Washington, D.C. – The Rural Wireless Association has filed comments in response to the FCC’s Further Notice of Proposed Rulemaking on the Enhanced Competition Incentive Program.  The ECIP seeks to encourage licensees to partition, disaggregate, or lease spectrum to small carriers and Tribal Nations increasing rural wireless service availability.  While RWA supports the program, RWA has numerous suggestions that will help better achieve the Commission’s goals.

RWA suggestions include: (1) not allowing ECIP benefits to participants in a transaction involving any degree of affiliation; (2) using megahertz rather than percentage when defining the minimum amount of spectrum to make a transaction eligible for ECIP benefits; (3) for rural-focused transactions, allowing the rural area to include a de minimis amount of non-rural area; (4) not limiting transactions under the rural transaction prong to license areas consisting of a Partial Economic Area or smaller; (5) permitting licensees that enter into a qualifying rural transaction prong transaction that exceeds one thousand square miles to utilize up to a 5% bidding credit in a future spectrum auction; (6) adopting a “use it or lose it” provision, whereby any license area in an ECIP transaction that remains unserved at the end of a licensee’s second license term be removed from the licensee’s license area; (7) adopting a 95% coverage requirement; (8) not automatically terminating any license assigned as part of an ECIP transaction where the assignee of the license fails to meet the program requirements; and (9) making any new Wireless Radio Service substantial service construction requirement geography-based rather than population-based.

By adopting these recommendations, the Commission can ensure that all entities, regardless of size or population density, are incentivized to participate in the ECIP and that rural areas are sufficiently served.  For too long, many licensees have neglected their rural license areas, further exacerbating the digital divide.  RWA believes this program can encourage the necessary transactions that can expand telecommunications and broadband service in rural America.

A copy of RWA’s comments can be found here.