Prior to the Christmas holiday, representatives from WTA met with staff from the FCC Wireline Competition Bureau and the Commissioner offices to discuss the association’s thoughts on the proposed Rural Digital Opportunity Fund.
WTA indicated that some of its members are interested in participating in the RDOF auctions, but that substantial revisions need to be made to the CAF Phase II Auction procedures before they are applied to areas with existing 10/1 Mbps broadband networks, customers and service arrangements. WTA is concerned that the application of virtually the same mechanism to RDOF areas served by 10/1 Mbps wireline broadband networks will result in the displacement and withdrawal of many existing wireline service providers.
WTA proposed a bidding credit for existing 10/1 Mbps broadband networks receiving high-cost support that had met their build-out obligations under the pre-auction support mechanism. WTA also proposed several additions and changes to RDOF weighting factors in order to increase the likelihood that the RDOF auctions will select proposals that will provide quality services aimed at meeting long-term customer needs in an economical manner, and not be skewed to low-cost, bare-bones proposals devised primarily to win reverse auctions now without worrying about future service needs and upgrade costs. In addition, WTA expressed concerns about the adverse impact of irrevocable letters of credit upon small bidders. LOCs can be very expensive (if available at all to some entities) and can substantially reduce the net support received by successful bidders. More details about WTA’s proposals can be found in it’s filing of September 23.
A representative Notice of ex parte for all six meetings can be found here.