RWA Asks FCC to Make Carriers Keep 3G Operating For Now

The Rural Wireless Association (RWA) urged the FCC to require the three major nationwide carriers — AT&T, Verizon, and T-Mobile — to delay the shutdown of their 3G networks. Each carrier has announced plans to sunset 3G service on dates ranging from December 31, 2021, (T-Mobile) to mid-2022 (Verizon and AT&T).

The RWA told the agency its rural member carriers need more time to transition to VoLTE (Voice over LTE) roaming before 3G is shut down nationwide. Rural Americans served by RWA members are already experiencing the effects of these shutdowns, the association told the Commission. “RWA carrier members across the country are receiving reports from their rural customers of degraded or nonexistent 3G coverage in advance of these 3G sunset deadlines announced by the nationwide carriers,” said RWA attorneys in an FCC filing.  

That’s why RWA conducted a survey in the second and third quarters of this year. When asked if their rural customers experienced 3G service degradation when leaving their home networks and roaming on other carriers’ networks, members said “yes,” for both voice and data services across the country. It tracked occurrences in: Wichita, KS (Sprint); Philadelphia, PA (Sprint); Oklahoma City, OK (Sprint); Atlantic City, NJ (Sprint); Denver, CO (Sprint); San Antonio, TX (AT&T and T-Mobile); Dallas, TX (AT&T and T-Mobile); downtown Birmingham, AL (Sprint); Vernal, UT (Sprint and Verizon); Craig, CO (Sprint and Verizon); Tulsa, OK (Verizon); Henderson, NV (Verizon); Colorado (generally) (Verizon); Texas (generally) (Verizon); Central Oklahoma (AT&T, Sprint, and T-Mobile); and New Jersey (AT&T, Sprint, and T-Mobile).

The 3G shutdowns have a particularly harmful impact on certain categories of subscribers, namely, “ranchers and farmers traveling to larger market areas outside of their home carrier’s service areas, and senior citizens who have not upgraded their handsets due to fixed incomes when they travel beyond the reach of their home carrier’s network,” said RWA.

Rural carriers must implement VoLTE roaming before these 3G networks sunset due to the continued need for 3G Circuit Switch Fall Back (3G CSFB). 3G CSFB delivers voice and SMS (Short Message Service) to LTE via 2G and 3G. 3G CSFB occurs in networks supporting LTE data but not supporting VoLTE, the LTE voice call standard, or in networks not permitting VoLTE roaming by outside subscribers. When a subscriber places or receives a call or SMS message using an LTE device, “the device ‘falls back’ to the 3G or 2G network to complete the call or to deliver the SMS text message,” explains RWA.  

“Rip and Replace” should speed up rural carrier’s transition away from 3G, as reimbursement applicants seek to use Reimbursement Program funds to replace legacy 3G covered list equipment with LTE and 5G-ready equipment and services including VoLTE. However, the Commission has “regrettably” decided not to reimburse carriers for the cost of replacing VoLTE non compatible handsets, notes RWA. “This will cause hardship to low-income rural Americans and cause them to fall further behind in adopting LTE and 5G technology, potentially leaving them unconnected,” the association explains.

RWA is asking for the FCC to mandate the national carriers delay their 3G sunsetting or shutdowns for a year, to December 31, 2022. “The transition from 3G to VoLTE cannot take place without roaming testing and coordination among the nationwide carriers and rural carriers,” says RWA. It asks the FCC to take these factors into consideration, especially when considering the public safety aspects associated with E-911 and emergency voice calls.

RWA supports the relief requested by the alarm industry in its emergency petition. By granting the Alarm Industry Communications Committee’s request, both the alarm industry and rural carriers will have more time to transition, notes the association.

By Leslie Stimson, Inside Towers Washington Bureau Chief

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