Before the Federal Communications Commission

Washington, D.C. 20554 In the Matter of ) ) Establishing a 5G Fund for Rural America Universal Service Reform – Mobility Fund

) ) )

GN Docket No. 20-32 WT Docket No. 10-208 (closed)

COMMENTS OF THE RURAL WIRELESS ASSOCIATION, INC.

Outside Counsel: Michael Bennet Womble Bond Dickinson (US) LLP 1200 19th Street, NW, Suite 500 Washington, DC 20036 (202) 857-4442 Michael.Bennet@wbd-us.com

Carri Bennet, General Counsel Stephen Sharbaugh, Legislative & Policy Analyst 5185 MacArthur Blvd., NW, Suite 729 Washington, DC 20016 (202) 551-0010 legal@ruralwireless.org

June 25, 2020

mailto:Michael.Bennet@wbd-us.commailto:legal@ruralwireless.org

Table of Contents

Page No.

Summary ............................................................................................................................. i

I. The Commission Should Adopt a Hybrid Approach to the 5G Fund for Rural America that Relies in Part on Legacy Support to Allow for Accelerated 5G Rural Buildout .........................................................1

II. Framework for the 5G Fund ...................................................................................8

III. Public Interest Obligations and Performance Requirements ..............................11

IV. Eligibility Requirements ..........................................................................................19

Summary

The Rural Wireless Association, Inc. (“RWA”) supports the establishment of a 5G Fund. 5G is

completely lacking in rural America and the approach set forth in RWA’s comments will incentivize rural

wireless carriers to immediately begin the targeted buildout of 5G service to rural areas that lack coverage

as early as 1st quarter, 2021.

RWA’s three phase approach will provide 5G service in areas served by rural carriers who

currently receive legacy support should they opt to meet stringent 5G buildout requirements. Under the

first phase of RWA’s approach, 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. 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. 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.

With respect to demonstrating compliance with performance requirements, RWA opposes any

outdoor testing requirement based on grids, such a requirement imposes substantial burdens 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.

i

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.

ii

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Before the Federal Communications Commission

Washington, D.C. 20554

In the Matter of ) )

Establishing a 5G Fund for Rural America Universal Service Reform – Mobility Fund

) ) )

GN Docket No. 20-32 WT Docket No. 10-208 (closed)

COMMENTS OF THE RURAL WIRELESS ASSOCIATION, INC.

The Rural Wireless Association, Inc. (“RWA”)1 submits these comments in response to

the Notice of Proposed Rulemaking and Order (“NPRM”) adopted by the Federal

Communications Commission (“FCC” or “Commission”) in the above captioned proceeding.2

This proceeding is an important step on the road to delivering the critical benefits of 5G service

to rural America, and RWA appreciates the opportunity to comment on structuring the fund to

help ensure that these benefits are delivered as comprehensively and as soon as possible.

I. The Commission Should Adopt a Hybrid Approach to the 5G Fund forRural America that Relies in Part on Legacy Support to Allow forAccelerated 5G Rural Buildout

The NPRM seeks comment on two approaches to distribute the 5G Fund for Rural

America (“5G Fund”) – Option A and Option B, as well as an alternative approach proposed by

RWA.3 Both Option A and Option B, while well intentioned, have flaws that will delay the

targeted provision of 5G service to rural areas that currently lack it. Meanwhile, RWA’s

1 RWA is a 501(c)(6) trade association dedicated to promoting wireless opportunities for rural telecommunications companies who serve rural consumers and those consumers traveling in rural America. RWA’s members are small businesses serving or seeking to serve secondary, tertiary, and rural markets. Each of RWA’s member companies serves fewer than 100,000 subscribers.

2 Establishing a 5G Fund for Rural America; Universal Service Reform – Mobility Fund, Notice of Proposed Rulemaking and Order, GN Docket No. 20-32, WT Docket No. 10-208 (closed), rel. April 24, 2020 (“NPRM”).

3 NPRM at par. 20-39, 93.

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proposed “Phase 0” approach, which incorporates elements of both Option A and Option B,

incentivizes carriers to immediately begin the targeted buildout of 5G service to rural areas that

desperately need it.

Option A and Option B

Option A calls for a two-phased approach that would begin as early as 2021. In Phase 1

of Option A, there would be funding of up to $8 billion and the Commission would rely on the

concept that 5G has only been deployed in urban areas. RWA agrees that 5G is a very new

service, to date 5G has been built out only in the largest metropolitan areas, and is not currently

deployed outside of urban areas.4 RWA has reviewed the eligible market areas defined by the

FCC (Rural-Urban Commuting Areas (RUCAs) codes 5-10) and has determined that there

currently is no 5G coverage in any of these areas.5 RWA does not expect 5G coverage in any of

these areas absent support.6 However, the issue with Option A’s limitation to RUCAs 5-10 is

4 According to T-Mobile’s website, 5G is currently deployed in limited areas in the following six urban areas: New York, Los Angeles, Las Vegas, Atlanta, Cleveland and Atlanta (https://www.t-mobile.com/devices/samsung-galaxy-s10-5g). Verizon’s website shows it has deployed 5G in limited portions of the following 35 urban areas: (Atlanta, Boise, Boston, Charlotte, Chicago, Cincinnati, Cleveland, Columbus, Dallas, Denver, Des Moines, Detroit, Grand Rapids, Greensboro, Hampton Roads, Hoboken, Houston, Indianapolis, Kansas City, Little Rock, Los Angeles, Memphis, Miami, Minneapolis, New York City, Omaha, Panama City, Phoenix, Providence, Salt Lake City, San Diego, Sioux Falls, Spokane, St. Paul, Washington D.C) (See https://www.verizon.com/5g/coverage-map/); AT&T’s website shows that it has deployed 5G (dubbed 5G+)in select portions of the following 35 urban areas: Atlanta, Austin, Baltimore, Charlotte, Cleveland, Dallas, Detroit, Houston, Indianapolis, Jacksonville, King of Prussia, Las Vegas, Los Angeles, Louisville, Menlo Park, Miami, Miami Gardens, Nashville, New Orleans, New York City, Oakland, Ocean City, Oklahoma City, Orlando, Philadelphia, Phoenix, Raleigh, Redwood City, San Antonio, San Bruno, San Diego, San Francisco, San Jose, Waco, West Hollywood. (See https://www.att.com/5g/consumer/ ).

5 To verify RWA’s assessment that no 5G exists in RUCAs 5-10, RWA challenges any carrier to come forward to demonstrate that it has deployed 5G in RUCAs 5-10.

6 RWA notes that it does not expect T-Mobile to build out 5G in these areas as part of its merger specific rural 5G build out commitments which are population-based not geographic-based. See In re Applications of T-Mobile US, Inc., and Sprint Corporation For Consent to Transfer Control of Licenses and Authorizations, Memorandum Opinion and Order, Declaratory Ruling, and Order of Proposed Modification, 34 FCC Rcd 10578, 10697-98, para. 270 (2019); see also Notice of Ex Parte of T-Mobile USA, Inc., GN Docket No. 20-32 (filed Apr. 15, 2020) at p. 2 (“T-Mobile’s 5G merger commitment is population-based and does not commit T-Mobile to deploy 5G to a defined geography.”).

https://www.t-mobile.com/devices/samsung-galaxy-s10-5ghttps://www.t-mobile.com/devices/samsung-galaxy-s10-5ghttps://www.verizon.com/5g/coverage-map/https://www.att.com/5g/consumer/

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that there are also areas in RUCAs 3-4 that may not receive 5G services without high cost

support being available to support such areas. Thus, it is possible that under a pure Option A

approach, there will be areas that are more densely populated that will not receive 5G service.

Under Option B, the Commission would determine areas eligible for 5G Fund Phase I

support only after collection and processing new mobile broadband coverage data from carriers,

which the Commission recognizes “would also be likely to significantly delay the Phase I

auction and disbursement of high-cost support to rural areas, including to those areas that do not

currently receive support.”7 Specifically, the Commission “anticipate[s] that the earliest we

could conduct the 5G Fund Phase I auction after collecting new coverage data under the Option

B approach would be sometime in 2023.”8 Apart from the substantial burdens that such a data

collection program and challenge process based on the submitted data would impose on rural

carriers, such delay would unnecessarily harm the public by delaying the initial deployment of

5G service to currently unserved rural areas.

RWA Hybrid Proposal

RWA’s proposal uses elements of Option A and Option B. RWA’s proposal involves

three phases: Phase 0, Phase 1, and Phase 2. The proposal will provide rural carriers who

currently receive legacy support an opportunity to continue to receive that support in exchange

for meeting 5G buildout requirements. Rural carriers are uniquely suited to take on this

important task as they have proven track records in deploying commercial, next-generation

wireless networks with their highly trained, local workforce and have existing knowledge of

7 NPRM at par. 37.

8 Id. at par. 37, n. 68.

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local community needs.9 RWA’s proposed framework will also prevent subsidizing multiple

carriers in the same market area and considers T-Mobile’s rural 5G buildout commitments that

span into 2026.

Phase 0

RWA proposes that in Phase 0, dubbed the “5G Small Carrier Fund,” $1.5 billion be

allocated for carriers with 500,000 or fewer subscribers currently receiving legacy support.

Although current legacy support levels are frozen at 60%, RWA proposes that the legacy support

levels would be increased up to 90% in exchange for carriers’ commitment to build out 5G

networks.10 The amount of support legacy carriers receive might be affected by the

Commission’s proposed adjustment factors. The adjustment factors may increase the amount of

support auction winners receive in certain areas, based upon the terrain and market demand for

broadband services. Whether the Commission would apply the adjustment factors to legacy

carriers’ current levels of legacy support, considering the areas under Phase 0 would not be

subject to an auction, is unknown. In RWA’s view, there is no need to apply an adjustment

factor to Phase 0. Phase 0 carriers are extremely familiar with their service areas, know exactly

what areas they would need to serve to meet the requirements of the 5G Small Carrier Fund, and

9 See generally Notice of Ex Parte of RWA, GN Docket No. 20-32 (filed June. 24, 2020).

10 RWA has reviewed data available through the Universal Service Administration Company and compiled a list of legacy support recipients that RWA believes to have fewer than 500,000 subscribers. Attachment 1 lists these companies and their annual levels of legacy support based on 60% of the baseline support awarded under the FCCs old identical support rule. See USF/ICC Transformation Order, para. 519. The USF/ICC Transformation Order eliminated the old identical support rule and ratcheted universal service support down by 20% in 2012 and another 20% in 2013, where it has remained frozen pending the FCC holding the Mobility Fund Phase II Auction, which was moth-balled, and now pending resolution of the instant proceeding. RWA calculated the amount each small company would receive if the FCC were to increase the amount of support up to 90% of the original baseline support and determined that approximately $1.5 billion over a ten-year period would be needed if every small legacy support recipient made the determination to upgrade to 5G within portions of their current service areas that are located in RUCAs 5-10.

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would not need an adjustment factor to incent them to serve particular areas provided sufficient

universal service support is available.

In terms of other obligations, carriers would be required to identify where they are

targeting their legacy support by census tract and could only target areas that are defined as rural

using RUCA codes 5-10 and that are substantially within the current area served by the legacy

support recipient.11 The carriers eligible for Phase 0 would receive this support over a 10-year

term. RWA proposes that legacy carriers commit to deploying 5G 3GPP Release 15 or higher by

year 4 (based on 40% of the geography), 3GPP Release 17 or higher by year 8 (based on 60% of

the geography) and 75% by year 10 (based on geography) utilizing 7 Mbps download and 1

Mbps upload speeds measured at the cell edge and speeds of 35/3 Mbps within the defined

predicted area.12

RWA also proposes that there would be no overlap in support. To the extent eligible rural

carriers are receiving overlapping support today, they would allocate support using an allocation

methodology based on the percentage of geography, road miles and/or the number of POPs

covered to separate out overlapping areas based on census tracts or risk loss of support for the

areas of overlap and having the area go to auction. RWA submits that allowing overlapped areas

to be negotiated by the stakeholders during a predetermined window will solve the overlap. To

the extent it does not, the census tracts would be considered unserved, and legacy support would

11 RWA recognizes that use of census tracts to target support may result in such areas not matching up completely with a legacy support recipient’s served area. RWA requests flexibility in identifying the census tracts to which support would be targeted. To the extent that 25% of the census tract is within the current service area of a legacy support recipient, then the entire census tract should be eligible if selected.

12 RWA justifies these buildout requirements as less stringent than Phase I buildout requirements because Phase 0 will be occurring ahead of Phase I and 5G services are still in the process of being developed and refined. Those carriers participating in Phase I of the reverse auction will begin buildout of their 5G networks two to four years after those legacy support recipients committing to Phase 0. RWA is also proposing that a higher release of 3GPP be implemented by legacy support carriers by the latter part of the funding period (i.e., 3GPP release 17 which is scheduled to be available in 2021). See https://www.3gpp.org/release-17 (last visited June 25, 2020).

https://www.3gpp.org/release-17

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be removed. The overlapped “disputed” census tracts would then be included in the Phase I

auction.

Phase 1

In Phase 1, which could begin as early as 2021, if the Commission selects Option A using

RUCAs 5-10, RWA proposes that $6 billion be allocated to provide support to rural areas,

removing any census tracts served by legacy support carriers electing to receive support in Phase

0. Only one recipient per market would be permitted to receive support.

Phase 2

RWA proposes, in Phase 2, which could begin as early as 2024, that $1.5 billion, plus

any leftover support from Phase 0 and Phase 1, would be authorized to assist in further

deployment of 5G, 3GPP Release 17 or higher. RWA recommends that the coverage analysis

prior to the Phase 2 auction be focused on: (1) the FCC’s Digital Opportunity Data Collection

(Option B); (2) the FCC’s Precision Agriculture Task Force Analysis; and (3) T-Mobile’s rural

5G merger-specific build out commitments which should be fully disclosed to the FCC by 2024

and cover projections through 2026. In regard to T-Mobile’s commitments, by 2024, T-Mobile

will already be obligated to cover 84% of the rural population and 2.4 million rural square miles.

When such areas can be built out without universal service support, it is important that Phase 2

funding not be used to overbuild in areas where T-Mobile has deployed 5G (at least 3GPP

Release 15 or higher), though RWA notes that many of the T-Mobile-defined rural areas may not

be defined as “rural” using RUCAs 5-10 as T-Mobile never provided a definition for rural areas

in its merger specific commitments.

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Eligible Areas

RWA supports the use of RUCAs 5-10 to define eligible areas. The Commission has

proposed a rational and straightforward way to define eligible rural areas. RUCAs 5-10 are so

rural in nature that they are likely to never be built out with 5G absent a high cost subsidy.13 By

selecting clear bright line criteria and with the knowledge that there is limited deployment of 5G

in select portions of select urban areas,14 the FCC has landed on a method for ensuring that

universal service support is targeted to areas where there is no 5G coverage today or likely to be

in the future (absent support), thereby targeting 5G support where it is needed the most. This

will allow 5G funds to be disbursed to needed areas with certainty and in an expedited manner.

Public Interest Benefits of RWA Hybrid Proposal

Under RWA’s proposal, small rural carriers will be provided the certainty needed to

begin deploying 5G immediately in areas where no 5G exists today and where 5G is unlikely to

come without this funding. Rollout of 5G under Phase 0 could begin as early as 2021. Legacy

support recipients have been good stewards of the universal service funds received and should be

encouraged to continue their work of bringing advanced mobile services to rural America.15

13 Pursuant to the U.S. Department of Agriculture, Rural-Urban Commuting Area Codes, https://www.ers.usda.gov/data-products/rural-urban commuting-area-codes/ (last visited March 12, 2020), RUCA 5 is defined as “micropolitan high commuting: primary flow 30% or more to a large Urban Cluster;” RUCA 6 is defined as “micropolitan low commuting: primary flow 10% to 30% to a large Urban Cluster;” RUCA 7 is defined as “small town core: primary flow within an Urban Cluster of 2,500 to 9,999 (small Urban Cluster);” RUCA 8 is defined as “small town high commuting: primary flow 30% or more to a small Urban Cluster;” RUCA 9 is defined as “small town low commuting: primary flow 10% to 30% to a small Urban Cluster;” and RUCA 10 is defined as “rural areas: primary flow to a tract outside an Urban Area or Urban Cluster.” NPRM at par. 29, notes 50, 51. Given the low population density and the distance from an urban area, RUCAs 5-10 provide a rational measure of the rural nature of a geographic area and the need for support to provide for 5G deployment.

14 See footnote 4, supra (demonstrating 5G coverage by AT&T, T-Mobile, and Verizon – the three nationwide carriers).

15 See generally Notice of Ex Parte of RWA, GN Docket No. 20-32 (filed June. 24, 2020).

https://www.ers.usda.gov/data-products/rural-urban%20commuting-area-codes/

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No 5G is available in RUCAs 5-10 today so there is no threat of targeting 5G Rural

Funds to areas where 5G already exists. Spending $6 billion (or two thirds of the fund) will

jump start the provision of 5G in rural areas not currently served as early as 2022. Holding back

$1.5 billion for Phase 2 until 2024 or later, until after better mapping data exists, the Precision

Agriculture Task Force has completed its mission, and T-Mobile has most of its rural 5G

coverage areas built or mapped out, will ensure 5G support is not deployed in areas that would

be served absent support. In addition to the $1.5 billion, any funds not utilized in Phase 0 or

Phase 1 could be repurposed to Phase 2.

Under RWA’s proposal, 5G funds could be awarded in Phase 0 by 1st Quarter 2021, with

the auction for Phase 1 by the end of 2021, and Phase 2 following after the mapping data is

collected and refined. This will greatly accelerate the rollout of 5G to rural unserved areas,

compared with utilizing just the Option A or Option B approach, while still incorporating

beneficial elements of each approach.

II. Framework for the 5G Fund

Term of Support

RWA supports the proposed ten-year term of support. Anything less than ten years is too

short a period to allow carriers to recover the substantial investment required to build out a 5G

network.

Budget

As discussed above, RWA proposes a $1.5 billion budget for continued support to legacy

carriers with fewer than 500,000 subscribers. Although RWA proposes a different breakdown of

the total 5G fund budget for the various phases, RWA supports the proposed $9 billion total

budget for the 5G Fund and the proposed reservation of $680 million for Tribal lands. RWA

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also supports the exclusion of Alaska Mobile Plan areas, Puerto Rico, and the U.S. Virgin

Islands as those areas already receive high cost support under existing programs.

RWA’s Phase 0 proposal discussed above addresses the NPRM’s questions about the

possible reduction of the total Phase I budget by an amount equivalent to the amount necessary

to cover the overall phase down of legacy support. Under RWA’s proposal, $1.5 billion would be

budgeted for eligible legacy support recipients (i.e., those with 500,000 or fewer subscribers),

with any leftover amount should an eligible legacy support recipient opt not to build out 5G

added to the proposed $6 billion budget for Phase I. Larger carriers receiving legacy support

would have their support transitioned over a five-year period or less if areas served receive

winning bids in the reverse auction as proposed in the NPRM. RWA also supports the proposed

budget of at least $1.5 billion for Phase II. As discussed above, RWA specifically proposes a

budget of $1.5 billion (plus any leftover support from Phase 0 and Phase I) for Phase II.

Minimum Geographic Area for Bidding

RWA supports the use of census tracts as the minimum geographic area for bidding.

RUCAs are census tract based, which makes census tracts appropriate as a minimum geographic

area of bidding. RWA also supports the proposal to remove any census tracts that have de

minimis eligible areas, defined as an area of one square kilometer or less within the census tract.

Auctioning these areas would provide a windfall to those already serving the majority of the

census tract.

Adjustment Factor

The proposed adjustment factor should not be applied to Phase 0. Legacy support

recipients know these areas well having served them for the past ten years or more and are best

positioned to allocate their current support to each census tract for the provision of 5G. As long

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as these census tracts are within RUCAs 5-10 and the legacy support amounts in the aggregate

per legacy support recipient are at 90% or less in total of the baseline level of support under the

old identical support rule,16 then the legacy support recipient should be allowed to dictate how

much support is allocated to each census tract in which it commits to build 5G and meet the

legacy support recipient build out benchmarks discussed above.

Geographical Flexibility for Legacy Support

The FCC should allow a mobile eligible telecommunications carrier (“ETC”) receiving

high-cost support for a particular subsidized area the flexibility to use such support for the

provision, maintenance, and upgrading of facilities and services within any of the designated

service areas for which it received legacy high-cost support within each state that support is

provided. In Phase 0, legacy support carriers would inform the FCC where the support is to be

disaggregated and targeted within RUCAs 5-10. Legacy support carriers, who have an intimate

familiarity with their local service territory, should be able to provide 5G service anywhere

within that territory tied to their commitment to buildout to 85% by year ten as discussed below.

Disaggregation of Legacy Support

Under Phase 0, each eligible legacy support carrier will need to determine the amount of

legacy support needed to continue to operate its legacy network and set aside a portion of its

support to maintain and operate the legacy network(s) outside of RUCAs 5-10. The legacy

support carrier should continue to get this disaggregated amount for five years to be applied to its

legacy network. The remaining amount would then be applied to build out 5G in census tracts

located in RUCAs 5-10 over a ten-year period as specified by the legacy support carrier. At the

end of the five-year period, the legacy support recipient could then commit to use the funds to

16 See Attachment 1 for calculation of maximum amount of support for each carrier utilizing 90% of the baseline amounts under the old identical support rule for legacy support recipients with 500,000 or fewer subscribers.

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upgrade or expand 5G in areas that do not have an unsubsidized carrier serving them as

evidenced by the FCC’s data collection maps contemplated under Option B that have not

received funding pursuant to a reverse auction for the 5G Rural Fund. To the extent there are not

sufficient unserved areas to target the funding to, the legacy support recipient’s funds would

transition back to the 5G Rural Fund for Phase II or some other purpose.

III. Public Interest Obligations and Performance Requirements

Initial Report

RWA supports the Commission’s proposal to have legacy support recipients file an initial

report describing their current service offerings in their subsidized service areas and how the

legacy support received is being used.17 This information will help the Commission ensure that

support is actually being used for its intended purpose. Any reporting requirement adopted by

the Commission should require legacy support recipients to demonstrate that support is being

used to expand and/or upgrade the network if the Commission intends to allow legacy support

recipients to continue receiving support. In the event, legacy support is phased down before five

years, there is no need for a reporting requirement.

Public Interest Obligations and Performance Requirements for Legacy Support

Recipients

The NPRM proposes to require legacy support recipients to provide 5G broadband

service that meets the established requirements for legacy support recipients to at least 85% of

the square kilometers in their subsidized service areas in each state by the end of the fourth full

calendar year. The FCC believes that this can be accomplished in four years, but does not

17 RWA notes that this is in line with the survey it recently took of its membership which gathered data to demonstrate the long history and success its small rural carrier members have had in using legacy support to build, expand and upgrade their networks from 2G to 3G to 4G LTE.

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account for what happens after four years to fund the continued support and maintenance of the

5G network. This is why it is critical to allow the legacy support to continue beyond the fourth

year. Legacy support recipients must have certainty and predictability to invest in their networks

without risking support being removed after five years. Under RWA’s proposal, the support

allowed in Phase 0 would continue for ten years. Building out a 5G network is much more

complex and time consuming than building out prior generation networks. The schedule

proposed in the NPRM is too aggressive and will be too difficult for legacy support carriers to

meet with 5G. RWA proposes instead that the Commission require legacy support recipients to

meet applicable requirements (cell edge speeds of 7 Mbps upload, 1 Mbps download; 100

millisecond latency; and deployment of 3GPP release 15 or higher in all cell sites and sectors)

for 40% of the square kilometers in their subsidized service areas in each state by the end of year

four, 60% by the end of year six, and 85% by the end of year ten.

Annual and Interim Reporting Requirements for Legacy Support Recipients

RWA agrees that current mobile recipients of legacy high-cost support should be required

to file annual and interim reports on how legacy support is being used and certify to compliance.

Such reports will allow the Commission to ascertain the efficacy of its program. RWA also

agrees that legacy support recipients that receive a de minimis amount of support should be

exempt from public interest obligations and performance requirements, with the caveat that the

exemption not apply where the carrier chooses to opt in to Phase 0 and continue to receive

support for 5G for the ten-year period. De minimis in this context should be defined as less than

$100,000 per year with a certification from the legacy support recipient that the de minimis funds

are being used for ongoing support and maintenance of 2G, 3G, and/or 4G LTE networks and

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that the support for these networks will be phased out within 5 years or less based on the 5G

Rural Fund auction results.

Ensuring Auction Competitiveness

The NPRM asks how the Commission can ensure that legacy support recipients are

incentivized to participate in the auction, regardless of whether they receive legacy support.

Legacy support recipients can utilize their existing infrastructure to serve new areas with 5G, and

the resulting efficiencies provide an incentive to such carriers to participate in the auction

because they are able to leverage existing infrastructure such as towers, battery backup,

generators, backhaul, and 5G ready LTE networks, etc.

Public Interest Obligations and Performance Requirements for 5G Fund Support

RWA supports the NPRM’s proposal to require 5G Fund support recipients to provide

mobile, terrestrial voice and data services that comply at a minimum with 5G-NR technology as

defined by 3GPP Release 15. 3GPP, Release 15 is the current available release. While future

releases are expected, a baseline release is required and should be established by the FCC to set a

standard for 5G. Relying on speeds and latency measurements alone as a measurement for 5G

could allow some 4G LTE networks to qualify. RWA members have reported that in less dense

areas where excess capacity exists it is not uncommon to get 35/3 Mbps speeds and latency of

100 ms round trip. The Commission should ensure that 3GPP, Release 15 is deployed and that

5G devices are available to operate on the 5G network.

RWA conditionally supports the proposal that support recipients be required to provide

service at reasonably comparable rates and allow collocation and voice and data roaming through

the 10-year support term. Specifically, RWA supports this proposal with respect to collocation

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only to the extent that the tower can support multiple carriers. Any reinforcement or upgrade

costs would have to be borne by the last carrier desiring to collocate on the tower.18

With respect to performance benchmarks for 5G Fund support recipients, RWA proposes

the same benchmarks as those discussed above in connection with legacy support recipients. As

such, auction winners would be required to meet applicable requirements (cell edge speeds of 7

Mbps download, 1 Mbps upload; 100 millisecond latency; and deployment of 3GPP release 15

or higher in all cell sites and sectors) for 40% of the square kilometers in their subsidized service

areas in each state by the end of year four, 60% by the end of year six, and 85% by the end of

year ten.

The NPRM asks whether the FCC should adopt an early service milestone which would

allow a support recipient to reduce the value of its letter of credit (“LOC”) if it offers service that

meets the established 5G performance requirements in at least 20% of the total square kilometers

in its winning bid areas in a state by the end of year two. RWA supports this concept and

believes the LOC should be reduced by 20% when this criterion is met. RWA believes the LOC

should be further reduced by another 20% at the end of four years provided the recipient has met

its 4 year 40% benchmark coverage and by another 20% at the end of 6 years provided the

recipient has met its 60% coverage benchmarks.

18 ANSI/TIA-222-G standards for wind loading requirements on towers increase the costs of collocation due to the need for tower reinforcement. See Structural Standard for Antenna Supporting Structures and Antennas, ANSI/TIA-222-G. Tower reinforcement can be costly ($100,000 or more) and the costs of such reinforcement should not be borne by the tower owner even if universal service support is used to build and maintain the tower. ANSI/TIA-222-G standards for wind loading requirements on towers increase the costs of collocation due to the need for tower reinforcement. See Structural Standard for Antenna Supporting Structures and Antennas, ANSI/TIA-222-G. Tower reinforcement can be costly ($100,000 or more) and the costs of such reinforcement should not be borne by the tower owner even if universal service support is used to build and maintain the tower. The new ANSI/TIA-222-H standards may also increase costs due to the need to analyze the antenna mount design, and conduct additional inspection requirements. See Structural Standard for Antenna Supporting Structures and Antennas and Small Wind Turbine Structures, ANSI/TIA‐222-H. Carriers will likely need to replace mounts and possibly upgrade platforms.

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Data Speeds

RWA supports the adoption of required data speeds of 35/3 Mbps. The NPRM asks

whether higher speeds would be feasible for rural areas, given the spectrum available to carriers,

and whether the benefits to rural consumers of requiring higher network speeds outweigh the

potential costs of meeting those requirements. Because 5G can be used for so many different

purposes and is envisioned to connect things to broadband not just people, RWA cautions the

FCC not to just focus on speed. Speed is not the only measurement for defining 5G. Latency is

also a measurement and in lowering latency, the trade-off may be lowering speed especially in

M2M applications and automation. In rural areas, this may also mean telehealth application,

precision agriculture applications and oil and gas operations, among others. Given the variety of

5G uses and the spectrum being utilized to support 5G in rural areas for these different

applications, there is no one size (or speed) that fits all. For simplicity, RWA agrees that

utilizing a 35/3 Mbps speed and a 100 ms roundtrip latency is the best approach and will be a

clear indication that achieving such speeds and latency, coupled with 3GPP release 15 or higher

being deployed will evidence 5G coverage in rural areas.

Minimum Cell Edge Requirements and Latency

RWA supports the NPRM’s proposal to require that carriers deploy service in eligible

areas with a minimum cell edge download speed of 7 Mbps and minimum cell edge upload speed

of 1 Mbps, with a 90% probability and a 50% cell loading factor. RWA also supports the

proposal to require latency of 100 ms or less per round trip.

Data Allowance

RWA supports the proposed requirement that 5G Fund support recipients provide at least

one service plan in eligible areas that includes a data allowance that would correspond to the

16

WBD (US) 49483004v1

average U.S. subscriber data usage, but there should not be a cap on the maximum data usage

allowance that would be required for the final service milestone. 5G usage is not the same as 4G

usage. The marketplace should be allowed to decide what is offered in a carrier’s retail plans

and also take into consideration enterprise, agricultural and industrial uses and service offerings

that may be more prone to connecting things rather than people.

Reasonably Comparable Rates

The Commission proposes to require that 5G Fund support recipients offer services in

eligible rural areas at rates that are reasonably comparable to rates they offer in urban areas.

RWA notes that generally speaking, rural carriers try to match urban pricing to the extent

possible, but rather than promulgating a rule, the FCC should allow the marketplace to govern

the rates that carriers offer in rural areas.

Demonstrating Compliance with Performance Requirements

The NPRM proposes to require that 5G Fund support recipients demonstrate performance

using a combination of predictive propagation modeling and comprehensive on the ground

testing. RWA strongly opposes any on-the-ground testing requirement, as such a requirement

imposes substantial burdens on support recipients, particularly in the extremely rural areas that

are the subject of the 5G Fund. Predictive propagation modeling will generate sufficiently

accurate data to allow for enforcement of performance requirements provided the propagation

modeling used is calibrated to a common standard and carriers are not permitted to include

assumptions in the model that grossly overstate coverage.19

RWA supports the proposed requirement that milestone coverage maps be generated to

show cell edge coverage with minimum download and upload speeds of 7 Mbps and 1 Mbps,

19 See generally, Mobility Fund Phase II Coverage Maps Investigation Staff Report, GN Docket No. 19-367, rel. December 4, 2019.

17

WBD (US) 49483004v1

respectively, with 90% probability and 50% loading, and a showing of where 35 Mbps/3 Mbps

with latency of 100 ms per round trip or better service is available. Testing for speed and latency

should be depicted on the coverage maps utilizing an acceptable link budget.

Milestone Map Supporting Data

RWA supports the proposed requirement that recipients submit supporting data in

addition to milestone coverage maps. Link budgets, which are already required on the FCC

Form 477, would allow for verification of coverage. Although such supporting data would be

helpful, RWA believes that an alternative proposal, where the FCC would instead provide

recipients the acceptable propagation software, which include model calibration capability,

would be preferable. A sample of drive test data could then be submitted to verify that

assumptions in the link budget are calibrated with the propagation model software utilized to

confirm the calculations used to meet the required speed throughputs. This would reveal the

methodology used and generate more confidence in the propagation model. In addition, a

requirement that recipients submit a calibrated model tuning report would ensure that coverage

maps are built using comparable standards and further improve the accuracy of the coverage

map. The report should include the following data: (1) software type; (2) terrain and clutter

resolution; (3) calibrated propagation characteristics; (4) correction factors for each clutter type,

which contain the number of points per clutter type class, mean error, and standard deviation;

and (5) summary statistic information that includes the number of points used in the calibration

process, mean error, standard deviation, and root mean square.

RWA supports the proposal that at least 96% of speed tests in the cumulative speed test

data submitted for each construction milestone be required to have a speed of 35 Mbps download

and 3 Mbps upload and a latency of no greater than 100 ms round trip in order to be included as

18

WBD (US) 49483004v1

meeting the standard. However, from a buildout commitment standard, the cell edge boundary,

which will determine whether the coverage benchmarks are met, will be measured at the 7 Mbps

download 1 Mbps upload speeds.

Coverage Area Measurement Methodology

Drive testing imposes substantial time and cost burdens on support recipients. The rural

areas that would be served by 5G under the 5G Fund are vast, with extensive portions that are

non-drivable or otherwise inaccessible. Sample drive testing to verify coverage is more cost

effective. The resources required to do extensive drive testing would be better spent on

deploying 5G, and given that predictive propagation modeling that is properly calibrated and

vetted is both comprehensive and accurate, there is simply no need for a drive test on a grid by

grid basis in these circumstances. However, should the Commission still consider the use of

drive testing on a sample basis, RWA comments below on the some of the proposed aspects of

these requirements.

The Commission proposed that speed tests be taken between 6 a.m. and midnight. While

the proposed window for testing is generally appropriate, the timing of tests should be at peak

periods of network usage and should ideally be network specific. For example, some carrier’s

network busy hours may be between midnight and 2 a.m. depending on agricultural production,

meat processing, and oil and gas activity taking place. RWA reminds the FCC that 5G brings the

advent of connecting things to broadband and things don’t necessarily adhere to traditional

human time frames of activity.

The NPRM asks whether a load simulator should be required. A load simulator should

not be required as it skews data and potentially harms service reliability. Every time a carrier

conducts a simulation, it requires injecting noise into the site to simulate load, which results in

19

WBD (US) 49483004v1

unreliable service to the detriment of subscribers. Given there are fewer cell sites in rural areas

to offload traffic, this would not be a safe approach.

With respect to outdoor testing, RWA believes that any required tests should be

conducted in vehicles and based on dashboard-mounted devices. The mobile wireless industry’s

current practice is based on in-vehicle testing. To conduct testing for the outdoor environment,

additional equipment would be required to connect the phone with external antennas that would

be located on the drive test vehicle, and the test phone would have to be placed inside a metal

box attached to the computer. Software from tools such as TEMS, NEMO, and maybe RantCell

run on the computer then execute each test. This additional hardware is not typically used in

current testing by service providers, and therefore would be an additional cost.

There should be no testing of non-drivable areas. Measuring performance on private

property, off road areas, state and national parks, etc. has proven to be incredibly expensive and

should not be required.

Testing Measurement Application Development

There is no need for the Commission to consider developing an app to verify coverage.

There are already a sufficient number of apps in the marketplace that can accomplish this. For

example, the Ookla app takes speed test data which can be used to verify coverage, and there are

various crowdsourcing apps (such as Truecall from NETSCOUT) that do the same.

IV. Eligibility Requirements

ETC Designations

RWA agrees with the Commission’s proposed ETC designation requirements.

Specifically, RWA agrees that: (1) a prospective auction applicant be allowed to be designated as

an ETC after it is announced as a winning bidder for a particular area if it obtains such

20

WBD (US) 49483004v1

designation within 180 days after the release of the public notice announcing winning bidders;

(2) the 180 day deadline be waived where a winning bidder has demonstrated good faith efforts

(presumed if the winning bidder filed its ETC application with the relevant authority within 30

days after the release of the public notice announcing winning bidders) to obtain its ETC

designation, but the proceeding has not been completed by the deadline; and (3) the Commission

should forbear from the statutory requirement that the ETC service area of a 5G Fund winning

bidder conform to the service area of the rural telephone company serving the same area.

Spectrum Access

The Commission proposes requiring that an applicant seeking to participate in a 5G Fund

auction have access to spectrum in an area that enables it to satisfy the applicable performance

requirements in order to receive 5G Fund support for that area. Unlicensed spectrum should not

be allowed to satisfy this eligibility criterion as its availability cannot be relied upon. General

Authorized Access (GAA) CBRS spectrum, however, should be considered as qualifying

spectrum if enough is available in the rural area since there will be a SAS to prevent interference

and prioritize use. A minimum of 15 megahertz of spectrum should be available in a given

census tract that can be devoted to 5G use. 15 megahertz is a sufficient amount of spectrum to

support 35/3 Mbps speed when used in coordination with Multiple Input Multiple Output

(“MIMO”).

Encouraging Participation

The Commission proposes to permit all qualified applicants to participate in a 5G Fund

auction. T-Mobile should not be allowed to use 5G auction funds to meet its merger specific 5G

rural buildout commitments. To date, T-Mobile has not identified such areas to the FCC. Since

it has not come forward with this self-identifying data, it should not be allowed to participate.

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WBD (US) 49483004v1

Transaction Conditions

RWA agrees with the NPRM’s tentative conclusion that T-Mobile should not be

permitted to use any eligible areas for which it might win 5G Fund support to fulfill the

commitments made by T-Mobile to the FCC in connection with the FCC’s approval of the T-

Mobile-Sprint transaction. T-Mobile made merger specific rural 5G build out commitments to

the FCC to obtain approval of its merger with Sprint prior to the FCC announcing the 5G Rural

Fund. In making those commitments, T-Mobile already budged for its rural 5G deployment

without reliance on a government subsidy. Accordingly, T-Mobile should not be permitted to

utilize the 5G Rural Fund to honor those commitments.

RWA looks forward to working with the FCC on developing the 5G Rural Fund and

appreciates the incredible effort put forward thus far.

Respectfully submitted,

Outside Counsel: Michael Bennet Womble Bond Dickinson (US) LLP 1200 19th Street, NW, Suite 500 Washington, DC 20036 (202) 857-4442Michael.Bennet@wbd-us.com

RURAL WIRELESS ASSOCIATION, INC.

/s/ Carri Bennet ___________________________ Carri Bennet, General Counsel Stephen Sharbaugh, Legislative & Policy Analyst 5185 MacArthur Blvd., NW, Suite 729 Washington, DC 20016 (202) 551-0010legal@ruralwireless.org

June 25, 2020

mailto:Michael.Bennet@wbd-us.commailto:legal@ruralwireless.org

UNIVERSAL SERVICE ADMINISTRATIVE COMPANY

Frozen High Cost Support Projected by State by Study Area

Second Quarter 2020

Appendix HC07

2Q2020

Page 1 of 1

Available for Public Use

Monthly Annual Monthly Annual

AL 259002 PINE BELT CELLULAR, INC. CETC X Y 14,985$ 179,820$ 8,988$ 107,856$ 59.98% 161,838$

AS 679000 AST TELECOM, LLC DBA BLUE SKY COMMUNICATIONS CETC X Y 134,342$ 1,612,104$ 80,604$ 967,248$ 60.00% 1,450,894$

AS 679001 AMERICAN SAMOA TELECOMMUNICATIONS AUTHORITY WIRELESS DIVISON CETC X Y 90,592$ 1,087,104$ 54,354$ 652,248$ 60.00% 978,394$

AZ 459001 SMITH BAGLEY, INC. - CL CETC X Y 680,959$ 8,171,508$ 408,573$ 4,902,876$ 60.00% 7,354,357$

AZ 459002 SMITH BAGLEY, INC. (NON-RESERVATION) CETC X Y 50,401$ 604,812$ 30,239$ 362,868$ 60.00% 544,331$

CO 469001 NORTHEAST COLORADO CELLULAR, INC. CETC X Y 815,925$ 9,791,100$ 489,553$ 5,874,636$ 60.00% 8,811,990$

CO 469009 NNTC WIRELESS, LLC CETC X Y 417$ 5,004$ 250$ 3,000$ 59.95% 4,504$

GU 669001 GUAM CELLULAR AND PAGING, INC. DBA GUAMCELL COMMUNICATIONS CETC X Y 286,120$ 3,433,440$ 171,671$ 2,060,052$ 60.00% 3,090,096$

GU 669003 PULSE MOBILE, LLC CETC X Y 164,338$ 1,972,056$ 98,602$ 1,183,224$ 60.00% 1,774,850$

GU 669004 PTI PACIFICA, INC. DBA IT&E CETC X Y 251,969$ 3,023,628$ 151,181$ 1,814,172$ 60.00% 2,721,265$

IA 359053 IOWA RSA NO. 2 LIMITED PARTNERSHIP CETC X Y 12,094$ 145,128$ 7,255$ 87,060$ 59.99% 130,615$

IA 359054 RSA 1 LIMITED PARTNERSHIP CETC X Y 54,742$ 656,904$ 32,844$ 394,128$ 60.00% 591,214$

IA 359070 IOWA RSA 7 CETC X Y 134,951$ 1,619,412$ 80,969$ 971,628$ 60.00% 1,457,471$

IA 359071 IOWA RSA 8 CETC X Y 103,193$ 1,238,316$ 61,912$ 742,944$ 60.00% 1,114,484$

IL 349008 ILLINOIS VALLEY CELLULAR RSA 2 - I CETC X Y 30,058$ 360,696$ 18,033$ 216,396$ 59.99% 324,626$

IL 349009 ILLINOIS VALLEY CELLULAR RSA 2 - II CETC X Y 25,352$ 304,224$ 15,210$ 182,520$ 60.00% 273,802$

KS 419007 NEX-TECH, LLC CETC X Y 2,237$ 26,844$ 1,342$ 16,104$ 59.99% 24,160$

KS 419009 EPIC TOUCH COMPANY CETC X Y 131,529$ 1,578,348$ 78,915$ 946,980$ 60.00% 1,420,513$

KS 419010 NEX-TECH WIRELESS, LLC CETC X Y 1,566,482$ 18,797,784$ 939,887$ 11,278,644$ 60.00% 16,918,006$

KS 419011 UNITED WIRELESS COMMUNICATION INC. CETC X Y 214,038$ 2,568,456$ 128,420$ 1,541,040$ 60.00% 2,311,610$

KS 419014 CELLULAR NETWORK PARTNERSHIP DBA PIONEER CELLULAR CETC X Y 160,175$ 1,922,100$ 96,103$ 1,153,236$ 60.00% 1,729,890$

KS 419015 WESTLINK COMMUNICATIONS, LLC CETC X Y 108,454$ 1,301,448$ 65,071$ 780,852$ 60.00% 1,171,303$

KS 419020 NE COLORADO CELLULAR, INC. D/B/A VIAERO WIRELSS CETC X Y 5,021$ 60,252$ 3,012$ 36,144$ 59.99% 54,227$

KY 269005 CUMBERLAND CELLULAR, INC. CETC X Y 1,541$ 18,492$ 924$ 11,088$ 59.96% 16,643$

KY 269007 EAST KENTUCKY NETWORK, LLC DBA APPALACHIAN WIRELESS CETC X Y 672,576$ 8,070,912$ 403,544$ 4,842,528$ 60.00% 7,263,821$

KY 269008 BLUEGRASS CELLULAR CETC X Y 1,091,757$ 13,101,084$ 655,052$ 7,860,624$ 60.00% 11,790,976$

MI 319005 THUMB CELLULAR LLC CETC X Y 99,882$ 1,198,584$ 59,927$ 719,124$ 60.00% 1,078,726$

MO 429789 NORTHWEST MISSOURI CELLULAR CETC X Y 113,348$ 1,360,176$ 68,008$ 816,096$ 60.00% 1,224,158$

MO 429790 MISSOURI RSA NO. 5 PARTNERSHIP CETC X Y 150,291$ 1,803,492$ 90,173$ 1,082,076$ 60.00% 1,623,143$

MP 659001 GUAM CELLULAR AND PAGING, INC. CETC X Y 17,528$ 210,336$ 10,516$ 126,192$ 60.00% 189,302$

MP 659002 PTI PACIFICA, INC. CETC X Y 63,227$ 758,724$ 37,935$ 455,220$ 60.00% 682,852$

MT 489001 MID-RIVERS TEL. COOP. CETC X Y 72,728$ 872,736$ 43,636$ 523,632$ 60.00% 785,462$

MT 489006 SAGEBRUSH CELLULAR, INC. CETC X Y 210,576$ 2,526,912$ 126,344$ 1,516,128$ 60.00% 2,274,221$

MT 489010 SAGEBRUSH CELLULAR, INC. - CL CETC X Y 340,933$ 4,091,196$ 204,558$ 2,454,696$ 60.00% 3,682,076$

NC 239004 CAROLINA WEST WIRELESS, INC. CETC X Y 95,400$ 1,144,800$ 57,237$ 686,844$ 60.00% 1,030,320$

ND 389013 SAGEBRUSH CELLULAR, INC. CETC X Y 19,898$ 238,776$ 11,936$ 143,232$ 59.99% 214,898$

NE 379008 NORTH EAST COLORADO CELLULAR, INC. CETC X Y 690,400$ 8,284,800$ 414,238$ 4,970,856$ 60.00% 7,456,320$

NM 499001 SMITH BAGLEY CETC X Y 179,125$ 2,149,500$ 107,473$ 1,289,676$ 60.00% 1,934,550$

NM 499009 SMITH BAGLEY, INC. - CL CETC X Y 162,187$ 1,946,244$ 97,311$ 1,167,732$ 60.00% 1,751,620$

NM 499011 COMMNET WIRELESS, LLC CETC X Y 55$ 660$ 32$ 384$ 58.18% 594$

NV 559005 COMMNET OF NEVADA, LLC CETC X Y 143,611$ 1,723,332$ 86,165$ 1,033,980$ 60.00% 1,550,999$

NV 559007 COMMNET OF NEVADA, LLC CETC X Y 29,052$ 348,624$ 17,430$ 209,160$ 60.00% 313,762$

OK 439008 PANHANDLE TELECOMMUNICATIONS SYSTEMS, INC. CETC X Y 307,161$ 3,685,932$ 184,295$ 2,211,540$ 60.00% 3,317,339$

OK 439012 PINE CELLULAR PHONES, INC. - CL CETC X Y 332,833$ 3,993,996$ 199,698$ 2,396,376$ 60.00% 3,594,596$

OK 439013 CELLULAR NETWORK PARTNERSHIP CETC X Y 15,889$ 190,668$ 9,532$ 114,384$ 59.99% 171,601$

OK 439017 CROSS WIRELESS LLC DBA SPROCKET WIRELESS LLC - CL CETC X Y 7,450$ 89,400$ 4,469$ 53,628$ 59.99% 80,460$

OK 439019 CROSS VALLIANT CELLULAR PARTNERSHIP - CL CETC X Y 29,613$ 355,356$ 17,766$ 213,192$ 59.99% 319,820$

OK 439031 CELLULAR NETWORK PARTNERSHIP - CL CETC X Y 1,055,867$ 12,670,404$ 633,519$ 7,602,228$ 60.00% 11,403,364$

OK 439032 PANHANDLE TELECOMMUNICATION SYSTEMS INC. - CL CETC X Y 469$ 5,628$ 280$ 3,360$ 59.70% 5,065$

OR 539004 EDGE WIRELESS CETC X Y 60,301$ 723,612$ 36,179$ 434,148$ 60.00% 651,251$

OR 539007 EAGLE TELEPHONE SYSTEMS, INC. DBA SNAKE RIVER PCS CETC X Y 126,643$ 1,519,716$ 75,985$ 911,820$ 60.00% 1,367,744$

SC 249002 FTC COMMUNICATIONS, LLC CETC X Y 219,248$ 2,630,976$ 131,548$ 1,578,576$ 60.00% 2,367,878$

SD 399014 JAMES VALLEY WIRELESS, LLC CETC X Y 64,732$ 776,784$ 38,837$ 466,044$ 60.00% 699,106$

TN 299905 ADVANTAGE CELLULAR SYSTEMS, INC. CETC X Y 17,709$ 212,508$ 10,624$ 127,488$ 59.99% 191,257$

TX 449018 CT CUBE LP CETC X Y 48,025$ 576,300$ 28,814$ 345,768$ 60.00% 518,670$

TX 449026 MID-TEX CELLULAR LTD. CETC X Y 30,409$ 364,908$ 18,244$ 218,928$ 60.00% 328,417$

TX 449043 CGKC&H #2 RURAL LIMITED PARTNERSHIP DBA WEST CENTRAL WIRELES CETC X Y 104,674$ 1,256,088$ 62,803$ 753,636$ 60.00% 1,130,479$

TX 449046 CGKC&H #1 L. P. FIVE STAR WIRELESS CETC X Y 15,937$ 191,244$ 9,561$ 114,732$ 59.99% 172,120$

UT 509002 SMITH BAGLEY, INC. - CL CETC X Y 12,245$ 146,940$ 7,346$ 88,152$ 59.99% 132,246$

WA 529003 WASHINGTON RSA NO. 8 LIMITED PARTNERSHIP CETC X Y 211,591$ 2,539,092$ 126,952$ 1,523,424$ 60.00% 2,285,183$

WA 529004 EASTERN SUB-RSA LIMITED PARTNERSHIP CETC X Y 66,740$ 800,880$ 40,042$ 480,504$ 60.00% 720,792$

WI 339015 NSIGHTTEL WIRELESS, LLC CETC X Y 393,938$ 4,727,256$ 236,355$ 2,836,260$ 60.00% 4,254,530$

WI 339023 WI RSA #1 LIMITED PARTNERSHIP CETC X Y 473,167$ 5,678,004$ 283,899$ 3,406,788$ 60.00% 5,110,204$

WY 519005 GOLD STAR COMMUNICATIONS, LLC CETC X Y 150,165$ 1,801,980$ 90,097$ 1,081,164$ 60.00% 1,621,782$

WY 519905 UNION TELEPHONE CO. DBA UNION CELLULAR CETC X Y 649,771$ 7,797,252$ 389,860$ 4,678,320$ 60.00% 7,017,527$

Total Support 13,587,066$ 163,044,792$ 8,152,132$ 97,825,584$ 60.00% 146,740,313$

LEGEND

Revenue Type P - Price Cap

X - Competitive

% of Pre-

Cap

Support @ 90%

of Pre-Cap

Pre-Cap Monthly Support Post Cap Monthly Support

State SAC Study Area NameRevenue

TypeType Eligible

USAC - High Cost Support Mechanism January 31, 2019

Attachment 1