Dear Chairman Pai:
Last month's Mobility Fund Phase II (MF-II) Coverage Map Investigation Staff Report confirmed what we already knew to be true -- the maps were wrong. While we commend the Federal Communications Commission (FCC or Commission) for acknowledging that critical fact, we have some serious reservations about the recently announced 5G Fund and the decision to focus these limited mobile broadband deployment dollars on the promise of a 5G future when many places in our states still lack 4G service or do not have any service at all. To stand any chance of connecting rural Americans, the FCC needs a more accurate method of data collection, a strong challenge process, and a funding process that includes terrain factors to ensure that the hardest to serve places can compete for limited funding.
While carriers are beginning to roll out 5G service in select major metropolitan areas, 5G availability remains the exception rather than the rule for most Americans, even those living in big cities. The divide is even greater for the rural Americans we represent, some of whom still lack the 4G LTE service promised by MF-II. By refocusing funding toward 5G, not only will our states have to compete with our more urban, more profitable neighbors, we are also at a major systemic disadvantage because of the additional hurdles 5G presents for rural deployment. Specifically, high frequency signals being utilized for several announced 5G deployments enable faster data rates but cannot travel as far or pass through geographic impediments like buildings or mountains as easily. In order to overcome these technological constraints, 5G deployment will rely on the deployment of small, densely-concentrated cells to transmit effectively. While this may be possible in urban areas with large customer bases, these constraints will make it extremely difficult to deploy in rural areas like our home states. 5G deployment is an admirable long-term goal, but the performance criteria for the 5G Fund should account for the realities of closing the digital divide today.
Additionally, as you consider the structure of this new 5G Fund, we urge you to learn from the MF-II process. The Commission only recognized the fundamental flaws in the coverage maps after states, local governments, tribal governments, mobile broadband providers, and other stakeholders were allowed to review and formally challenge the incumbent providers' reported coverage data. One of the principal lessons learned from MF-II was that the old way of mapping does not work. We can no longer have a system where maps are drawn based on unreliable data. As your agency's Staff Report recommended, data must be collected based on more specific parameters that better reflect minimum on-the-ground network performance. And we must allow people to be a part of the verification process before the money goes out the door.
We also urge you to retain the terrain factor that you committed to include in the MF-II process. As Senators representing states where challenging topographical features make broadband deployment extremely expensive, we know all too well the competitive disadvantage we face when applying for funding that is awarded through reverse auctions. The states we represent have distinctive landscapes that are integral to their identity and their beauty which is what draws people from around the world to visit each year. Unfortunately, these same natural features make the construction of critical broadband infrastructure far more expensive than other parts of the country. It costs more to serve fewer people, plain and simple. Without a terrain factor or a high cost set aside, we cannot compete.
All Americans, no matter their area code, deserve to have access to high speed, reliable mobile service, and we need your help to make this a reality. We thank you for your careful consideration of this request and look forward to working with the Commission to ensure that this funding will go to the places that need it the most.