Letter to Ajit Pai - Improve Rural Broadband Support for Cellphone Service

Letter

Dear Chairman Pai:

As you know, many of us have expressed concern about the accuracy of the Federal Communications Commission's map of eligible areas for Mobility Fund Phase II Support (MFII). This map is intended to reflect areas that lack unsubsidized mobile 4G LTE service, but it unfortunately falls short of an accurate depiction of areas in need of universal service support. Therefore, the FCC's challenge process will play an outsized role in determining appropriate eligible areas for MFII support. Communities in our states that are not initially eligible or successfully challenged will be ineligible for up to $4.53 billion in support over the next 10 years, exacerbating the digital divide and denying fundamental economic and safety opportunities to rural communities.

While you have noted that state, local, and Tribal governments can participate in the challenge process, absent additional direction, they may remain unaware or unprepared to do so. We appreciate and encourage additional outreach to state, local, and Tribal governments on how they can participate in the challenge process. However, with less than 100 days remaining and additional state outreach presentations not yet completed, MFII challengers will struggle within the current timeframe to provide requisite information that will correct significant flaws in the current map. Additionally, the parameters for challenges have already changed once during the existing challenge timeframe through the Order on Reconsideration on April 30, 2018, altering existing measurements for challenges.

In recent testimony before the Senate Appropriations Committee, you expressed that the FCC has "some flexibility [for] an extension of time" to ensure sufficient time for state and local governments, as well as carriers and other potential challengers, such as state farm bureaus, to fully participate in the process. To provide this additional time and encourage participation in the challenge process, we urge you to extend the current challenge process window by 90 days.

The MFII process presents an opportunity to take significant steps to address the digital divide and preserve and expand mobile broadband in rural areas. We strongly urge you to ensure this opportunity is available to all communities deserving support through compiling accurate data that reflects our constituents' experience, including providing additional time for challengers to submit data, conducting additional information sessions for state, local, and Tribal governments, and providing Congress with an update on final eligible areas before conducting an auction of support.

Sincerely,