Washington, D.C. – The Rural Wireless Association, Inc. (RWA) has filed an Opposition to an Application for Review filed by Verizon following the Federal Communications Commission’s Wireless Telecommunications and Wireline Competition Bureaus’ wise decision to increase the buffer radius for the Mobility Fund Phase II (MFII) challenge process from 250 meters to 400 meters. In its Opposition, RWA urged the Commission not to vacate the Challenge Procedures Reconsideration Order, and retain the buffer radius extension from 250 to 400 meters

The Bureaus’ decision to extend the buffer radius to 400 meters was made in response to a March 21, 2018 filing by RWA that detailed the burden a challenger would experience as a result of the 250 meter buffer radius. Additional data submitted by RWA has since shown that it would take six to eight full-time employees working 150 days just to collect the data needed to mount a challenge using the 250 meter buffer radius – a tremendous burden on small and rural carriers with small staffs and narrow operating margins.

“The 400 meter buffer radius is critical,” said RWA General Counsel Carri Bennet. “It has turned a completely impossible task into one that is merely tremendously difficult.” RWA’s opposition argues that the 400 meter buffer radius is entirely consistent with the Commission’s challenge process rules, and that – contrary to Verizon’s unsupported assertions – it will not result in widespread successful challenges of areas that are served by unsubsidized qualifying coverage. Further, RWA argues that the 400 meter buffer radius will improve challenge process data accuracy. “A longer buffer radius means that more areas will be measurable using drive tests. More areas that are measurable using drive tests means that more entities will be technically and financially capable of participating in the challenge process. More challenges will yield more accurate coverage data, not less,” said Bennet. “This, will, in turn, yield a more accurate 4G LTE coverage map and help to target USF support in rural areas where it is badly needed.”