RWA recently filed comments with the FCC in two interrelated proceedings. First, in response to an FCC Notice of Proposed Rulemaking regarding its Designated Entity and Competitive Bidding rules, RWA filed comments supporting the creation of a spectrum auction bidding credit specifically for rural carriers.  Many rural wireless carriers, including RWA members, are ineligible for the FCC’s bidding credits reserved for small businesses. In fact, just 5 of the 11 rural entities that won AWS-3 spectrum licenses received bidding credits. These bidders, collectively, received less than $1 million of the entire $3.57 billion bidding credits awarded – a deeply concerning figure. A bidding credit specifically for rural carriers 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. RWA’s comments also support: (1) increasing the small business credit revenue thresholds; (2) retaining (rather than increasing) the five-year unjust enrichment period; (3) repealing the annual DE reporting requirement; and (4) retaining the current joint bidding arrangement rules for non-nationwide wireless service providers.

RWA also filed joint comments with NTCA – The Rural Broadband Association in response to the FCC’s Incentive Auction Comment Public Notice – an item seeking input on proposed procedures for the 600 MHz Broadcast Incentive Auction currently scheduled to take place in early 2016. The Associations express support for FCC decisions to: (1) create a spectrum reserve for carriers with minimal low-band (below 1 GHz) spectrum holdings; (2) use Partial Economic Areas, rather than too-large Economic Areas, as the geographic license size; and (3) prohibit package bidding. The Associations also encouraged the FCC to continue its preparation work without delay and hold the Incentive Auction in early 2016 as scheduled.