Washington, D.C. – The Rural Wireless Association, Inc. (RWA) is pleased the Commission granted its Petition for Clarification that the Mobility Fund Phase II (MF-II) collocation requirement applies to newly constructed, rather than all, network towers. 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, not a requirement imposed upon them, and RWA appreciates the Commission’s action on this issue.

RWA welcomes the Commission’s rule modification allowing MF-II recipients to reduce the value of a letter of credit (LOC) at a slightly more rapid rate. However, RWA and its members remain concerned that obtaining and carrying the necessary LOCs will still be a burdensome and costly process for small and rural carriers, and tie up capital that could instead be put toward additional wireless broadband deployment.

RWA is disappointed that the Commission refused to front-load MF-II support to better match initial capital outlays. Carriers will have substantial up-front deployment costs at the beginning of the support term. While carriers can take out loans to cover the deployment costs and then seek reimbursement, doing so comes at a price. The anticipated higher interest rates due to inflation will detract from the capital carriers could put toward more deployment.

RWA also disagrees with the Commission’s decision not to increase the MF-II budget. The record in this proceeding overwhelmingly shows that the current budget is insufficient. Unless there is more funding to build this critical infrastructure, many in rural America will continue to go without mobile wireless service – service they need for economic development, public safety, and every day necessities.