The RWA filed an ex parte in the Mobility Fund Phase II (“MFII”) proceeding expressing concern over a further extension of the deadline challenging LTE coverage for the MFII Challenge Process. RWA instead urged the Federal Communications Commission to address challenge process issues by investigating Verizon’s claimed 4G LTE coverage and requiring Verizon to re-file its coverage map using corrected data.

On November 19, 2018, the National Association of Regulatory Utility Commissioners (“NARUC”) submitted a Motion for an Extension of Time requesting that the Commission extend the MFII Challenge Process for a second time, from November 26, 2018 to March 15, 2019. While RWA agrees with NARUC that the MFII Challenge Process has been fraught with difficulties, it does not support a second deadline extension. Many of RWA’s members have spent millions of dollars and thousands of work hours to participate in the challenge process. An extension through the winter season – a time when difficult weather and treacherous road conditions will make drive testing dangerous in many locations and completely impossible in others – is unlikely to yield a statistically significant increase in test points over what has already been compiled.

Further, extending the deadline while still using Verizon’s map compiled with inaccurate data fails to address the real problem underlying the MFII Challenge Process. Doing so will simply cost prospective challengers more time and money, without yielding appreciably different results. RWA and others have expressed grave concerns regarding the accuracy of Verizon’s coverage data, and RWA continues to believe that the best way to improve the MFII Challenge Process is to investigate Verizon’s claimed 4G LTE coverage and require the re-filing of the map using corrected data.

“Verizon’s overstatement of coverage is the underlying problem, and it has caused tremendous harm to RWA’s membership in the form of millions of dollars and thousands of hours spent to prove nonexistent coverage – coverage that Verizon knows does not exist,” said Carri Bennet, RWA’s General Counsel. “The best way to address the MFII Challenge Process’ shortcomings is to correct the underlying data.”