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'Extraordinarily Expensive'

Carriers Raise Concerns on Parts of FCC's Puerto Rico, Virgin Islands Proposals

Carriers raised concerns in response to an FCC Further NPRM proposing to extend USF support to eligible mobile and fixed carriers in Puerto Rico and the U.S. Virgin Islands, approved by commissioners 4-0 in October (see 2210270046). The proposals fall short of meeting ongoing needs, commenters told the agency, posted Monday in docket 18-143.

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T-Mobile said it used money from the Bringing Puerto Rico Together Fund, approved in 2017, to “make significant investments … to expand and harden the network.” Extend Stage 2 support “until a long-term support mechanism is in place,” T-Mobile urged. “Rather than reducing the amount of Stage 2 support to 25% of current levels … the Commission should continue offering Stage 2 mobile support at current funding levels during the transitional period,” the carrier said.

Stage 2 support, along with capital expenditure investment, “has enabled T-Mobile to install new and replace outdated generators, exchange and increase backup batteries, upgrade technology, and expand 5G coverage above and beyond its [Sprint] merger commitment,” the carrier said. But Hurricane Fiona this year “made clear that additional investments are necessary to ensure both the resiliency of the existing network to protect against future natural disasters and to the continued deployment of advanced communication services in Puerto Rico,” T-Mobile said: The storm “brought heavy rains and caused landslides that hampered roads, uprooted bridges, and caused significant losses across Puerto Rico.”

At one point during Fiona, T-Mobile “was refueling over 250 generators on a daily basis, which required moving approximately 11,000 gallons of diesel fuel,” the company said. “Even though most of T-Mobile’s cell sites in Puerto Rico will be equipped with backup generators and/or battery banks, constant use requires T-Mobile to upgrade and replace them.”

Maintaining existing service levels and investing in network resiliency is a constant challenge in the USVI, and investments can be wiped away by the next major storm -- as Hurricane Fiona recently demonstrated in Puerto Rico,” said Virgin Islands Telephone (Viya). A proposal to end transitional support Dec. 31, 2025, “falls short of achieving the Commission’s goals,” the company said. At that point, 40% of the population likely will have “no provider of last resort to look to for service,” including those living in “the most rural and economically disadvantaged parts of the Territory,” Viya said.

Operations in the USVI “are extraordinarily expensive, with a small population dispersed across three main islands with difficult topography, unpredictable commercial power, and the ever-present risk of major storms,” Viya said: “While service costs are high, revenue potential is low, with an unemployment rate nearly three times higher than the U.S. mainland and a poverty rate 60% higher.”

Puerto Rico Telephone Co. (PRTC) urged the FCC to maintain support at the current levels throughout the transition period. “The recent experience with Hurricane Fiona serves as a reminder that, while there has been improvement since 2017, there is still much to do,” PRTC said. The commission’s proposed reduction in funding levels “would harm the residents of Puerto Rico by significantly hindering PRTC’s ongoing efforts to harden its mobile network, while also delaying 5G deployment,” the company said: “Considering Puerto Rico’s persistent power grid problems and their respective costs for carriers, the Commission should also consider the effect that a funding reduction would have on carriers.”

Competitive carrier Liberty urged the FCC to cut fixed-wireless support while maintaining current levels for mobile providers. “The level of transitional funding that the Commission proposes in the Further Notice will be grossly inadequate to support … continued progress, including the expansion of mobile networks and services to unserved and underserved municipalities and the continued hardening of those networks in Puerto Rico and USVI," Liberty said.