RWA filed comments that will help the FCC draft the Nineteenth Annual Report on the state of competition in mobile wireless services.
In its comments, RWA focuses on specific trends in mobile wireless network deployment that impact rural areas, such as the slow implementation of voice over LTE service, the need for legacy CDMA and GSM networks to ensure universal voice coverage, and small rural-based providers’ limited ability to enter into data roaming agreements with nationwide providers.
In response to the sources of mobile wireless coverage data that the FCC has indicated it will use to compile the Nineteenth Report, RWA cautioned the FCC to not over-rely on FCC form 477 data. RWA explained that Form 477 data contains inaccuracies and often overstates available mobile coverage throughout the U.S.
RWA also warned the FCC about its proposal to reduce, and in some cases eliminate, universal service support for mobile wireless services because a substantial loss of support will jeopardize ongoing operations for most, if not all, small rural-based mobile wireless providers.
Additionally, RWA invited the FCC to further examine the impact of two policy choices it made when designing the forward auction portion of the 600 MHz Broadcast Incentive Auction. Those two decisions – to auction licenses based on Partial Economic Areas and award a Rural Service Provider bidding credit – are already showing favorable results, which proves that spectrum auction policy decisions can be used to improve mobile wireless competition.
About RWA – Headquartered in Arlington, Virginia, RWA – the Rural Wireless Association is a trade association representing rural wireless carriers who each serve fewer than 100,000 subscribers. RWA’s members have joined together to speed delivery of new, efficient and innovative telecommunications technologies to remote and underserved communities. For more information visit www.ruralwireless.org