Expand Pool of RDOF Applicants in Unserved Rural, Tribal Areas, Commenters Ask FCC

Baseline broadband performance should not be defined as 25/3 Mbps under RDOF, NTCA said. Instead, the FCC should consider including and weighting four tiers, with 25/3 Mbps redefined as the minimum. The group also wants latency metrics considered so voice communications remain supported as a universal service.

Eliminating requirements for RDOF recipients to offer stand-alone voice services would increase participation, several industry stakeholders said. "When the focus of the program is on providing broadband to unserved areas, it makes little sense to continue to require providers to be certified telecommunications carriers," said NCTA. It asked the FCC to forbear on the requirement that RDOF recipients be designated eligible telecommunications carriers (ETCs.)

NCTA also raised concerns about requiring RDOF recipients to meet predetermined subscriber benchmarks: That changes the RDOF focus from broadband deployment to broadband adoption, and places "the burden of guaranteeing adoption on the provider." The uncertainty over how much support would be needed to spur adoption "could potentially deter bidders," NCTA said.

CenturyLink said requiring providers to ensure a "sufficiently high percentage of consumers take the service is not an appropriate measure of whether participants have made the requisite service available to Americans in high-cost areas at reasonable rates."

Make sure RDOF funds don't go to overbuilders or duplicate other federal or state broadband subsidies, some said. The FCC must consider what impact RDOF will have on participants of its Connect America Fund (CAF), USTelecom said: "The commission can continue to leverage its previous investments and the significant work that USTelecom members have done in rural communities while at the same time ensuring that obligations and funding are commensurate moving forward."

The Wireless ISP Association also supports eliminating requirements to offer stand-alone voice service. "As a practical matter, there are few if any consumers that lack access to voice capability, either through an existing carrier, interconnected VoIP or an over-the-top VoIP application," said WISPA.

Parties differ on how the FCC should tweak its broadband performance requirements. America's Communications Association said the agency "should increase service provider performance requirements over time to ensure rural consumers receive 'reasonably comparable' services to their urban counterparts and adopt a limited subscribership target to incentivize customer signups." ACA said performance tier bid weighting methodology can deter participation in the competitive bidding process if not done well, and limit competition and reduce the cost-effectiveness of the program. Similar past broadband auctions "unduly favored service providers relying on lower-performance tiers (technologies) while discouraging bidding in higher-performance tiers," it said. "Providers only will participate in an auction if they have a reasonable chance of winning."

Future-Proof Performance

Technologies such as fiber that can deliver 1 GB or faster performance "should be weighted more favorably in the reverse auction," Incompas said. The RDOF reverse auction design should "ensure that as much fiber is deployed in rural America as possible," Incompas said. Not only would doing so help deliver "robust fixed broadband networks that are sustainable, scalable, and future proof," Incompas said, but fiber is "the backbone to wireless communications, and with the advent of 5G technology, mobile providers will be dependent on fiber backhaul." Incompas wants the FCC to include in the reverse auction all areas in the U.S. not served with fixed terrestrial broadband service of at least 25/3 Mbps, unless support has been promised under another program.

The FCC should anticipate over the 10-year RDOF term demand for new applications with higher upload speed requirements, such as remote medical procedures and testing, farm auctions, home monitoring, video and the Internet of Things, WTA said.

But WTA also said the FCC should consider giving a substantial bidding credit to existing CAF support recipients if they meet buildout requirements to "avoid potential problems with stranded investment, unpaid construction loans and unrecovered facility costs" from previous broadband infrastructure deployment commitments. This could "maintain and improve the quality of service expected by existing customers while discouraging low-ball bidding strategies that would reduce service quality and customer satisfaction," WTA said. It also supports bidding credits to encourage more deployment of broadband facilities and services on tribal lands.

Bids from high-latency providers should receive higher weights than proposed, ITTA said. Carriers using satellite or other high-latency technologies "must demonstrate that they can provide quality, reliable voice service as a condition of receiving support," it said.

Satellite Broadband at Issue

The proposed latency penalty is excessive, Hughes Networks Systems said. Viasat said the penalty isn't sustainable as a policy matter and is "unlawful." SpaceX said "no sensible IP-based provider would deploy voice-specific hardware in their networks and possibly segregate capacity for a service consumers do not want." Because RDOF will distribute so much money over the next 10 years, the FCC should "carefully consider how to account for numerous burgeoning technologies," such as 5G mobile broadband, wireless ISPs and non-geostationary orbit satellites, the company said.

"Satellite broadband has an important role to play in exceptionally high-cost or isolated areas in which the support required to deploy terrestrial broadband would be prohibitive," Verizon said, but it wants the FCC to restrict satellite broadband providers to bidding "for exceptionally isolated or sparsely-populated areas,"

Allow broadband providers to bid on census blocks rather than require commitments to building out larger areas, many recommended.

The FCC should add a limited crowdsourcing challenge to contest the reported availability of 25/3 Mbps service to identify census blocks where such broadband service is either unavailable or "only nominally available" due to bad data from Form 477 reports, said the National Rural Electric Cooperative Association. "In connection with the CAF II auction, many cooperatives were bewildered to learn that areas in their communities were reported as served, when, in fact, the census blocks were not served," it said.

Hold a single RDOF auction after it corrects the broadband service location mapping system, Windstream said. Frontier also wants the FCC to wait for better mapping data, it said: "The best course of action to maximize the benefits from the RDOF is to utilize the most current and accurate broadband mapping data as possible."

Reply comments are due Oct. 21.