878 | $1,342 | ~$9/mo |
"If customer-funded" spreads a tower's full cost over its customers as a monthly adder over 12 years (lower over 20). If the District funds the shared towers, each household covers only its own radio (~$5.50/mo). Nobody pays until it's built. (Full per-tower costs & payback on the next page.)
Mason PUD 3 builds a "fiberhood" at a 75% sign-up, recovered through a $25/mo bill adder (renter-friendly); Kitsap PUD and Ammon, ID use a petition → property assessment for owner-occupied areas; Grays Harbor PUD projected a 40% take rate on its latest phase and got ~78%. None of them paused. Define the commitment, set the threshold, put the District on a build timeline, and pick any model above — the providers are ready to sign, and the customers are ready to return.
We placed the District's audited financial statements beside its budgets. The telecom business is not struggling: its audited net worth more than doubled — from $4.9M (2019) to $10.5M (2025) — with a surplus every year but one ($808,166 in 2024 alone). Yet the District never funded the $1.2M wireless upgrade while its capital and attention flowed to a federally-funded fiber program. That $1.2M is roughly 1.5 years of this segment's surplus. And it is a lean network to run — $0 for internet transit, and just $34,700/yr to lease all nine tower sites (the biggest, Eder, is free). Affordability was never the issue — priorities were.
One business, two opposite trends
$4.9M (2019) → $10.5M (2025), profitable every year but 2019 (Note 9). A healthy, growing business.
$330K (2021) → ~$26K (2026). Part tracks falling subscribers — but the $1.2M platform upgrade was never budgeted at all.
Not a hypothetical: the wireless line's actual yearly leftover (after its debt, reinvestment, and a full revenue-share of shared staff), banked as it came in: $158K→$336K→$626K→$940K→$1.33M by 2025 — clearing the $1.2M cost in five years, no grant, loan, or rate increase. Even banking half funds it inside the gear's life. Leftover is modeled (the standalone wireless margin isn't separately reported); but its growth tracks the documented reinvestment decline, and it reconciles with the audited $808K segment surplus.
The District keeps a $10 million Rate Stabilization Reserve — raised from $6M — and managed a $34.8 million bond construction fund — it plainly knows how to reserve for large capital. And RCW 54.16.330 requires telecom revenues to be dedicated to building and maintaining telecom facilities and paying their debt. The wireless network is one of those facilities; that money was the telecom system's to spend on itself — and it went to fiber. (We allege no hidden cash and no wrongdoing: electric and telecom share one reporting fund, and funding fiber is lawful. The point is stewardship — a thriving public business that chose not to maintain the network its rural majority relies on, then called a $1.2M upgrade unaffordable.)
The ~$1.2M upgrades seven tower sites serving 878 customers — about $1,200 all-in per customer (~$1,340 spreading the full 1,035-radio budget over today's 878), returning the District's proposed $40/mo wholesale rate (~$480/yr). At an estimated operating cash margin (~45–50% — derived from the audited operating income by adding back non-cash depreciation; the 24.9% net figure is after that depreciation), it pays back in about 5–7 years on an undiscounted simple-payback basis — a discounted median ~9–10 years in the rebuilt model — inside the equipment's ~10–11-year life (the gear it replaces lasted ~16). It is also affordable today: ~$1.2M is about 1.5 years of the segment's surplus, funded from telecom, not electric rates.
| Tower site | Customers | Upgrade cost | Per customer | Payback, alone* |
|---|---|---|---|---|
| Eder • phase 1 | 241 | $274,499 | $1,139 | ~5.3 yr |
| Jackass Butte • phase 1 | 132 | $156,713 | $1,187 | ~5.5 yr |
| Coleman • phase 1 | 170 | $227,385 | $1,338 | ~6.2 yr |
| Number Hill | 83 | $112,952 | $1,361 | ~6.3 yr |
| Nortons | 83 | $124,863 | $1,504 | ~7 yr |
| Pickens | 125 | $188,575 | $1,509 | ~7 yr |
| Shellrock | 44 | $93,383 | $2,122 | ~9.8 yr |
| All seven | 878 | $1,178,370 | $1,342 | ~6.2 yr |
Every tower pays for itself inside the gear's ~10-year life — the lowest-cost sites fastest, so a phased build starts with Eder, Jackass Butte, and Coleman (543 of 878 customers for ~$659K). *Standalone payback at the proposed $40/mo tier and an est. ~45% cash margin; growth or tiered pricing only speeds it (the single $40 tier actually caps recovery). Two tailwinds: wholesale revenue per subscriber is up ~8% even as the base shrank, and Washington's own BEAD plan put 47.5% of its funding into fixed wireless (largest award ~$332M, to a fixed-wireless provider).
Even the worst case — a lower margin and a full NCI exit — recovers inside the equipment's life; the District's plan lands at ~5.4 years on an undiscounted simple-payback basis (a discounted median ~9–10 years, still within the gear's ~10–11-year life), and tiered pricing (the hardware supports 500 Mbps) would speed it further and earn more over the asset's life. The single proposed $40 tier actually caps recovery — pricing is a retail decision the providers, not the District, should make.
Page 10 of 11 — continued: the pricing evidence and what we ask of the Board.
| Blended wholesale rate | Simple payback (undiscounted) | Extra lifetime revenue |
|---|---|---|
| $40 — single tier | ~5.6 yr | — |
| $45 blended — modest premium mix | ~5.0 yr (11% faster) | ~+$0.5M |
| $48 blended — strong premium mix | ~4.7 yr (17% faster) | ~+$0.8M |
To be clear: the $40 base is fair — about 25% cheaper in real terms than the 2009 rate, and on cost-based math a sub-$40 tier is genuinely hard. The forfeit is at the top: the hardware "could comfortably offer 500 Mbps" (the District's words), the ~1-in-3 who buy the fastest tier elsewhere (OpenVault) have nothing to buy, and the District's own billing shows customers migrating up-tier for five straight years (the 20 Mbps ceiling tier grew 635 → 1,033). Premium and business plans above the base recover the upgrade faster — roughly $0.5–0.8M more over the gear's life — and give providers an upsell path as customers' needs grow.
Save Local Broadband — savelocalbroadband.com
An independent, technology-neutral effort by Okanogan County ratepayers — not affiliated with the PUD or any provider. Sources: WA State Auditor's Office, Okanogan PUD 2024 financial statements (Note 9 — Telecommunications); the District's Tarana 6 GHz upgrade cost workbooks (2026); monthly telecom billing reports, 2021–2026 (public-records request); three retail providers' cancellation logs (aggregated; source records held for the Board); USDA Broadband Initiatives Program grant + loan, 2010 (~$9,169,637); the County/CCT Broadband Action Team Digital Equity Action Plan (2023); Starlink published rates & terms (2026). The full data, methodology, charts, and downloadable records are at savelocalbroadband.com.