Washington, D.C., – The following statement may be attributed to Carri Bennet, Rural Wireless Association, Inc. (“RWA”) General Counsel:
Today, RWA submitted Reply Comments in response to the Mobility Fund Phase II FNPRM urging the Commission to adopt a challenge process that does not unduly burden Challenged Carriers or Challengers, and that is administratively efficient. Rather than burdening all carriers by requiring the resubmission of coverage data everywhere, or burdening Challengers by requiring the submission of extensive unsubsidized coverage data in a too-short time period, the RWA Proposal walks a fine line by requiring additional information where necessary without being overinclusive and inefficient.
Further, RWA urged the Commission to allow Challengers to dispute whether service is truly “unsubsidized,” and adopt a requirement that challenge response propagation maps reflect a signal strength threshold of -85 dBm (RSRP). The Commission should not adopt a minimum challenge area size or restrict challenge process participation only to wireless carriers or government bodies. By imposing such limits, the Commission may inadvertently create a less accurate and robust challenge procedure. RWA also advocated that, regardless of which specific challenge plan the Commission adopts, the burden of proving the existence of unsubsidized coverage at the requisite speeds must rest squarely on the unsubsidized service provider – the party that actually has the information.
There is no program more vital to strengthening and expanding mobile voice and broadband services in rural America than Mobility Fund Phase II – as such, RWA will continue its collaboration with FCC Commissioners and staff to ensure that rural Americans and those traveling through rural America have access to mobile broadband services.