RWA welcomes today’s announcement that the Federal Communications Commission is launching an investigation into whether one or more major carriers violated the Mobility Fund Phase II (MF-II) reverse auction’s mapping rules and submitted false coverage maps. Further, RWA applauds Chairman Pai’s decision to suspend the next step of the challenge process until the investigation has concluded. RWA agrees that the Commission “must ensure that the data is accurate before it can proceed.”

RWA first notified the Commission in April 2018 – less than two months after the initial MF-II eligible area map was released – of Verizon’s overstated coverage, noting that Verizon overstated its coverage in the Oklahoma Panhandle and in other areas of the country. RWA later filed an Informal Request for Commission Action requesting that the Commission investigate the 4G LTE coverage claimed by Verizon and require re-filing of Verizon’s data to correct its overstated coverage. Multiple carriers and a coalition of radio frequency engineering firms have expressed similar concerns. In addition, several members of Congress and NARUC have also weighed in on the exaggerated coverage.

RWA’s concerns about overstated coverage have been borne out by challenge process data. RWA member Panhandle Telecommunication Systems, Inc. drove 124,421 miles (a distance nearly equivalent to driving 5 times around the Earth) during the challenge process, and took a total of 3,605,517 speed tests. Of the total test points collected, 3,232,612 (89.7%) tested below 5 Mbps download speed or did not register 4G LTE service at all. Another RWA member collected 2,684,667 test points, and found that 99.09 percent of those points tested below 5 Mbps download speed or did not register 4G LTE service at all. Yet another RWA member collected 1,485,324 test points, and found that 82.9 percent of those points tested below 5 Mbps download speed or did not register 4G LTE service at all.

Obtaining the drive test data comes at a cost. “Overstated coverage by Verizon and others has caused RWA’s members to spend millions of dollars and thousands of hours to prove a negative,” said Carri Bennet, RWA’s General Counsel. “We know that out of 106 entities that had access to the USAC portal, only 21 submitted challenges. Many entities, RWA members included, made the difficult decision to sit out the challenge process – not because of a lack of interest, but because the overstated coverage across the country made participation prohibitively expensive. To illustrate just how high a barrier to entry there was, three small rural wireless carriers submitted more than 37 percent of the total test points submitted nationwide. This was not the ‘robust’ challenge process that the Commission envisioned.”

RWA thanks Chairman Pai and Commission staff for their attention to this issue, and welcomes a continued dialogue on a matter so important to rural America.