In its comments, WTA focused on the following four issues:
- (1) that the Commission should retain census block groups as the minimum geographic area for bidding in the RDOF auction rather than effectively excluding many small entities by shifting to census tracts;
- (2) that the Commission should require RDOF bidders to employ a 100 percent (rather than 70 percent) subscribership assumption in designing their RDOF-supported networks in order to ensure that both normal and emergency broadband service demands can be met expeditiously;
- (3) that the Commission should not permit RDOF bidders to gain an unfair competitive advantage and subject their future broadband customers to uncontrollable interference and congestion problems by employing unlicensed spectrum; and
- (4) that the Commission should continue to preclude RDOF bidders from designating performance tiers and latency combinations that their proposed technologies have not yet demonstrated the capability to provide.