JSI Offers Updated Maps, Bidding Model

Late last week, the FCC released a Public Notice with an updated list of eligible areas for the Rural Digital Opportunity Fund (RDOF) Auction 904. We encourage all companies interested in participating in the RDOF to evaluate the updated list as it may impact not only the areas eligible for support that you previously had identified but also the reserve prices, thus impacting your bidding strategy. The RDOF short form application window opens this week on July 1 at Noon EDT and closes on July 15 at 6:00 p.m. EDT.

JSI is available to assist you in evaluating the final list and updated reserve prices, as well as determining bids and bidding strategies, assisting with completing the short form application, and providing guidance as to how to use the proxy method in the bidding process. In addition to our mapping tool, we have developed a financial model to assist companies in determining the lowest bid and assessing whether or not the project is feasible with the ability to vary the model on “what ifs.” For those that have already received RDOF eligible area maps from JSI, we will be reaching out to see if you would like for us to provide you with updated maps. If you have not used our mapping tool, we encourage you to contact us so that we can better explain how the tool is much more manageable than the FCC’s map and can be used to better identify eligible areas and reserve prices. While we are not able to assist with bids and bidding strategies after July 15 when the prohibited communications rules kick in, after that date, we will still make available these tools and our consulting services in a more general way as allowed by FCC’s rules.

While this list is considered the “final” list, the Public Notice announced that prior to the start of the auction, the FCC will eliminate census blocks identified in pending RUS ReConnect Round 2 grants and grant/loan combinations that are awarded funding prior to the auction. As to differences between this updated list and the previous version, the FCC accepted most of the challenges which indicated updated Form 477 data and granted most of the state and federal grant areas upon verifying that the challenger had a binding commitment to provide at least 25/3 Mbps using ReConnect Round 1 grants and grant/loan combinations. The FCC, however, decided not to exclude blocks where ReConnect Round 1 loans had been awarded and added those blocks to the list as they had not been included in the first list.

The FCC, however, denied some challenges, including challenges by 38 companies that claimed they had deployed broadband or voice after June 2019, but the FCC was unable to verify voice service provided by these challengers. The FCC also denied Frontier’s 16,987 challenged Form 477 blocks and all of its challenged 6,230 state-funded blocks except those in New York. The FCC explained that Frontier “overstate[d] its coverage and represent[s] implausible deployment during a time of financial distress for the company.” Other challenges that were denied include late-filed challenges, one that lacked evidence that blocks were served, one that filed a challenge based on merger commitments, challenges that were outside the scope of what the FCC expected in its narrow challenge process, two that did not include census blocks, and several others. Not surprisingly, no rate-of-return provider took up the FCC’s offer to relinquish blocks for the RDOF that the provider would not be able to serve with 25/3.

To receive an updated RDOF map or if you would like our assistance with the short form, our financial model or if you have any questions about the auction, please contact John Kuykendall or Cassandra Heyne in the Maryland office at 301-459-7590.