Treasury Department guidance on American Rescue Plan Act funding for state and local government fiber projects raises questions on throughput standard

The U.S. Treasury Department has updated guidance on the use of $10 billion in American Rescue Plan Act grant funding to state, local and tribal governments for capital projects to construct advanced telecom infrastructure. The text below is excepted from the guidance:

Broadband Infrastructure Projects. The construction and deployment of broadband infrastructure projects (“Broadband Infrastructure Projects”) are eligible for funding under the Capital Projects Fund program if the infrastructure is designed to deliver, upon project completion, service that reliably meets or exceeds symmetrical download and upload speeds of 100 Mbps. If it would be impracticable, because of geography, topography, or excessive cost, for a Broadband Infrastructure Project to be designed to deliver services at such a speed, the Project must be designed so that it reliably meets or exceeds 100 Mbps download speeds and between 20 Mbps and 100 Mbps upload speeds and be scalable to a minimum of 100 Mbps symmetrical for download and upload speeds. Treasury encourages Recipients to focus on projects that will achieve last-mile connections. Recipients considering funding middle-mile projects are encouraged to have commitments in place to support new and/or improved last-mile service.

This guidance favors fiber to the premises projects providing symmetrical throughput, something fiber can easily support. What's curious is the highlighted text. It begs the question of how "geography, topography, or excessive cost" (and what would be excessive?) would allow projects providing asymmetric throughput to qualify if those specific qualifications are met. It makes no sense because none of those factors would reasonably affect whether the delivered throughput is symmetric or asymmetric for a fiber to the premises project. Treasury clearly has some more explaining to do.