On December 26, 2018, the Rural Wireless Association filed an Informal Request for Commission Action asking the FCC to investigate the 4G LTE coverage claimed by T-Mobile USA, Inc. as part of the one-time data collection for the Mobility Fund Phase II reverse auction process. The action was prompted by drive testing conducted by RWA members who uncovered that T-Mobile’s data submitted to the FCC regarding its claimed coverage at 5 Mbps or greater download speeds was not accurate or supported. Over 90% of the points tested in the claimed coverage areas failed to meet the 5 Mbps download threshold speed. It has become evident that T-Mobile did not have the requisite backhaul facilities to support 5 Mbps download speeds at the time it submitted its data to the FCC. It further appears that in submitting its claimed coverage as of the January 4, 2018 deadline for submitting actual coverage, T-Mobile relied on the coverage provided by facilities that it built out after the January 4, 2018 deadline.

As part of the requested investigation, RWA has asked the Commission to obtain and analyze information related to the timing of T-Mobile’s cell sites built in rural areas over the past three years, including the dates associated with the installation of power, 4G LTE Radio Access Network, and backhaul capable of supporting 5 Mbps download speeds, and the launch of commercial service. To the extent the Commission determines that data submitted by T-Mobile has been fabricated or has been based on projected future coverage, RWA has demanded that the Commission take appropriate action including, but not limited to, 1) barring T-Mobile from participating in the Mobility Fund Phase II reverse auction; 2) requiring T-Mobile to reimburse challengers for their costs associated with the challenge process; and/or 3) issuing appropriate sanctions for misrepresentation of information submitted by T-Mobile under penalty of perjury.

“By overstating its coverage, T-Mobile (an unsubsidized carrier) prevents these rural areas from being eligible for universal service support. The scale to which this has occurred is a big unknown and must be investigated. RWA members have limited resources and were only able to drive test a small fraction of T-Mobile’s claimed coverage area,” stated Carri Bennet, RWA General Counsel. “The Commission needs to investigate the data submitted by T-Mobile on a wide scale basis and take appropriate action to correct the data. Putting the burdens of continuing to investigate T-Mobile’s misstated coverage on the backs of rural carriers, local governments and individual citizens who do not have the tools or resources to challenge the data is a losing proposition and only serves to harm consumers, especially those living, working and traveling through rural America.”