Mobility Fund Phase II Coverage Maps Investigation Staff Report

As part of the Federal Communications Commission’s ongoing effort to reform universal service funding of mobile wireless services and focus subsidies on unserved areas rather than on areas that already have service, the FCC unanimously adopted a new data collection of 4G Long-Term Evolution (LTE) mobile broadband coverage maps and a challenge process to determine areas eligible for support in the Mobility Fund Phase II (MF-II) auction. The largest mobile providers supported both this data collection and the challenge process. After mobile providers submitted coverage maps to the FCC and during the challenge process, some parties raised concerns regarding the accuracy of the maps submitted by providers. Based on these parties’ complaints and its own review of the record, FCC staff became concerned that maps submitted by Verizon, US Cellular, and T-Mobile overstated their coverage and thus were not accurate reflections of actual coverage. Through the investigation, staff discovered that the MF-II coverage maps submitted by Verizon, US Cellular, and T-Mobile likely overstated each provider’s actual coverage and did not reflect on-the-ground performance in many instances. Only 62.3% of staff drive tests achieved at least the minimum download speed predicted by the coverage maps—with US Cellular achieving that speed in only 45.0% of such tests, T-Mobile in 63.2% of tests, and Verizon in 64.3% of tests. Similarly, staff stationary tests showed that each provider achieved sufficient download speeds meeting the minimum cell edge probability in fewer than half of all test locations (20 of 42 locations). In addition, staff was unable to obtain any 4G LTE signal for 38% of drive tests on US Cellular’s network, 21.3% of drive tests on T-Mobile’s network, and 16.2% of drive tests on Verizon’s network, despite each provider reporting coverage in the relevant area.

1. The FCC should terminate the MF-II Challenge Process
2. The FCC should release an Enforcement Advisory on broadband deployment data submissions, including a detailing of the penalties associated with filings that violate federal law, both for the continuing FCC Form 477 filings and the new Digital Opportunity Data Collection.
3. The FCC should analyze and verify the technical mapping data submitted in the most recent Form 477 filings of Verizon, US Cellular, and T-Mobile to determine whether they meet the Form 477 requirements.
4. The FCC should adopt policies, procedures, and standards in the Digital Opportunity Data Collection rulemaking and elsewhere that allow for submission, verification, and timely publication of mobile broadband coverage data.