Washington, D.C. – The Rural Wireless Association, Inc. (RWA) welcomes the March 8 letter to Federal Communications Commission (FCC) Chairman Ajit Pai. Like the letter’s signatories, RWA has serious concerns that the FCC’s map showing presumptive eligible areas for Mobility Fund Phase II (MF-II) support is not an accurate depiction of areas in need of universal service support.

First, and as RWA has discussed at length, the Commission’s unambitious threshold for unsubsidized, qualified 4G LTE coverage (download speeds of at least 5 Mbps with no corresponding upload requirement) is insufficient to ensure that rural Americans receive mobile broadband services that are “reasonably comparable” to those available in urban areas. In fact, the Commission itself has determined that a 5 Mbps download speed is simply not good enough to meet the needs of consumers in past proceedings.

Further, even if the Commission’s standard for unsubsidized, qualified 4G LTE coverage was sufficient, RWA agrees with Senators that the map misrepresents the existence of 4G LTE service in many areas. The Commission’s data collection process – a process that RWA opposed – has failed to yield an accurate coverage picture.

Finally, stakeholders cannot rely upon the Commission’s challenge process to adequately address the map’s shortcomings. Of significant concern is the fact that the Commission’s process will rely on a system of square kilometer, rather than square mile, grid squares. In the majority of rural America, roads are situated directly on the borders of a one mile by one mile grid. The Commission’s decision to ignore this reality has yielded a challenge scheme in which thousands of kilometer grid squares lack the necessary road coverage and will therefore be unmeasurable using drive tests. By way of example, 43 percent of one county’s kilometer grid squares would be unmeasurable using drive tests – using a mile grid square, only 3 percent of the same area would be unmeasurable. In a larger, more rural area, RWA found that 80 percent of the kilometer grid squares would be unmeasurable. In the same area using mile grid squares, that figure could be reduced to 46 percent.

“Under the Commission’s rules, small rural carriers will be forced to mount challenges by testing on foot, or via drones, horseback, four-wheeler, or crop duster. This is not the “robust challenge process” rural Americans have been promised,” said Carri Bennet, RWA General Counsel. “The challenge process parameters will impose significant and unnecessary costs on prospective challengers, and allow the Commission’s inaccurate picture of mobile wireless coverage to stand unchallenged in most places. Rural consumers will bear the consequences of these Commission decisions for the next decade. RWA joins Congressional leaders in urging the Commission to revisit its eligibility determinations and challenge process requirements before auctioning $4.53 billion in MF-II support.”