The Rural Telecommunications Group’s (RTG) reply comments submitted today in the Federal Communications Commission’s Phase II Mobility Fund proceeding emphasize that any decision prior to completion of Phase I on how to award Mobility Fund Phase II support is premature. “No decision as to how Mobility Fund Phase II support should be distributed should be made before Phase I has been completed and fully reviewed by both the Commission and the wireless industry,” stated RTG’s General Counsel, Carri Bennet. RTG urges the FCC to institute a reasonable examination period of no less than six months to examine the procedures and results of Phase I, receive feedback, and consider ways to improve its proposals for Phase II. “An examination period will allow the Commission to address the inaccuracies of the America Roamer data and the centroid method for determining whether an area is eligible or not eligible for Phase II support,” noted Bennet.

RTG supports a Mobility Fund Phase II support distribution mechanism that is structured to help achieve the goal of deploying advanced mobile wireless services to rural areas. To that end, it requests that the Commission place limits on the size of package bids, and scale back the public interest obligations of Mobility Fund support recipients to reflect the realities of mobile wireless networks that are deployed in rural areas.

Additionally, RTG points out that even though consumers are increasingly choosing mobile services over traditional fixed wireline service, only a mere 11 percent of the total high-cost budget is allocated to the Mobility Fund. To truly promote mobile services where Americans live, work, and travel, the Commission should seize opportunities to increase the overall size of the Mobility Fund.

“With so much at stake for rural America, it would be extremely unwise for the Commission to proceed in a hasty manner. Phase II of the Commission’s Mobility Fund is intended to award replacement support for existing ongoing USF support that is being phased down. If the Phase II ongoing support mechanism is not structured correctly, both existing mobile voice and broadband services, and those rural networks that will be built out with Phase I support, will be put in jeopardy,” stated Bennet. “It is critical that the Commission move carefully and deliberately before finalizing the details of Mobility Fund Phase II, and continue working with the wireless industry to craft a successful ongoing support mechanism for mobile wireless services in rural areas,” she added.

About RTG – Headquartered in Washington, DC, the Rural Telecommunications Group, Inc. (RTG) is a trade association representing rural wireless carriers who each serve less than 100,000 subscribers. RTG’s members have joined together to speed delivery of new, efficient and innovative telecommunications technologies to remote and underserved communities. ruraltelecomgroup.org @RTGwireless

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