On January 17, representatives from WTA, NTCA, ITTA and Vantage Point Solutions met with staff from Commissioner Clyburn’s and Rosenworcel’s offices to discuss concerns with a portion of the draft Order and Order on Reconsideration to be considered at the FCC’s January 30 Open Meeting.
The Associations’ concerns revolve around Section III.D.1. of the Draft Order, regarding how to address the “locations gap” in the CAF Phase II auction context. Vantage Point found an overestimation of model-identified locations in 85 percent of 144 exchanges, with an average discrepancy of approximately 22 percent between model-identified locations and “real-world” locations. These discrepancies “risk leaving areas unserved in perpetuity because no bidder may ever be able to justify serving areas where ‘facts on the ground’ differ materially from those identified in the model. In fact, the due diligence contemplated by the Draft Order may have the effect of dissuading prospective bidders, especially small businesses, from participating in the Phase II auction, if not at least directly contravening the Commission’s goal of maximizing participation in the auction.”
The Associations propose several solutions in a Notice of ex parte filed with the Commission.