WISPA Rebuts Arguments Which Seek to Undermine RDOF process

Washington, DC, February 22, 2021 – WISPA filed an ex parte today with the FCC which forcefully responds to unwarranted criticism leveled at certain winners of the RDOF Phase I auction, and the RDOF process as a whole.  Specifically, the ex parte addresses NTCA’s arguments which seek to interject more “transparency” into the RDOF process; and the related Vantage Point white paper, which incorrectly implies that fixed wireless networks cannot deliver Gigabit services. 
The main points in the NTCA rebuttal are:
  • The FCC already rejected NTCA’s arguments for generally applicable standards to approve fixed wireless deployments;
  • Since NTCA and others failed to file timely petitions for reconsideration with the FCC or petitions for review with federal courts of appeals, these arguments at this point amount to untimely petitions that the FCC cannot consider; and
  • Challenging fixed wireless providers on the basis that some winning bids are unexpectedly low is an unpersuasive reason to revisit these procedural requests because: (a) the FCC’s RDOF rules provide that an acceptable bid can be as low as one-percent of the reserve price to serve a census block; and (b) even fiber only providers won support with winning bids that were less than 10-percent of the reserve price.
As to the rebuttal of the Vantage Point white paper, which was submitted by WISPA technical consultant Fred Goldstein of Interisle Consulting Group, Goldstein notes:
  • The Vantage Point white paper contains a number of significant flaws that demonstrate a serious misunderstanding of how the fixed wireless access (WISP) industry works, and how and where a WISP chooses to provide its services;
  • WISPs operate across a range of frequencies, from TV White Space up through the millimeter wave bands, and while not all of these spectrum bands are capable of delivering Gigabit services, that does not rule out provision of such services in many targeted areas;
  • It is now possible to meet Gigabit Tier requirements using fixed wireless technologies;
  • While the possible speed of a wireless link depends on many factors, especially the quality of the path, the recent availability of millimeter-wave systems and equipment, especially on the unlicensed 60 GHz band, and the pending availability of standard-power devices on the 6 GHz band, make Gigabit download wireless speeds a realistic option in many places.
“WISPA appreciates the challenges that lie ahead for Commission staff in undertaking the rigorous review of long-form applications, [and] that is exactly what the Commission should continue to do – rely on its substantial training, knowledge, and expertise to determine those applicants that are ‘reasonably capable’ of meeting buildout milestones and performance obligations,” said Claude Aiken, President and CEO of WISPA in the ex parte.  In Aiken’s view, “the Commission should reject calls for disruptive, time-consuming, and litigation-producing changes that most assuredly will delay decisions on who should receive support and who should not, and the deployment of critical broadband facilities to unserved communities.”
A copy of the ex parte can be found here.
WISPA’s 1000 members are composed of fixed Wireless Internet Service Providers (WISPs) and the industry that supports fixed wireless broadband, including equipment suppliers, support services, and other components needed to run a successful business. Our members, and WISPs, in general, provide broadband access to millions of residential and business customers, often in exclusively rural areas.

Mike Wendy