Washington, D.C., – The following statement may be attributed to Carri Bennet, Rural Wireless Association, Inc. (“RWA”) General Counsel:
RWA is pleased to learn that the Commission has made several improvements to the Mobility Fund Phase II challenge framework. Adoption of a challenge window longer than the initially-proposed, too-short 60 days will be critical to ensuring that small rural carriers have a legitimate opportunity to challenge areas with overstated coverage. Further, allowing businesses and individuals to submit challenges is a win for consumers. RWA believes that, while the use of an 80% cell edge probability figure for use in the one-time data collection is an improvement over the 70% draft item proposal, it will less accurately represent the consumer coverage experience than using the industry-proposed 90% probability level.
RWA remains concerned at the lack of a 1 Mbps upload threshold to determine MFII support-eligible areas. Upload speeds are crucial to the end user’s experience – particularly in distance learning and telemedicine applications so necessary to ensure that those living in rural America are not left behind. Further, the Commission’s failure to address the CDMA/GSM incompatibility and potential loss of voice fallback will leave mobile consumers traveling in rural America without the voice and 911 services upon which they have previously relied. This issue will remain until VoLTE is deployed in rural America and VoLTE roaming agreements are in place among all carriers, The Commission’s lack of action, and resulting potential loss of service, unnecessarily endanger public safety.