While we take mobile broadband services for granted in urban environments, many rural Americans still don’t have access to wireless service to keep them connected to family, work and other vital services.   Travel just 75 miles from D.C., and chances are you could find yourself in a small community without wireless voice or broadband coverage. The FCC seeks to address that tomorrow by moving full speed ahead with Mobility Fund II (MFII), a program that will target $4.53 billion in Universal Service funding to bring rural Americans into the mobile broadband age.

More specifically, the Commission will consider rules that will put in place parameters to identify the areas that really need this critical funding. By proposing a one-time MFII-specific data collection and a well-defined challenge process, the Commission addresses concerns about data consistency and accuracy without delaying the program, potentially for years.   The parameters proposed in the FCC’s draft order will better target MFII funding to the areas where consumers have no mobile service rather than permitting these funds to go to areas where such service already exists.

We support the parameters proposed in the item, which will result in more square miles being initially identified as already-served by LTE than other proposals on the record. If a census block is identified as served when in fact it is not, parties may use the challenge process to identify those areas so that they may be deemed eligible for MFII funding. By contrast, if the parameters allow served areas to be identified as unserved, we risk sending scarce MFII funding to areas where it is not necessary because LTE has already been commercially deployed.

And it is critical that the FCC move the MFII process forward with deliberate speed. The current program – which still disburses almost $500 million/year – was voted in 2011 to be phased out by 2016. Moreover, the FCC has found that more than $300 million/year of this support goes to wireless carriers to provide service in areas where one or more competitors are also providing service without subsidy. In other words, those dollars are not supporting any incremental service to rural consumers. And the carriers getting those dollars – which includes AT&T – have long been on notice that those revenue streams would be redirected to MFII.

Inaction on this proceeding simply delays the promise of mobile broadband service to communities without such service today. We support the Commission’s commitment to the MFII program and its proposed framework. It strikes the right balance between the need to collect current coverage data and run an efficient challenge process with the goal of moving quickly to drive more mobile broadband service to rural America.

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