Existing Mobile Voice and Broadband Carriers Must be Protected in Rural Areas

The Rural Telecommunications Group (RTG), in response to the Federal Communications Commission’s Further Notice of Proposed Rulemaking seeking input on what rules to adopt as part of Phase II of its Mobility Fund, has filed comments with the FCC that promote the deployment of new mobile broadband services to rural markets while still protecting rural consumers who receive crucial voice and data coverage today.

“More than anything else, the Commission should make sure that in its quest to push rural 4G service with Phase II funding it does not inadvertently allow whatever level of mobile voice and data service is in rural markets today to deteriorate,” said Carri Bennet, RTG’s General Counsel. “Existing rural services should not be harmed in any way and rural consumers currently receiving service should be protected at all costs.”

As part of its recommendations to the Commission, RTG encourages the FCC to adopt a rule that would prohibit carriers from blocking their customers from accessing the networks of other carriers when such access covers area unserved by the blocking carrier. A more open roaming environment will make rural carriers less dependent on Mobility Fund support and allow customers of nationwide carriers to access voice and data services in rural markets that they are currently prevented from accessing by some of the largest carriers.

RTG also recommends that the FCC:

• Determine that any provider offering 3G or better service at the time of a Mobility Fund Phase II auction in an area for which it receives Mobility Fund Phase I support is not considered an unsubsidized carrier.
• Establish a date by which it will: (1) clarify whether each Tier I carrier will be classified as subsidized or unsubsidized; and (2) identify areas of eligibility based on whether there is 4G coverage.
• Create a process to ensure that American Roamer data is both current and accurate, and if it is not, allow carriers to challenge the coverage designation.
• Adopt the same road miles standard in both Phase I and Phase II and consider local and unpaved roads, private roads and vehicular trails when calculating linear road miles.
• Consider grouping areas that lack 2G coverage or any form of basic mobile service in an auction separate and apart from those areas in which carriers are seeking to upgrade from 2G, 2.5G and 3G services to 4G services.
• Grant carriers bidding credits for meeting additional criteria that are deemed in the public interest such as meeting the definition of small business and demonstrating rural coverage to low population density areas.

To maintain integrity in the process and to comply with the law, RTG states that only carriers with an ETC designation should be eligible for Mobility Fund support. Finally, RTG suggests that the FCC refrain from adopting any final rulemaking on Phase II support until Phase I has been completed so that the industry as a whole can take any “lessons learned” from the Phase I process and apply those to Phase II.

RTG remains optimistic that the Commission’s Phase I and Phase II Mobility Funds will be effective tools to promote rural mobile broadband while still protecting rural consumers who rely on rural carriers to provide them with voice and data services today in adverse economic and geographical conditions.

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

# # #