TR Daily Parties Say ‘Neither’ to FCC’s 5G Fund Options
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Friday, June 26, 2020

Parties Say ‘Neither’ to FCC’s 5G Fund Options

The FCC proposal for distributing $9 billion in support for deploying wireless broadband services to rural America is meeting with arguments for hybrid alternatives and different approaches altogether.

Parties were responding to a notice of proposed rulemaking (NPRM) adopted by the Commission over the partial dissents of Democratic Commissioners Jessica Rosenworcel and Geoffrey Starks in April in GN docket 20-32, which proposed a two-phase 5G Fund framework for distributing the support.

Among other things, the NPRM sought input on two possible options for the $8 billion first phase. Under the first option, the FCC would proceed to a reverse auction next year to distribute funding to areas that the FCC believes are unlikely to see 5G deployment absent such support, based on the best information it currently has available, such as the “rurality” of the area, which the agency views as a good proxy for lack of 5G deployment.

The second option calls for delaying the auction until 2023 while the FCC collects better, more granular data through its planned Digital Opportunity Data Collection initiative. The agency’s Democratic Commissioners said the two options present a false choice between speed and accuracy in distributing support (TR Daily, April 23).

In comments filed yesterday, The Rural Wireless Association proposed a “hybrid” three-phase approach to distributing 5G Fund support.

In Phase 0, “$1.5 billion would be allocated to carriers with 500,000 or fewer subscribers currently receiving legacy support to build out 5G in Rural-Urban Commuting Area (‘RUCAs’) codes 5-10. Legacy support levels would be increased from 60% to 90% in exchange for carriers’ commitment to build out 5G networks in these areas. The Phase 0 5G buildout could begin as early as 2021 since it does not involve an auction,” RWA said.

“In Phase 1, a reverse auction which could begin as early as 2021 with buildout beginning as early as 2022, $6 billion would be allocated to provide support to rural areas in RUCAs 5-10, excluding any census tracts served by legacy support carriers electing to receive support in Phase 0,” it continued.

“In Phase II, a reverse auction which could begin as early as 2024, $1.5 billion, plus any leftover support from Phase 0 and Phase 1, would be authorized to assist in further deployment of 5G. Adoption of the RWA proposal will provide small rural carriers the certainty needed to begin deploying 5G immediately in areas where no 5G exists today and where 5G is unlikely to be deployed without 5G Fund support,” RWA explained.

“With respect to demonstrating compliance with performance requirements, RWA opposes any outdoor testing requirement based on grids,” it said, citing the “substantial burdens” such an approach places on support recipients. “The rural areas that would be served by 5G Fund support recipients contain extensive portions that are non-drivable or otherwise inaccessible, and the resources required for testing these areas would be better spent on the deployment of 5G. To the extent drive testing is used, it should be based on in-vehicle measurements rather than stationary outdoor tests,” it added.

Finally, RWA said, “The Commission should not allow unlicensed spectrum to satisfy the spectrum access condition for eligibility and T-Mobile should not be permitted to use any eligible areas for which it might win 5G Fund support to fulfill its previous merger-related buildout commitments.”

Verizon Communications, Inc., also proposed an alternative to the two options outlined in the NPRM. “To realize the full potential of the 5G Fund and target support where it is most needed, the Commission should (1) hold Phase I of the auction in 2022, after it has collected better maps; (2) divide the 5G Fund budget evenly between Phase I and Phase II to leverage lessons learned as the 5G ecosystem develops; (3) and ensure consistency between mapping parameters and test procedures,” it said.

AT&T Services, Inc., said there are “compelling reasons to reject Option A in favor of Option B,” including the fact that “mobile broadband providers are still very much in the midst of deploying 5G to areas where most of the population resides, with the COVID-19 pandemic possibly slowing these providers’ deployment timelines. Under these circumstances, the Commission’s focus should be on completing and implementing the DODC mobile broadband mapping rules as quickly as possible.”

It added that “perhaps most compellingly, Option B is clearly the option that will utilize the funds most efficiently and is consistent with Congress’s explicit directive that the Commission use better data to award new mobile broadband deployment funding—i.e., 5G Fund support.”

AT&T also said that “the Commission’s proposal to validate 5G coverage and speed—modeled on its Mobility Fund Phase II (MF II) challenge process—is misguided and [that] the Commission should, in the first instance, rely on DODC learnings.”

It urged the use of census block groups rather than census tracts as the minimum geographical area for bidding.

T-Mobile USA, Inc., urged the FCC to “build on lessons learned from the Mobility Fund Phase II (‘MF-II’) process and rely on objective measures and/or coverage data from all providers to identify areas eligible for 5G Fund support.”

“In addition, while T-Mobile shares the Commission’s desire to ensure that funding goes to areas that would not otherwise have service, the Commission must not single out T-Mobile to reveal voluntarily highly confidential future build plans. Rather than relying on T-Mobile’s future deployment plans, the Commission should rely on objective data and/or updated coverage maps that reliably predict where the industry as a whole is likely to deploy 5G and to identify areas eligible for 5G Fund support. Trying to induce T-Mobile to disclose its future, competitively sensitive 5G deployment plans without imposing similar requirements on other mobile providers would not provide a complete picture of planned 5G deployments and would be arbitrary and capricious. It is neither good policy nor lawful to single out T-Mobile for disparate treatment from other wireless companies just because it is leading the charge to bring transformative new 5G service to rural areas,” T-Mobile added.

The National Association of Regulatory Utility Commissioners said that the Broadband Deployment Accuracy and Technological Availability (Broadband DATA) Act signed into law earlier this year (TR Daily, March 24), “reflects overwhelming bipartisan agreement that the FCC needs more accurate broadband maps to target subsidy funds.”

NARUC added, “The FCC must require current and accurate maps prior to awarding funds from the 5G Auction. … Funding 5G deployment in rural America is too important not to do right. That means using accurate data.”

Reflecting a resolution adopted at its winter policy summit earlier this year (TR Daily, Feb. 12), NARUC said that “5G Fund dollars should be prioritized for areas that do not have mobile wireless data coverage meeting a 5/1 mbps threshold.”

While supporting the second option, which would require improved broadband data before distributing funding, NARUC said that the NPRM “does not provide an adequate explanation of why the Option B proposal to base the Auction on better data requires a delay until 2023. It’s unclear why the FCC cannot generate updated maps for an auction prior to 2023, when Congress requires the FCC to update the form it uses to collect broadband deployment data from carriers no later than March of 2021.”

In joint comments, SES Americom, Inc., and O3B Ltd. called for technology neutral policies that will “enable satellite services to offer connectivity solutions.”

“This NPRM is seeking to arbitrarily impose a 100 [millisecond] latency standard. The Commission’s proposed latency metrics fail to consider the actual network requirements for all 5G services and could thwart the significant contributions that current and next-generation satellite technologies can contribute,” they said.

“Any latency benchmark the Commission adopts should reflect industry-accepted standards. This will ensure that the Commission does not undermine the reach of quality 5G service by imposing an artificial threshold that ignores the ability of systems with latencies higher than 100 ms to provide real-time applications,” they added.

“Due to the ubiquity, cost-effectiveness, and reliability of satellite service, satellite networks are critical to the rollout of fixed and mobile broadband services, including 5G networks,” they argued.

They also pointed to the ability of satellite-based technologies to continue to provide service to first-responders and consumers when terrestrial networks suffer failures in the fact of natural or man-made disasters. They urged the FCC to “factor in networking resiliency and network deployment time when evaluating performance metrics.”

“The Commission should also adopt an additional set of weighting tiers that incentivize faster network buildout periods. These tiers should permit alternative technologies to be used even if such technologies do not meet the bidder’s latency and speed requirements,” SES and O3B said.

The Nebraska Experimental Testbed of Things (NEXTT) said, “The 5G Rural Fund NPRM demonstrates the FCC’s continued commitment to ensuring the availability of high quality connectivity to all Americans, and its willingness to invest in rural America to ensure that the important benefits of wireless connectivity are available to Americans living and working in the hardest to reach parts of this nation. These goals are shared by the NEXTT team and its efforts to undertake and support research that develops the advanced wireless networks that will enable rural agricultural communities to thrive in our modern, interconnected world. We look forward to engaging with the Commission as it continues to develop this and other important programs, especially as the Commission eventually moves to the development of Phase II of the 5G Rural Fund.”

There were many individuals and groups that filed documents opposing the implementation of the 5G Fund on the grounds that 5G services will pose health risks from electromagnetic radiation. —Lynn Stanton, [email protected]

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