Washington, D.C., April 13, 2017 – RWA filed a Petition for Reconsideration of the Mobility Fund Phase II (“MFII”) Report and Order late on Wednesday. RWA’s Petition urges the Commission to reconsider its adoption of a 5 Mbps download area eligibility threshold, stating that it fails to ensure that rural Americans have access to LTE services that are “reasonably comparable” to those in urban areas. “Lowering the threshold for acceptable mobile wireless service will leave rural Americans – and those traveling through rural America – stuck with substandard mobile broadband for at least a decade,” said RWA’s General Counsel, Carri Bennet. RWA instead recommended adoption of a 10 Mbps download and 1 Mbps upload threshold.
RWA further points out the Commission’s failure to establish a 1 Mbps upload standard noting that the Commission only establishes a 5 Mbps download standard which further compromises acceptable service thresholds for rural consumers.
Further, RWA expressed concern that, as the rules are currently written, network towers that have not been subsidized would be subject to MFII collocation requirements. Whether or not to allow collocation on towers built and/or operated absent any universal service support should be a business decision made by individual carriers. It should not be a requirement imposed on MFII recipients that have not used support to build or operate their towers, and particularly not without adequate notice of the Commission’s intention to do so.
RWA also impressed upon the Commission the need to preserve voice service and 911 access in rural areas that lack adequate VoLTE and 3G network voice fallback capabilities. RWA urged the Commission to adopt a MFII support eligibility exception in a limited number of areas to accommodate technological incompatibilities that threaten public safety.
“There is no program more vital to maintaining and expanding mobile voice and broadband services in rural America than MFII,” said Bennet. “Given the program’s significant importance – and substantial ten-year budget – it is tremendously important that the FCC re-examine its Order and correct the flaws.”