Don't Favor LEO in RDOF Procedures, Commenters Ask FCC

SpaceX said it wants "the same auction procedures as other participants [that] provide SpaceX the same ability to demonstrate its technical qualifications to place bids consistent with its network capabilities." SpaceX isn't seeking special treatment, it said: Starlink isn't "reliant on an untested or experimental technology." Latency is a function of altitude, it said, and the system’s low latency is dictated by the laws of physics. "Refrain from categorically pre-determining which technologies can qualify for particular service tiers and allow applicants to establish eligibility at the short-form stage," ViaSat asked.

An FCC proposal to have the Wireline Bureau review "non-fully operational networks on a case-by-case basis, after short-term applications are submitted, introduces an opacity to the evaluation process that conflicts" with transparency goals, said the Fiber Broadband Association: Prohibiting bidding by unproven networks would "drive greater participation."

"Staff should not be obligated to entertain technical proposals in short-form applications that lack meaningful operational history upon which reasonable expectations of performance can be based," said the National Rural Electric Cooperative Association and Utilities Technology Council. WTA wants to continue to preclude "bidders from designating performance tiers and latency combinations that their proposed technologies have not yet demonstrated the capability to provide." Adtran wants the FCC to clarify there's no presumption "the nascent technology of mega-constellations" of LEOs can qualify for the gigabit performance tier and also clarify hybrid fiber/DSL technologies can qualify for that tier.

Relax latency so satellite companies can participate, SES Americom asked. "The current COVID-19 crisis underscores the need to accelerate the widest possible availability of broadband capacity to support remote learning and work, telehealth, and other critical services."

ISPs that deploy fiber to expand their service territories want to retain smaller minimum bidding areas such as census block groups. Satellite providers might have an advantage over wired technologies if auction procedures choose the census block tracts rather than census blocks as the minimum bidding territories, some suggested.

"Adopting a larger minimum bidding unit may mean that only a satellite provider will be able to cover the entire area to serve all of the eligible locations," said NCTA. "Cable operators may be unable to participate," it added. "In rural areas, the census units of geographic measurement can be quite large, which makes it difficult for providers to deploy terrestrial-based broadband networks to all eligible locations." Maintaining a smaller bidding unit "promotes competition among various providers," Frontier Communications said. "Bidders that prefer a larger unit because they are seeking to provide service over larger areas may still have the option to place package bids."

“USTelecom does not share the Commission’s concern that the large number of census blocks in this auction could create added bidding complexities,” the association said. “USTelecom supports the continued use of census block groups.”

AT&T doesn't anticipate increasing the number of bidding areas "will meaningfully change the preparation and data management required by auction participants," it said. "Bidders that will use consultants and software" for census block groups are just as likely to use them for census tracts, it said.