Federal Communications Commission DA 18-318
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Petition for Waiver of Wireless Partners, LLC 
to Participate in Mobility Fund II Challenge
Process
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WT Docket No. 10-208
ORDER 
Adopted:  March 30, 2018 Released:  March 30, 2018 
By the Chief, Auctions and Spectrum Access Division:
I. INTRODUCTION
1. In this Order, we grant Wireless Partners, LLC (Wireless Partners), a waiver to 
participate as a challenger in the Mobility Fund Phase II (MF-II) challenge process.
1
  For the reasons 
discussed below, we instruct the Universal Service Administrative Company (USAC) to grant access to 
the challenge process portal to the users identified in the Wireless Partners’ Petition for Waiver.  
II. BACKGROUND
2. In the MF-II Challenge Process Order, the Commission established the framework for a 
robust and efficient challenge process to resolve disputes about areas found to be presumptively ineligible 
for MF-II support.
2
  The Commission concluded that government entities (state, local, and Tribal) and all 
service providers required to file Form 477 data with the Commission are best suited to participate as 
challengers in the MF-II challenge process.
3
  The Commission found that limiting participation to these 
interested parties would satisfy its policy goal of administrative efficiency because they are the entities 
that are most likely to have access to and be able to provide data relevant to the Commission’s 
consideration of a challenge.
4
  The Commission explained, however, that other entities wishing to 
participate in the process as a challenger could request a waiver of this rule.
5
3. On March 21, 2018, Wireless Partners filed a petition for a waiver of the rule limiting 
participation in the MF-II challenge process.
6
  Wireless Partners states that it is neither a governmental 
1
 Petition of Wireless Partners, LLC for Waiver to Participate in the Challenge Process, WT Docket No. 10-208 
(filed Mar. 21, 2018) (Petition for Waiver).
2
 Connect America Fund; Universal Service Reform – Mobility Fund, Order on Reconsideration and Second Report 
and Order, 32 FCC Rcd 6282, 6282, 6296-314, paras. 1, 27-64 (2017) (MF-II Challenge Process Order).
3
 Id. at 6303, para. 42. 
4
 Id. at 6303-04, para. 42 & n.115.
5
 Id. at 6304, para. 43 n.119 (citing 47 CFR § 1.3); see also Mobility Fund Phase II Challenge Process Handsets and 
Access Procedures for the Challenge Process Portal, Public Notice, 32 FCC Rcd 10372, 10376, para. 10 & n.33 
(WCB/WTB 2017). 
6
 Petition for Waiver at 3.
Federal Communications Commission DA 18-318
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entity nor a service provider required to file Form 477 data with the Commission and, thus, has no right to 
participate as a challenger.
7
  However, Wireless Partners contends that it qualifies for a rule waiver 
because it has a bona fide interest in the MF-II challenge process and a plausible ability to submit a valid 
challenge.
8
  
III. DISCUSSION
4. The Commission may waive its rules and requirements where there is “good cause 
shown” to do so.
9
  Good cause, in turn, may be found “where particular facts would make strict 
compliance inconsistent with the public interest.”
10
  A waiver is therefore “appropriate only if special 
circumstances warrant a deviation from the general rule and such deviation will serve the public 
interest.”
11
  For the rule limiting participation in the MF-II challenge process, the Commission anticipated 
that this good-cause standard would be met “in cases in which a[] . . . business demonstrates a bona fide 
interest in the challenge process and a plausible ability to submit a valid challenge.”
12
5. We conclude that there is good cause for granting the requested waiver.  Wireless 
Partners asserts it has a bona fide interest in the challenge process because it is a mobile 
telecommunications company that holds Commission licenses and designs, builds, owns, and operates 4G 
LTE networks that provide voice and broadband data services in unserved and underserved markets.
13
  It 
further claims that its networks currently support the subscribers of other service providers through 
roaming and other commercial arrangements.
14
  In its capacity as a provider of wholesale 4G LTE 
wireless voice and broadband services in unserved and underserved areas, Wireless Partners states that it 
“has concrete information regarding areas where wireless service is available and where it is not” that is 
relevant to the MF-II challenge process.
15
  Furthermore, Wireless Partners has demonstrated its interest in 
the MF-II challenge process by participating in the associated rulemaking proceeding.
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6. Wireless Partners also has plausible ability to submit the data necessary to support a valid 
challenge.  In particular, Wireless Partners asserts that it has the resources of a facilities-based provider of 
4G LTE voice and broadband data services.
17
  Wireless Partners also claims to have experience with 
wireless network performance testing.
18
  Moreover, as indicated above, Wireless Partners states that it has 
“concrete information regarding areas where wireless service is available and where it is not.”
19
  Thus, we 
7
 Id. at 1.
8
 Id. at 1-2. 
9
 47 CFR § 1.3 (“Any provision of the rules may be waived by the Commission on its own motion or on petition if 
good cause therefor is shown.”).
10
 Ne. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).  In making this determination, the 
Commission may “take into account considerations of hardship, equity, or more effective implementation of overall 
policy.”  WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969).
11
 Ne. Cellular Tel. Co., 897 F.2d at 1166.
12
 MF-II Challenge Process Order at 6304, para. 43 & n.119.
13
 Petition for Waiver at 1-2.
14
 Id. at 2.
15
 Id.
16
 Letter from Robert Parsloe, President & CEO, Wireless Partners, LLC, to Marlene H. Dortch, Secretary, FCC, 
WT Docket No. 10-208, WC Docket No. 10-90, at 1 (June 21, 2017); Wireless Partners, LLC, Reply at 1-3.
17
 Petition for Waiver at 2.
18
 Id.
19
 Id.
Federal Communications Commission DA 18-318
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conclude that there is good cause for granting the requested waiver and instruct USAC to grant the users 
included in Wireless Partners’ Petition for Waiver access to the MF-II challenge portal.  
IV. ORDERING CLAUSES
7. Accordingly, IT IS ORDERED, pursuant to the authority contained in sections 4(i), 254, 
303(r), and 332 of the Communications Act of 1934, as amended, and section 706 of the 
Telecommunications Act of 1996, 47 U.S.C. §§ 154(i), 254, 303(r), 332, 1302, and sections 0.131(a), 
0.331, and 1.3 of the Commission’s rules, 47 C.F.R. §§ 0.131(a), 0.331, and 1.3, that the Petition for 
Waiver of Wireless Partners, LLC, is HEREBY GRANTED to permit it to participate in the MF-II 
challenge process.
8. IT IS FURTHER ORDERED that, pursuant to section 1.102(b)(1) of the Commission’s 
rules, 47 CFR § 1.102(b)(1), this Order SHALL BE EFFECTIVE upon release.
FEDERAL COMMUNICATIONS COMMISSION
Margaret W. Wiener
Chief, Auctions and Spectrum Access Division
Wireless Telecommunications Bureau