A Community’s Guide to Challenging Mobility Fund Phase II Ineligibility

The Federal Communications Commission (FCC)’s Mobility Fund Phase II (MF-II) aims to incentivize LTE/4G deployment in rural areas through reverse auction by making available up to $4.53 billion over the next ten years. However, some find the data that the FCC uses to make these funding decisions to be unreliable or incomplete. To combat this, the FCC has allowed for communities to enter a Challenge Process to assert eligibility for funding. Communities can also opt to connect with other organizations to complete the process.

The FCC’s eligibility map deems which communities currently can and cannot apply for MF-II funding. The map’s data comes from mobile providers’ data on where they provide LTE coverage at the sub-census-block level, as well as Universal Service Administrative Company (USAC) subsidy data.

The map has drawn criticism from interest groups — like the Competitive Carriers Association (CCA) and Rural Wireless Association (RWA) — that claim the map is inaccurate due to the data collection process. A group of senators also opposed the map and signed a letter to FCC Chairman Ajit Pai showing concern over policy implications as a result of the map.

“It is now clear that the parameters the FCC directed carriers to use in its one-time data collection have failed to produce a credible map of eligible areas, and it is most disappointing that absent significant changes, the Commission will fall short of Congress’s mandate for Universal Service,” CCA President and CEO Steven Berry said in a statement.


What can a community in need do if the map deems it ineligible for MF-II funding?

Communities can go through the Challenge Process, an initiative the FCC established to allow for underserved and misrepresented communities to gain the funding they need for broadband deployment. Through this process, interested parties can formally challenge the map’s initial determination that a certain area is ineligible for funding.

To challenge the FCC’s map, parties must submit a Portal Access Request Form in order to gain access to the USAC portal. Communities can then send in speed test measurements to demonstrate that existing coverage is below the 5 Mbps minimum benchmark.

The providers challenged will then have the opportunity to respond to the challenge submissions. When the Challenge Process is complete, the FCC will determine and publish the final list of areas eligible for the MF-II auction.

Because the MF-II Challenge Process can be complicated, communities can choose to join forces with municipal leagues, county governments, cooperatives, state governments, and other groups. Collaborating often makes it easier to participate in the Challenge Process; reach out to us if you would like help navigating the process or contacting other organizations.

The FCC is also planning to release a step-by-step guide on how to complete the Challenge Process, so keep an eye out for that in the coming weeks. The FCC and USAC have also held webinars on the topic, which you can watch here and here.

The Challenge Process is open from March 29, 2018 to August 27, 2018. If you would like more information or assistance completing the Challenge Process, please feel free to contact us.


Anna Higgins is a 2018 summer intern at Next Century Cities and a candidate for a master of public policy at the University of Virginia.

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