The statement below may be attributed to Daryl A. Zakov, RWA’s Assistant General Counsel.

RWA appreciates the Commission’s attention to the issues surrounding the upcoming 600 MHz Incentive Auction, including the examination of its competitive bidding rules and bidding credit eligibility.  Rural wireless carriers, including RWA members, are small businesses that provide wireless service to consumers living in some of most remote parts of the nation – but surprisingly – many are not eligible for FCC auction bidding credits.  In fact, just 5 of the 11 rural entities that won AWS-3 spectrum licenses in the recent Auction 97 received small business bidding credits.  These bidders, collectively, received less than $1 million of the entire $3.57 billion in AWS-3 bidding credits awarded – a deeply concerning figure.

To address this issue, RWA supports efforts to have the FCC award bidding credits to entities that actually qualify as a “rural telephone company” under the Commission’s existing rules, or to a qualified rural telephone company’s subsidiary or affiliate.  A rural telco bidding credit would help to better target bidding credit resources to bona fide small businesses and rural telephone companies, and promote additional competition in the wireless industry – a win-win for consumers.