Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY
I tried to follow this questionnaire but I quickly got lost. Is there a reader's digest version of the issues at play? thanks, marlon - Original Message - From: "Rick Harnish" To: "'WISPA General List'" Sent: Thursday, May 27, 2010 9:13 AM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY > Done > > Please take the survey. http://www.surveymonkey.com/s/XC5DF7F There are > 10 > questions on two pages. You must answer all statements with Agree, > Undecided or Disagree to proceed. > > I would have liked to have asked whether the responders are a member or a > non-member but we are only allowed 10 questions per survey and I didn't > have > room. > > Thanks, > Rick Harnish > >> -Original Message- >> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On >> Behalf Of David E. Smith >> Sent: Thursday, May 27, 2010 11:29 AM >> To: WISPA General List >> Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband >> >> On Thu, May 27, 2010 at 04:55, MDK wrote: >> >> [ snip: a lot of interesting ideas with which I personally disagree >> but they're still interesting ideas ] >> >> > This idea recognizes and codifies that subsidy = threat of regulation >> and >> > that free markets with a competitive environment do NOT need any >> regulation >> > to provide workable services to consumers. >> >> Does WISPA have any mechanism in place for polling the membership, to >> see whether MDK's ideas really have the kind of support he thinks they >> do? I think the membership is large enough that it's not necessarily >> fair/wise to assume that nine board members can accurately assess >> these things. >> >> MDK: ever consider running for a spot on the board? That's one way to >> be sure WISPA is listening to your views. :) >> >> David Smith >> MVN.net >> >> >> --- >> - >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> --- >> - >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
> Tom: There no reason on earth that the exception must create the rule. > If Alaska wants subsidized phone service, then Alaska can frankly do it on > its own.Any objections? Having been to Alaska, a few parts of it, > and > observed the function of the incumbent telco, I have completely ZERO > sympathy for anyone who says that GCI, et al, is desperately in need of > massive federal bailouts/subsidies/funding. They have complete > monopolistic control of just about every byte of TCP/IP traffic, every > phone > call, and every text message in the vast majority of the state, a position > beaurocratically ensured for the next eon, by many factors. There is > no > reason on earth to use Alaska as a template for tax, communications, or > any > other policy anywhere else in the other 48 states. > Allthough those arguements can be made, none-the-less, I'd recommend speaking to an Alaskan Congressman, and man will you get a convincing story telling you other wise. And they are good at telling their soapbox story. Resistane will be found here, and the politics to follow. Thats all I'm really saying. > 3) Rural America needs better mobile phone coverage. Subsidees are needed, > > Sure. Let's let the market do it.Want to know how? I have the > perfect idea, and NO subsidy is needed at all... AT ALL.Keep reading. Although I'm for the market to work it out, after all I live in an areas where the market is strong, But again there will be resistence to "just let the market work it out", for one reason. The topic (communication) is to important for anything but a success, and that needs to be guaranteed, for the good of the nation. Whether money is misused or overspent is a secondary concern. At the end of the day it comes down to America is only as strong as its weakest link, and when all states in America are at their strongest, America as a whole will be stronger. Thats the whole foundation of being a united 50 state America. A strong state can help a weak state on one topic and vice versa on another. For example, what if the Rural Western/Central States said, "we have plenty of food, but its ours, if the East coast Urban cities want to eat, they'll need to build their own farms"? (actually, we have our own farms, this was jsut a hypthothetical example). Many Western/Cemtral Farms are subsidized, to guarantee Food will never be a shortage. Following the arguements to disband USF, would one equally have the opinion that Farms should no longer be subsidized, and if food ran out, oh well, tough luck? It wont be hard to gain acceptance to disband USF for arguements like "its a broken system, outdated system, and there is now a better way", and proving that. But I dont think we'll ever gain acceptance of an arguement similar to "let them take care of their own problem, or leave them on their own at the mercy of the market." >> a >> fund that already exists and does not come from WISP's pcoket, where will >> it >> come from. If mobile is needed, something needs to pay for it. Will >> future > > It isn't needed.Frankly, if we could have some 600 or 700 mhz slices > of > spectrum, with appropriate rules for some channels set aside for the > purpose, we could deploy our own version of "cellular" in small towns Thats the golden issue isn't it. In my young twentie, I used to say, "If I could just live 6 months rent free, I could save my money, and then start a company that would enable me to have a higher fair income, and I'd be able to get out of the pay check to paycheck debt struggle. Thing is... rent wasn't free. There is a cost associated with housing and its a resource in demand controlled by the marklet. I had to face reality, rent isn't free. Its the same thing with wireless, spectrum is a valued resource in short suply, Spectrum isn't free. With that said, we might have that choice anyways. If TV Whitesacpe finally gets released to WISPs, that valuable resource will be free to us. It will be a science project, for the feds to learn if when Spectrum is available does it really enable investment in deployment. The other arguement with spectrum is that it does exist. For example, 2.5Ghz exists all over the country. Who's faught is it if we were not insightfull enough to buy it, when it could be had at the right price, out of auction? I know for a fact some cases where Sprint leased the spectrum licesnes from schools (that owned it) in rural towns for as little as $2000 total for the license period. Not having spectrum will not be a good defense. The answer would just be to give the money and aid to the companies that already have the spectrum and resources to more optimally succeed. Then the problem would be cured, just not by us. As well, the principle behind auctions is taht items will be sold for their true worth, what someone is willing to pay for it. People ar willing to pay a price because they calculate they can get a retu
Re: [WISPA] How the FCC Proposes the Regulate Broadband
++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ -- From: "Tom DeReggi" Sent: Friday, May 28, 2010 9:36 AM To: "WISPA General List" Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Matt, > > Although I agree with most of what you say, specifically there are huge > risks that USF will just go straight to the Cellular carriers to build out > more mobile phone towers to deliver broadband. In order to win a battle to > dispand USF, we have to effectively combat other's objections to that. > > What would you propose we respond to the following common objections > > 1) Alaska - Full of Icy sub-zero weather, surrounded by frozen water, very > rural. Without USF subsidee not only would communications providers fail, > but the people that are served would be at severe risk. These > communicatiosn > are absolutely necessary for healtch care and public safety. The > alternative > optiosn to communbicate jsut dont exist. This territory can be the most > expensive and challenging to serve. Without USF, these Americans will be > left out in the cold. Alaska has some very influencial > senators/legislators > protecting USF. Tom: There no reason on earth that the exception must create the rule. If Alaska wants subsidized phone service, then Alaska can frankly do it on its own.Any objections? Having been to Alaska, a few parts of it, and observed the function of the incumbent telco, I have completely ZERO sympathy for anyone who says that GCI, et al, is desperately in need of massive federal bailouts/subsidies/funding. They have complete monopolistic control of just about every byte of TCP/IP traffic, every phone call, and every text message in the vast majority of the state, a position beaurocratically ensured for the next eon, by many factors. There is no reason on earth to use Alaska as a template for tax, communications, or any other policy anywhere else in the other 48 states. > > 2) If a Rural Telco fails, consumers will be left without communications. > Shouldn't competitive provider options be available to all homes, before > the > solution in place that works is dispanded. How can we be certain that > Rural > Telcos will be able to survive without their subsidees? To get their > subsidees in the first place they likely had to prove their need, in order > to qualify. Other than just self-perception, what evidence do we have to > support our claim, that Rural USF recipients can survive without the > continued subsidees? I'm sympathetic to the plight of people who live in rural areas and whose telco has been built upon the permanence of subsidy, however... buyer beware... Perhaps a good bankruptcy would be in order, and management who can figure out how to offer POTS service to small communities without the benefit of massive subsidy should be in charge, rather than just using them as an excuse to perpetuate a bad idea. The ever decreasing numbers of copper lines in use should clue some bright individual into building a model based upon some internet bandwidth and VOIP and some inexpensive switching to get the job done for peanuts.Lots of members of this list can explain how it could be done for surprisingly small costs. Some reduced regulation of how the service must be offered and so on, could make reasonably priced business and technology models completely the normal order of the day. > > 3) Rural America needs better mobile phone coverage. Subsidees are needed, Sure. Let's let the market do it.Want to know how? I have the perfect idea, and NO subsidy is needed at all... AT ALL.Keep reading. > thats why coveratge is not there now. If USF got disbanded would it > reduce No, that's not why.Rural coverage stinks because it costs an absolute FORTUNE to put in. Why? 1. Spectrum costs 2. standards and practicses of large cellular co's are NOT cost efficient. 3. Investment must have huge ROI to pay for the damn spectrum auctioned off. > the subsidees to Mobile carriers, or would it indirectly steal future > funding sources WISPs? If mobile expansion funding is not gotten from USF, > a > fund that already exists and does not come from WISP's pcoket, where will > it > come from. If mobile is needed, something needs to pay for it. Will future It isn't needed.Frankly, if we could have some 600 or 700 mhz slices of spectrum, with appropriate rules for some channels set aside for the purpose, we could deploy our own version of "cellular" in small towns and rural areas lacking mobile telephony.Just as long as we don't have to raise 700 million to own some theoretical right to use
Re: [WISPA] How the FCC Proposes the Regulate Broadband
++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ -- From: "Tom DeReggi" Sent: Friday, May 28, 2010 8:15 AM To: "WISPA General List" Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > I've always been pro-tax credit, based on my personal agenda. > I think it incourages investment, not only helps reduce an ISP's tax > burden. > > However, from my experience debating ARRA, I learned there can be some > disadvantages of Tax Credits. > The BIG disadvantage for WISPs is that it helps Large Telcos and Cable Cos > and large scale VC backed companies the most. They have tons of income > they'd love to have tax relief from. Did you read what my proposal was? Because as it is, I cannot possibly see how this scenario could possibly be true. Please, keep reading. They also have tons of money to > invest, WISPs may have less comparatively. Probaly the best way to get > FIOS > built out to your community, to put the local WISP out of business, is to > give Verizon a healthy Tax credit to Invest there. As is defined by "my community", and as defined as I defined things in my proposal, I reach 9 different "communities". What I cover would be in 9 different segments, 6 of which would contain under 3000 people. Verizon is NOT going to build out 50 miles of fiber to reach 95% of the roughly 2500 people (1000 rooftops) in my hometown (my zip code), just so they could get a tax credit of 5, 10, or even 20 or 50 dollars/month / customer in my area, especially if that lasts for 3 or 4 years, max.Because no matter what they offered, I could come right behind them and simply offer VASTLY less expensive service and get a LOT better ROI. Verizon would be insane to even try. If the credit was $50/month, I'd simply declare "free internet for a limited time" and for a $150 install fee, they'd get "free" internet for as long as that subsidy lasted. And then $40 after that. Verizon can't compete with that. Their needed 30 years of revenue to amortize would not exist. The next question is: Where would they build out fiber, where no competition exists, with 'near universal coverage', where a single zip could would net them huge numbers of customers? Nowhere. Such scenarios don't exist anymore outside of smalltown/rural/unusual areas.And, if that kind of per-person refund did exist, the chance that no competitor would come along to capitalize on it and bring the subsidy to an automatically triggered end is real small. > > The bottom line is large companies have cash and favorable borrowing > capabilty and have no problem looking at 30 years out to gain their ROI. That's all fine and good, but we're not talking about subsidy for 30 years. More like 2 to 5 or maybe 8, tops. > WISPs on the other hand tend to be more upfront cash constrainted. Even > lending can be limted due to insufficient colladeral. Now I understand > many > business owners are better off than others in their ablty to get larger > scale funding. But as projects scale larger, it becomes more of a > challenge. > The Large Telcos (and USF ILECs) always will have more recognized > colladeral. Yes, and they are technologically constrained. And, beaurocratically hampered from being anywhere near the efficient models of a small business. > This is one of the reasons that in ARRA lobbying that the concept of Loan > assistance and Grants was preferable to lobby for. That would be more > beneficial to a WISP than a tax credit on income they never had, because > they never were able to fund their proposed project in the first place. But they have the manpower, lawyers, accountants, and lobbyists to kick us to the curb in terms of getting those. besides, WHY WOULD I WANT MORE DEBT??? If someone came to me and said "You qualify for 200,000 line of credit, at terms that seemed fantastic... I would NOT take it.Once burned, twice shy.I'm going to own this business, not rent it from the lender.I've finally reached the point where I got enough money coming in to make some growth investment every month, enough to be meaningful to my business. And I do. Every month it's upgrades to stuff, new sites, more capacity, or "little cost" install deals or whatever.I'm leveraging every dime I can and what debts I have have tought me to STAY OUT. Further, the "lending/grants" methods are all about how to play the game, not making the best use of what capital you have. It doesn't fund the best ideas. It funds the best application (fantasy) writer. > > The question to be asked is. Do we wan
Re: [WISPA] How the FCC Proposes the Regulate Broadband - NTIA Press release today
The NTIA just did a press release today saying they are going to let the state broadband mapping agencies modify their grants for the mapping efforts http://www.ntia.doc.gov/press/2010/SBDDNewWindow_05282010.html Not to sound self serving but to get better WISP participation, and showing many of these supposed unserved areas are really served, WISPA could support the idea of each state paying someone who understands how to properly map WISP coverage and convert that information to a GIS format. If the WISP were to do this with an entity they trust, and that works with the WISP to make sure the map results are accurate, this may help to accurately identify these truly unserved areas. I have talked to many WISP's who felt the requests for information by the states was burdensome and those that did see results were not happy with the end product as it seemed to be inaccurate. If a trusted party did the mapping, the final coverage could be released without having to give up all kinds of other proprietary data. Just a thought as I read this press release.. There may not be so many people unserved as the government currently thinks and thus could be good ammunition to argue against a USF fund. Hard to argue that fact if there is no independent data to back it up. Brian -Original Message- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Tom DeReggi Sent: Friday, May 28, 2010 5:16 PM To: WISPA General List Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband While I'm at it Next Quesetions Im sure the feds will easilly understand why we WISPs want the USF to be killed. But, should the feds accommodate the intersts of 1000 WISPs/ISPs or a 100 million rural consumers? At the end of the day, there is an acknowledged digital divide, and something needs to be done about it, in the Fed's minds. As it sits today, do WISPs / small ISPs have enough capitol and funding to cure it? Can we get broadband to 99% of Americans in 5 years, like AT&T TV Commercials say they can? I'd argue not. Lets lower the sandard Can WISPs/small ISPs accomplish the penetration goals stated in the NBP first draft? (I forget what they are exactly , but something like 50mb or higher to 100 million homes and atleast 5mbps to everywhere else.) I'd like to think we could, but honestly I think thats still stretching our capabilty without assitance. So how do we propose that the Digital divide be cured, and funded, if USF gets killed? Currently, Feds would like to redirect USF funds, and that is targeted as a potential solution, even if it kills WISPs. (We are expendable, if consumers get broadband). If we argue that USF funds are used inefficiently, wont the defense be to "reform USF" so it will be used efficiently instead? Sure we can argue that it never will be. But not sure policy makers will accept the answer (or I should say insult) that they aren't capable. I dont think we can effectively argue there is no problem to solve. Specifically Brian Webster's report supports 24% of America is still unserved. So in summary, the question is. How are we going to fund solving the rural digital divide in a timely fassion? I recognize, we could simply reply, "dont know, but USF clearly isn't it, for X reasons.". But it would be great if we could give them the alternative. I recognize this is not an easy question. For example the entire NBP was written to start to address the answer. Policy makers are heavilly advocating "for all Americans". I've been asked and tested by policy makers, with the question, "Can I serve everyone in my coverag area.". And I have to truthfully say "no, I can not.". That is one of the reasons feds show favoratism to the ILECs(mini monoplies). This is a problem. I'm not sure feds are as worried abouyt efficient use of money as much as getting the job done. ILECs have a proven record to get it done with VOIP, why could they not do the same with Broadband, if they got the USF free handout. At the end of the day, we need to tell Congress what we need to get the job done, or if we already have what we need, our better plan that will replace USF. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message ----- From: "Matt Larsen - Lists" To: "WISPA General List" Sent: Friday, May 28, 2010 3:39 PM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Tom, > > Thank you for asking your questions - I have some awesome answers for > you. > > 1) Alaska. Alaska does indeed have an infrastructure problem. > Alaska also receives an enormous amount of federal support already along > with substantial revenues from their natural resources, mainly oil and > gas. These Americans would not be left out in the c
Re: [WISPA] How the FCC Proposes the Regulate Broadband
> Those companies you fear have always had more money than our ISPs. It's > about customer service and adopting technology, that we survive, not by > financial superiority. I only partially agree. The facts are, people with funding can build faster than those that dont and have to fund their expansion through cash flow as they earn it. Its not about being able to compete with them, its about them getting there first. Once someone has service, that is fast and inexpensive, its tough to lewer them away afterwords. I can give an example of today... A fiber provider just tried to steal one of my customers, by undercutting me by 400% on dollars and increasing the speed by factor of 10. My customer called me, to negotiate because they valued my customer service. But none the less it was an offer they could not ignore, no matter how good my custoemr service. I kept the customer, but at the end of the day, I had to match the price. I cant afford to do that with everyone, but they could. Financial superiority does have a lot to do with it. > That's a lot of assumptions. > Let me rephrase my statement. The issue of "rurality" regarding "home density per Sq mile" (aka population) is not enough to justify the opinion that a monopoly is needed for operations to be profitable and sustainable. That was my point. Environmental Barriers on the other hand may. Non-Line-of-Site, whether Dense Foliage or hilly terrain is a wireless business plan killer. And fiber's higher cost or cost of wireless models to get around those challenges, can be financially difficult. In those cases, subsidees may be required, I fully agree. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "jp" To: "WISPA General List" Sent: Friday, May 28, 2010 5:20 PM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > On Fri, May 28, 2010 at 11:15:08AM -0400, Tom DeReggi wrote: >> I've always been pro-tax credit, based on my personal agenda. >> I think it incourages investment, not only helps reduce an ISP's tax >> burden. >> >> However, from my experience debating ARRA, I learned there can be some >> disadvantages of Tax Credits. >> The BIG disadvantage for WISPs is that it helps Large Telcos and Cable >> Cos >> and large scale VC backed companies the most. They have tons of income >> they'd love to have tax relief from. They also have tons of money to >> invest, WISPs may have less comparatively. Probaly the best way to get >> FIOS >> built out to your community, to put the local WISP out of business, is to >> give Verizon a healthy Tax credit to Invest there. > > Those companies you fear have always had more money than our ISPs. It's > about customer service and adopting technology, that we survive, not by > financial superiority. > >> If the goal is to help more American get faster broadband sooner, Tax >> Credits is a great idea. But if the goal is to help make sure WISPs >> becomes >> a larger part of that solution, I'm not so sure it helps us. >> Strategically, >> it would benefit WISPs if we could discourage investment from large >> carriers. > > That first goal is one that would be supported and we should be able to > say our goal is not contrary to that. > >> The other thing is that Tax Credits equally rewards all spending whether >> it >> is efficent or wasteful spending. Dont we want policy that focuses >> rewards >> to those that spent more efficiently? WISP's advantage is that they have >> more affordable cost of deployment. >> >> One of the things I challenge today is where there is any place left on >> teh >> planet in rural America that is not cost effective to serve with >> wireless? >> With the exception of Tower costs. If line of sight can be acheived, and >> twoers are needed, the cost to deploy an area can skyrocket. But >> otherwise, >> even rural areas of 1 home per square mile can be afforded with Fixed >> Wireless. HAving a low dnsity is actually preferred. When a 2.4Ghz AP >> can >> extend 20 miles, and can only support about 20-50 homes per AP, its a >> perfect match for low density rural terrain. > > That's a lot of assumptions. > > http://www.f64.nu/photo/tmp/jeffersonsouth/ > > Here's an IR panorama from a tower we just put up last year in one of > the best locations in our service area. You can see a few houses around > the tower/hill site, but otherwise as far as you can see it's trees and > 90%+ of customers require NLOS solutions due to trees. This was not cost > effective to serve without a stat
Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY
I agree. Most of the questions are too convoluted to clearly understand. For a survey like this to have any meaning at all, the questions need to be written clearly so everyone will understand them the same way. Leon D. Zetekoff wrote: On 5/27/2010 12:13 PM, Rick Harnish wrote: Done Please take the survey. http://www.surveymonkey.com/s/XC5DF7F There are 10 questions on two pages. You must answer all statements with Agree, Undecided or Disagree to proceed. I would have liked to have asked whether the responders are a member or a non-member but we are only allowed 10 questions per survey and I didn't have room. T Hi RIck...can the grammar be improved? leon No virus found in this outgoing message. Checked by AVG - www.avg.com Version: 9.0.819 / Virus Database: 271.1.1/2897 - Release Date: 05/26/10 02:25:00 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- Jack Unger - President, Ask-Wi.Com, Inc. Network Design - Technical Training - Technical Writing Serving the Broadband Wireless, Networking and Telecom Communities since 1993 www.ask-wi.com 818-227-4220 jun...@ask-wi.com WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
I'll be there. But if we keep getting all this good feedback from everyone, there wont be much left to debate :-) Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "Forbes Mercy" To: "WISPA General List" Sent: Friday, May 28, 2010 4:39 PM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband >I nominate Matt Larsen to serve on the panel for USF at the Regional > Meeting! Wouldn't it be interesting if Tom was on there to? I'd go just > for the debate! > > On 5/28/2010 12:39 PM, Matt Larsen - Lists wrote: >> Tom, >> >> Thank you for asking your questions - I have some awesome answers for >> you. >> >> 1) Alaska. Alaska does indeed have an infrastructure problem. >> Alaska also receives an enormous amount of federal support already along >> with substantial revenues from their natural resources, mainly oil and >> gas. These Americans would not be left out in the cold - communication >> wise - if they took some of their massive piles of money and built out >> their infrastructure. Right now, the Alaska Permanent Fund - >> http://en.wikipedia.org/wiki/Alaska_Permanent_Fund - has 28 Billion >> dollars in it, and is primarily used to pay an annual dividend to Alaska >> residents. I'm pretty sure that money would go to better use if Alaska >> used that to pay for their communications infrastructure needs instead >> of expecting the residents of the lower-48 to pay for it. >> >> 2) Rural Telco Failure. I have a really hard time believing that a >> rural telco could fail, but I guess it could happen. In that scenario, >> I would suggest that the government set up some kind of a trustee >> operation that maintained the operation of the telco until a buyer could >> be found. I live in a very rural area, and the majority of the rural >> ILECs here are swimming in money from USF, and have very successful >> "unregulated" subsidiaries that operate outside of the normal regulatory >> environment. With all of the recent advances in voice switching and >> remote broadband deployment, the residents of a community with a >> failling telco would be better off in the long run if the telco was >> allowed to fail and someone else was able to come in and rebuild with >> more modern equipment. This is a little tricky, but could be addressed >> in a more efficient manner than what we are seeing now. >> >> 3) Mobile Phone Coverage. There is a really simple answer to this >> one. There are buildout requirements in cellular licenses that the >> federal government grants to mobile carriers. They have been >> effectively lobbbying to get USF money to build out and meet those >> requirements. Even so, rural cellular coverage is awful. USF has >> been the carrot to incentivize rural wireless buildouts - now it is time >> to try the stick. Rural carriers that don't build out, or only build >> out the areas with with Interstates and highways (for roaming traffic) >> without building out to the sparsely populated rural locations lose >> their licenses. This will lower the value of the licenses in rural >> areas to the point where smaller competitors could feasibly buy licenses >> and compete. It would also substantially reduce the amount of spectrum >> warehousing that goes on in rural areas. No need to throw money at >> this problem, just enforce the existing laws and modify the requirements >> so that there is less "redlining" of the more profitable portions of >> their license area. >> >>I think that the idea of pitting the New Jersey delegation against the >> Alaska delegation is fantastic. Why should people in NJ be paying for >> phone services in Alaska? >> >> I would like to close with an illustration of what goes on with USF. >> USF is attached to every access line, and looks pretty innocuous on a >> single line phone bill. However, when I was running a dialup ISP and >> we had several hundred lines coming into our system, that USF cost was >> in the $3000/$4000 range every month. Especially frustrating was that >> one of my main competitors was the "unregulated" subsidiary of a nearby >> rural ILEC that was receiving a ton of USF money, had access to low >> interest capital from USDA and was receiving reciprocal compensation for >> terminating phone calls to their ISP system. In my mind, that >> $4000/month was going right to them to compete with me.Their >> subsidiary did not receive the money directly, but it paid the salaries >>
Re: [WISPA] How the FCC Proposes the Regulate Broadband
While I'm at it Next Quesetions Im sure the feds will easilly understand why we WISPs want the USF to be killed. But, should the feds accommodate the intersts of 1000 WISPs/ISPs or a 100 million rural consumers? At the end of the day, there is an acknowledged digital divide, and something needs to be done about it, in the Fed's minds. As it sits today, do WISPs / small ISPs have enough capitol and funding to cure it? Can we get broadband to 99% of Americans in 5 years, like AT&T TV Commercials say they can? I'd argue not. Lets lower the sandard Can WISPs/small ISPs accomplish the penetration goals stated in the NBP first draft? (I forget what they are exactly , but something like 50mb or higher to 100 million homes and atleast 5mbps to everywhere else.) I'd like to think we could, but honestly I think thats still stretching our capabilty without assitance. So how do we propose that the Digital divide be cured, and funded, if USF gets killed? Currently, Feds would like to redirect USF funds, and that is targeted as a potential solution, even if it kills WISPs. (We are expendable, if consumers get broadband). If we argue that USF funds are used inefficiently, wont the defense be to "reform USF" so it will be used efficiently instead? Sure we can argue that it never will be. But not sure policy makers will accept the answer (or I should say insult) that they aren't capable. I dont think we can effectively argue there is no problem to solve. Specifically Brian Webster's report supports 24% of America is still unserved. So in summary, the question is. How are we going to fund solving the rural digital divide in a timely fassion? I recognize, we could simply reply, "dont know, but USF clearly isn't it, for X reasons.". But it would be great if we could give them the alternative. I recognize this is not an easy question. For example the entire NBP was written to start to address the answer. Policy makers are heavilly advocating "for all Americans". I've been asked and tested by policy makers, with the question, "Can I serve everyone in my coverag area.". And I have to truthfully say "no, I can not.". That is one of the reasons feds show favoratism to the ILECs(mini monoplies). This is a problem. I'm not sure feds are as worried abouyt efficient use of money as much as getting the job done. ILECs have a proven record to get it done with VOIP, why could they not do the same with Broadband, if they got the USF free handout. At the end of the day, we need to tell Congress what we need to get the job done, or if we already have what we need, our better plan that will replace USF. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "Matt Larsen - Lists" To: "WISPA General List" Sent: Friday, May 28, 2010 3:39 PM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Tom, > > Thank you for asking your questions - I have some awesome answers for > you. > > 1) Alaska. Alaska does indeed have an infrastructure problem. > Alaska also receives an enormous amount of federal support already along > with substantial revenues from their natural resources, mainly oil and > gas. These Americans would not be left out in the cold - communication > wise - if they took some of their massive piles of money and built out > their infrastructure. Right now, the Alaska Permanent Fund - > http://en.wikipedia.org/wiki/Alaska_Permanent_Fund - has 28 Billion > dollars in it, and is primarily used to pay an annual dividend to Alaska > residents. I'm pretty sure that money would go to better use if Alaska > used that to pay for their communications infrastructure needs instead > of expecting the residents of the lower-48 to pay for it. > > 2) Rural Telco Failure. I have a really hard time believing that a > rural telco could fail, but I guess it could happen. In that scenario, > I would suggest that the government set up some kind of a trustee > operation that maintained the operation of the telco until a buyer could > be found. I live in a very rural area, and the majority of the rural > ILECs here are swimming in money from USF, and have very successful > "unregulated" subsidiaries that operate outside of the normal regulatory > environment. With all of the recent advances in voice switching and > remote broadband deployment, the residents of a community with a > failling telco would be better off in the long run if the telco was > allowed to fail and someone else was able to come in and rebuild with > more modern equipment. This is a little tricky, but could be addressed > in a more efficient manner than what we are seeing now. > > 3) Mobile Phone Cov
Re: [WISPA] How the FCC Proposes the Regulate Broadband
> on our subscribers. Its one of the hidden charges on teh telco bill, that > helps reduce how much RBOCS out price us. How many WISPs advertise, "no > hidden charges"? > > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > - Original Message - > From: "MDK" > To: "WISPA General List" > Sent: Friday, May 28, 2010 1:09 AM > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > > > > Please note that I said "refundable" tax credits. That is, if your > > credits > > are more than your taxes, you get a check back. > > > > This could be done so that your refunds would be quarterly. > > > > > > > > > > > > > > ++ > > Neofast, Inc, Making internet easy > > 541-969-8200 509-386-4589 > > ++ > > > > -- > > From: "Scottie Arnett" > > Sent: Thursday, May 27, 2010 8:24 PM > > To: "WISPA General List" > > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > > > >> > >> Considering past tax rebates, or credits, to take full advantage would > >> require that you are way in the black. This would help newer WISP > >> somewhat, but most are in the red from the beginning. It would definitely > >> help sustained WISP's that have been at it for a few years. > >> > >> Scottie > >> > >>> -- > >>> /* > >>> Jason Philbrook | Midcoast Internet Solutions - Wireless and DSL > >>> KB1IOJ| Broadband Internet Access, Dialup, and Hosting > >>> http://f64.nu/ | for Midcoast Mainehttp://www.midcoast.com/ > >>> */ > >>> > >>> > >>> > >>> WISPA Wants You! Join today! > >>> http://signup.wispa.org/ > >>> > >>> > >>> WISPA Wireless List: wireless@wispa.org > >>> > >>> Subscribe/Unsubscribe: > >>> http://lists.wispa.org/mailman/listinfo/wireless > >>> > >>> Archives: http://lists.wispa.org/pipermail/wireless/ > >>> > >> > >> > >> > >> > >> > >> WISPA Wants You! Join today! > >> http://signup.wispa.org/ > >> > >> > >> WISPA Wireless List: wireless@wispa.org > >> > >> Subscribe/Unsubscribe: > >> http://lists.wispa.org/mailman/listinfo/wireless > >> > >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > > > > > > WISPA Wants You! Join today! > > http://signup.wispa.org/ > > > > > > WISPA Wireless List: wireless@wispa.org > > > > Subscribe/Unsubscribe: > > http://lists.wispa.org/mailman/listinfo/wireless > > > > Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ -- /* Jason Philbrook | Midcoast Internet Solutions - Wireless and DSL KB1IOJ| Broadband Internet Access, Dialup, and Hosting http://f64.nu/ | for Midcoast Mainehttp://www.midcoast.com/ */ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
I'm glad I asked. Good answers. So let me ask one more to both you and membership... Why would we possibly want to lobby to keep USF? Is there one? (That is realistic and legelly viable to achieve.) Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "Matt Larsen - Lists" To: "WISPA General List" Sent: Friday, May 28, 2010 3:39 PM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Tom, > > Thank you for asking your questions - I have some awesome answers for > you. > > 1) Alaska. Alaska does indeed have an infrastructure problem. > Alaska also receives an enormous amount of federal support already along > with substantial revenues from their natural resources, mainly oil and > gas. These Americans would not be left out in the cold - communication > wise - if they took some of their massive piles of money and built out > their infrastructure. Right now, the Alaska Permanent Fund - > http://en.wikipedia.org/wiki/Alaska_Permanent_Fund - has 28 Billion > dollars in it, and is primarily used to pay an annual dividend to Alaska > residents. I'm pretty sure that money would go to better use if Alaska > used that to pay for their communications infrastructure needs instead > of expecting the residents of the lower-48 to pay for it. > > 2) Rural Telco Failure. I have a really hard time believing that a > rural telco could fail, but I guess it could happen. In that scenario, > I would suggest that the government set up some kind of a trustee > operation that maintained the operation of the telco until a buyer could > be found. I live in a very rural area, and the majority of the rural > ILECs here are swimming in money from USF, and have very successful > "unregulated" subsidiaries that operate outside of the normal regulatory > environment. With all of the recent advances in voice switching and > remote broadband deployment, the residents of a community with a > failling telco would be better off in the long run if the telco was > allowed to fail and someone else was able to come in and rebuild with > more modern equipment. This is a little tricky, but could be addressed > in a more efficient manner than what we are seeing now. > > 3) Mobile Phone Coverage. There is a really simple answer to this > one. There are buildout requirements in cellular licenses that the > federal government grants to mobile carriers. They have been > effectively lobbbying to get USF money to build out and meet those > requirements. Even so, rural cellular coverage is awful. USF has > been the carrot to incentivize rural wireless buildouts - now it is time > to try the stick. Rural carriers that don't build out, or only build > out the areas with with Interstates and highways (for roaming traffic) > without building out to the sparsely populated rural locations lose > their licenses. This will lower the value of the licenses in rural > areas to the point where smaller competitors could feasibly buy licenses > and compete. It would also substantially reduce the amount of spectrum > warehousing that goes on in rural areas. No need to throw money at > this problem, just enforce the existing laws and modify the requirements > so that there is less "redlining" of the more profitable portions of > their license area. > > I think that the idea of pitting the New Jersey delegation against the > Alaska delegation is fantastic. Why should people in NJ be paying for > phone services in Alaska? > > I would like to close with an illustration of what goes on with USF. > USF is attached to every access line, and looks pretty innocuous on a > single line phone bill. However, when I was running a dialup ISP and > we had several hundred lines coming into our system, that USF cost was > in the $3000/$4000 range every month. Especially frustrating was that > one of my main competitors was the "unregulated" subsidiary of a nearby > rural ILEC that was receiving a ton of USF money, had access to low > interest capital from USDA and was receiving reciprocal compensation for > terminating phone calls to their ISP system. In my mind, that > $4000/month was going right to them to compete with me.Their > subsidiary did not receive the money directly, but it paid the salaries > of their staff and generated traffic into their system to generate more > money. It also allowed them to either buy or bid up the price on > 700mhz spectrum for a big chunk of the state of Nebraska - and they are > only deploying service in part of it. Also paid the salaries of the > people on their staff that do nothing but fill out government forms and > apply for grants from f
Re: [WISPA] How the FCC Proposes the Regulate Broadband
oing less than $10million a year in revenue. Tax >> credits to tower companies that colocate/lease to atleast one local WISP >> (such as one doing less than $10million a year with a local office). In >> otherwords give help to those that help companies that are looked at as >> higher risk. I'd like to see fed help grow an industry of competitors, not >> just cater to consumer demands through monopolies. What we really need to >> do is get Congress involved and convinced that they need to mandate "support >> for small business", and "prevent funding of any monopoly behavior", before >> any future funding or subsidee programs get reformed or formed. >> >> >> Tom DeReggi >> RapidDSL& Wireless, Inc >> IntAirNet- Fixed Wireless Broadband >> >> >> - Original Message - >> From: "Matt Larsen - Lists" >> To: "WISPA General List" >> Sent: Friday, May 28, 2010 3:53 AM >> Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband >> >> >> >> >>> Mark, I would like to thank you for your interesting and obivously well >>> thought out post. >>> >>> I am firmly of the camp that USF should be completely discontinued, and >>> my efforts going forward will be to encourage its disbandment. The >>> major goals of the original USF program have been completed for some >>> time now, and the program is no longer needed. USF is providing >>> unneeded subsidization of wireless cellular carriers, some very large >>> corporations (CenturyLink) and many rural ILECs that take USF money and >>> use it to warehouse spectrum and compete with WISPs. >>> >>> The politically correct thing to do would be to find allies for our >>> other positions and offer to support USF reform that will be inclusive >>> of WISPs. I have had enough experience with the paperwork, legal >>> wrangling and political skullduggery at the state and federal levels >>> involved in getting USF to recognize that it is almost totally >>> incompatible with WISPs. USF is HURTING the deployment of broadband in >>> the US by supporting the entities that have either failed to deliver >>> broadband to many of their rural service areas (CenturyLink), have >>> delivered broadband but are now using the funds to subsidize other >>> activities such as spectrum warehousing (many small ILECs) or are using >>> it to fund the buildout of cellular networks (cellphone companies) that >>> provide awful coverage in rural areas. >>> >>> From a philosophical and practical standpoint, USF should be >>> abolished. The funds left in their coffers can be used to establish a >>> smaller, tightly focused program for schools and libraries - entities >>> that are legitimately benefitting from USF. >>> >>> USF has strong support from telcos and they are great at focusing on the >>> tiny parts of the program that are beneficial and the threat that some >>> telcos will "go under" without USF support - while the vast majority of >>> the money that comes out of USF goes to the bottom line of profitable >>> companies with ties to the original monopoly players. >>> >>> It is time for a quick lesson about the economic concept of "Fast >>> Failure". One of the very best features of capitalism and the >>> entrepeneurial environment of the United States is that a business can >>> and should fail if it turns out to not be economically feasible. When >>> that business fails, its resources are redistributed and another >>> business can step in. Subsidizing a business that doesn't need >>> subsidization, or creating a monopolistic situation through >>> subsidization or regulation leads to inefficiencies in the system. USF >>> is being used to support businesses that don't need the support and it >>> creates an anti-competitive environment. >>> >>> I would really like to see USF disappear. It just doesn't make sense >>> to me to try and work with a system that is hopelessly flawed and >>> unrepairable. >>> >>> Matt Larsen >>> vistabeam.com >>> >>> >>> On 5/27/2010 3:55 AM, MDK wrote: >>> >>> >>>> As I write, is it 1:40 AM, I'm tired as heck, but have been mulling this >>>> question for days, and have finally taken the time to do this. First, >>>> to >>>> my self-motivated "enemie
Re: [WISPA] How the FCC Proposes the Regulate Broadband
ut the > > continued subsidees? > > > > 3) Rural America needs better mobile phone coverage. Subsidees are needed, > > thats why coveratge is not there now. If USF got disbanded would it reduce > > the subsidees to Mobile carriers, or would it indirectly steal future > > funding sources WISPs? If mobile expansion funding is not gotten from USF, a > > fund that already exists and does not come from WISP's pcoket, where will it > > come from. If mobile is needed, something needs to pay for it. Will future > > funding opportunities and programs get redirected to mobile instead? Lets > > specifically look at West Virgina and BTOP/BIP. West Virginia got probably > > the largest grant of any ARRA recipient of about $130 million. I Personally > > thought it was an outrage. Most of the funds will go to pay Frontier to > > build fiber backbones, and Verizon to build out Mobile cellular towers and > > LTE. Making Verizon,the wealthiest RBOC one of the largest recipients of > > ARRA funds. Ironically, Verizon plled out of West Virginia as the ILEC, not > > to long ago. And now instead West Virginia pays them to come back to deploy > > mobile. This was the recommendation of the State officials, and strongly > > pushed from West Virginia Congressman, involved in congressional Broadband > > committee. The arguement was that mobile coverage in West Virgina was > > horrid and desperately needed. Many will argue mobile phones are more > > important than Broadband. Cell phones are a success stories, with 3-5 phones > > per household now adays. If the cellular phone tower needs to be build > > anyway, isn't it a better use of funds to take advantage of that > > infrastructure to also colocate a form of broadbnd wireless? Saying we dont > > want subsidees to go to mobile carriers may not get support by rural > > consumers nor policy makers, considering that mobile carriers also own > > license spectrum to deliver more sustainable operations, so they will argue. > > > > Now there is nothing more than I'd like to see is to stop subsidees to > > mobile phone carriers. They have more than enough revenue in urban and > > suburban America to self fund rural America mobility. That is something that > > is proveable, jsut by looking at public stock info, and the huge rate of > > growth the industry has had. It doesn;t need help. > > > > If the goal is to disband USF, it may be worth reaching out to NewJersey's > > congressmen. They are one of the largest payers into the fund, and their > > congressman have been very vocal about disbanding USF, and stopping the > > financial burden put on NewJersey residents. Any New Jersey WISP > > constituents on-list? > > > > > > What I'd like to see is tax credits go to third party investors that > > contribute to equalizing the industry. For example, tax credits to investors > > that invest in companies doing less than $10million a year in revenue. Tax > > credits to tower companies that colocate/lease to atleast one local WISP > > (such as one doing less than $10million a year with a local office). In > > otherwords give help to those that help companies that are looked at as > > higher risk. I'd like to see fed help grow an industry of competitors, not > > just cater to consumer demands through monopolies. What we really need to > > do is get Congress involved and convinced that they need to mandate "support > > for small business", and "prevent funding of any monopoly behavior", before > > any future funding or subsidee programs get reformed or formed. > > > > > > Tom DeReggi > > RapidDSL& Wireless, Inc > > IntAirNet- Fixed Wireless Broadband > > > > > > - Original Message - > > From: "Matt Larsen - Lists" > > To: "WISPA General List" > > Sent: Friday, May 28, 2010 3:53 AM > > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > > > > > > > >> Mark, I would like to thank you for your interesting and obivously well > >> thought out post. > >> > >> I am firmly of the camp that USF should be completely discontinued, and > >> my efforts going forward will be to encourage its disbandment. The > >> major goals of the original USF program have been completed for some > >> time now, and the program is no longer needed. USF is providing > >> unneeded subsidization of wireless cellular carriers, some very large > >> corporations (CenturyLink) and many rural ILECs that take USF money and > >> use it to war
Re: [WISPA] How the FCC Proposes the Regulate Broadband
What would you propose we respond to the following common objections > > 1) Alaska - Full of Icy sub-zero weather, surrounded by frozen water, very > rural. Without USF subsidee not only would communications providers fail, > but the people that are served would be at severe risk. These communicatiosn > are absolutely necessary for healtch care and public safety. The alternative > optiosn to communbicate jsut dont exist. This territory can be the most > expensive and challenging to serve. Without USF, these Americans will be > left out in the cold. Alaska has some very influencial senators/legislators > protecting USF. > > 2) If a Rural Telco fails, consumers will be left without communications. > Shouldn't competitive provider options be available to all homes, before the > solution in place that works is dispanded. How can we be certain that Rural > Telcos will be able to survive without their subsidees? To get their > subsidees in the first place they likely had to prove their need, in order > to qualify. Other than just self-perception, what evidence do we have to > support our claim, that Rural USF recipients can survive without the > continued subsidees? > > 3) Rural America needs better mobile phone coverage. Subsidees are needed, > thats why coveratge is not there now. If USF got disbanded would it reduce > the subsidees to Mobile carriers, or would it indirectly steal future > funding sources WISPs? If mobile expansion funding is not gotten from USF, a > fund that already exists and does not come from WISP's pcoket, where will it > come from. If mobile is needed, something needs to pay for it. Will future > funding opportunities and programs get redirected to mobile instead? Lets > specifically look at West Virgina and BTOP/BIP. West Virginia got probably > the largest grant of any ARRA recipient of about $130 million. I Personally > thought it was an outrage. Most of the funds will go to pay Frontier to > build fiber backbones, and Verizon to build out Mobile cellular towers and > LTE. Making Verizon,the wealthiest RBOC one of the largest recipients of > ARRA funds. Ironically, Verizon plled out of West Virginia as the ILEC, not > to long ago. And now instead West Virginia pays them to come back to deploy > mobile. This was the recommendation of the State officials, and strongly > pushed from West Virginia Congressman, involved in congressional Broadband > committee. The arguement was that mobile coverage in West Virgina was > horrid and desperately needed. Many will argue mobile phones are more > important than Broadband. Cell phones are a success stories, with 3-5 phones > per household now adays. If the cellular phone tower needs to be build > anyway, isn't it a better use of funds to take advantage of that > infrastructure to also colocate a form of broadbnd wireless? Saying we dont > want subsidees to go to mobile carriers may not get support by rural > consumers nor policy makers, considering that mobile carriers also own > license spectrum to deliver more sustainable operations, so they will argue. > > Now there is nothing more than I'd like to see is to stop subsidees to > mobile phone carriers. They have more than enough revenue in urban and > suburban America to self fund rural America mobility. That is something that > is proveable, jsut by looking at public stock info, and the huge rate of > growth the industry has had. It doesn;t need help. > > If the goal is to disband USF, it may be worth reaching out to NewJersey's > congressmen. They are one of the largest payers into the fund, and their > congressman have been very vocal about disbanding USF, and stopping the > financial burden put on NewJersey residents. Any New Jersey WISP > constituents on-list? > > > What I'd like to see is tax credits go to third party investors that > contribute to equalizing the industry. For example, tax credits to investors > that invest in companies doing less than $10million a year in revenue. Tax > credits to tower companies that colocate/lease to atleast one local WISP > (such as one doing less than $10million a year with a local office). In > otherwords give help to those that help companies that are looked at as > higher risk. I'd like to see fed help grow an industry of competitors, not > just cater to consumer demands through monopolies. What we really need to > do is get Congress involved and convinced that they need to mandate "support > for small business", and "prevent funding of any monopoly behavior", before > any future funding or subsidee programs get reformed or formed. > > > Tom DeReggi > RapidDSL& Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > - Original Message -
Re: [WISPA] How the FCC Proposes the Regulate Broadband
Hi Mark, Thanks for taking the time to present your views is such a well thought out fashion. I'm learning a lot from the equally constructive discussion that has followed. You're right to infer that WISPA's official position(s) will be discussed and decided by WISPA Members. Those Members who wish to contribute to forming WISPA official policy have volunteered to participate on WISPA's Legislative and FCC Committees. As a Membership organization, it is WISPA's duty and obligation to represent the Majority views of it's Members. You are welcome at any time to join WISPA and participate on those Committees. I've witnessed first-hand the thorough debate and discussion that goes on at the Committee level. I'm sure with your excellent mind, you would be able to bring additional valuable debate and discussion to these Committees. Committee Members who are especially committed also take the time to read and digest additional opinions as well - as demonstrated by the many Committee Members who have read your comments and shared their opinions on this public list. With regard to WISPA's policy positions - these are already discussed and advocated both publicly and privately both before and after formation. The fact that many WISPA Members are willing to openly discuss their views on this public (open to non-WISPA Members) list demonstrates open advocacy even though the final positions are decided privately by Committee Members. The fact that WISPA's official positions are publicly filed with the FCC and available online as well as published on both public and private WISPA lists demonstrates that WISPA's positions are indeed open to the public. These policy positions are also written clearly; just read any of them and the clarity should be obvious. There's no need that I can see for you to wait. WISPA's positions are already public and clear. When you are ready to sign up for WISPA Membership, that door is wide open for you. Here's the link . Thanks again for contributing your excellent thoughts to the discussion. jack MDK wrote: Tom, I've always assumed that the debate on this topic is going to be out of public view. What I've said is not news to anyone, it's not any secret and being proposed to WISPA publicly will change nothing, influence nothing, in terms of how anyone else chooses strategy or positions. I hope it's well debated. I hope you eventually reach a point where your policy stands at WISPA are publicly advocated and clear. I'm waiting. ++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ -- From: "Tom DeReggi" Sent: Thursday, May 27, 2010 6:58 PM To: "WISPA General List" Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband MDK, I applaud your Email. It will take some time to fully digest all the relevent points that were addressed. I dont agree with everything that you suggested, but I do agree with a signfiicant part of it. One realization that you brought up which I agree with is regarding that we will reach a time where a line will need to be drawn in the sand, and we'll need to know which side of the line we are going to be standing on. On some of these topics, playing both sides simply isn't going to be possible. I have a couple quick comments 1) Anything posted on the general list will be google indexed for the world to see. Including the apposing side. In my opinion, it is not wise to debate WISPA's strategy to combat these important issue, in that environment. For that reason, I have been disccussing NBP and TItleII reclassification topics on the member list which is only available to wispa members to read. Its also important that WISPA represent's WISPA member. When debating on an open list, its really hard for me to decipher which comments are comming from members and which are not. For example, a Verizon lobbiest could be masking themselves as a WISP, and I'd never know. I'd also like to re-engage legislative committee list, to start formulating a plan, so members list does not get saturated with policy posts. I welcome members to join legislative committe who are interested in debating this. The more members that join the committee, the bigger the change the conclusion will be a reflection of member's opinion. 2) I think much debate is needed regarding strategy for these important topics. I think its to early to ask members to vote on what our stance should be. Because there has been little debate to challenge potential stances, and many members may not yet be fully versed with all the facts, so some may make an uninformed decission, that could have results different than what they expected by taking their stance. 3) Stategy is needed. Its easy
Re: [WISPA] How the FCC Proposes the Regulate Broadband
uot;Matt Larsen - Lists" To: "WISPA General List" Sent: Friday, May 28, 2010 3:53 AM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Mark, I would like to thank you for your interesting and obivously well > thought out post. > > I am firmly of the camp that USF should be completely discontinued, and > my efforts going forward will be to encourage its disbandment. The > major goals of the original USF program have been completed for some > time now, and the program is no longer needed. USF is providing > unneeded subsidization of wireless cellular carriers, some very large > corporations (CenturyLink) and many rural ILECs that take USF money and > use it to warehouse spectrum and compete with WISPs. > > The politically correct thing to do would be to find allies for our > other positions and offer to support USF reform that will be inclusive > of WISPs. I have had enough experience with the paperwork, legal > wrangling and political skullduggery at the state and federal levels > involved in getting USF to recognize that it is almost totally > incompatible with WISPs. USF is HURTING the deployment of broadband in > the US by supporting the entities that have either failed to deliver > broadband to many of their rural service areas (CenturyLink), have > delivered broadband but are now using the funds to subsidize other > activities such as spectrum warehousing (many small ILECs) or are using > it to fund the buildout of cellular networks (cellphone companies) that > provide awful coverage in rural areas. > > From a philosophical and practical standpoint, USF should be > abolished. The funds left in their coffers can be used to establish a > smaller, tightly focused program for schools and libraries - entities > that are legitimately benefitting from USF. > > USF has strong support from telcos and they are great at focusing on the > tiny parts of the program that are beneficial and the threat that some > telcos will "go under" without USF support - while the vast majority of > the money that comes out of USF goes to the bottom line of profitable > companies with ties to the original monopoly players. > > It is time for a quick lesson about the economic concept of "Fast > Failure". One of the very best features of capitalism and the > entrepeneurial environment of the United States is that a business can > and should fail if it turns out to not be economically feasible. When > that business fails, its resources are redistributed and another > business can step in. Subsidizing a business that doesn't need > subsidization, or creating a monopolistic situation through > subsidization or regulation leads to inefficiencies in the system. USF > is being used to support businesses that don't need the support and it > creates an anti-competitive environment. > > I would really like to see USF disappear. It just doesn't make sense > to me to try and work with a system that is hopelessly flawed and > unrepairable. > > Matt Larsen > vistabeam.com > > > On 5/27/2010 3:55 AM, MDK wrote: >> As I write, is it 1:40 AM, I'm tired as heck, but have been mulling this >> question for days, and have finally taken the time to do this. First, >> to >> my self-motivated "enemies" who can't stand anything I say "Nuts!", I'm >> right and I know it. Now, for the rest, who are interested in more than >> just shallow mockery, here's serious conversation on serious topics, and >> the excuse to dismiss me for those who can't bring themselves to be >> serious. >> >> Some comments on the strategy for opposing FCC intervention. >> >> As is highlighted below - and has been discussed at considerable length >> in >> other venues... The NBP, the regulation of internet services, and "net >> neutrality" all hinge upon a couple of rather firm anchors. As we know, >> the FCC lost in the courts when it attempted to simply re-write the >> intent >> of current law.The first "anchor" for implementation of anything is >> to >> surmount the law as it sits right now.Either by Congressional action, >> or >> by administratively bypassing it. >> >> The current administration has demonstrated in several other areas they >> are >> willing to coordinate completely bypassing the legislative process, and >> regulate via "administrative rule". IE, agencies simply write new rules >> that force the intent of the administration, even if it conflicts with >> current law, or has no basis in law. There's considerable example and >>
Re: [WISPA] How the FCC Proposes the Regulate Broadband
ginal Message - From: "MDK" To: "WISPA General List" Sent: Friday, May 28, 2010 1:09 AM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Please note that I said "refundable" tax credits. That is, if your > credits > are more than your taxes, you get a check back. > > This could be done so that your refunds would be quarterly. > > > > > > > ++ > Neofast, Inc, Making internet easy > 541-969-8200 509-386-4589 > ++ > > -------------------------- > From: "Scottie Arnett" > Sent: Thursday, May 27, 2010 8:24 PM > To: "WISPA General List" > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > >> >> Considering past tax rebates, or credits, to take full advantage would >> require that you are way in the black. This would help newer WISP >> somewhat, but most are in the red from the beginning. It would definitely >> help sustained WISP's that have been at it for a few years. >> >> Scottie >> >>> -- >>> /* >>> Jason Philbrook | Midcoast Internet Solutions - Wireless and DSL >>> KB1IOJ| Broadband Internet Access, Dialup, and Hosting >>> http://f64.nu/ | for Midcoast Mainehttp://www.midcoast.com/ >>> */ >>> >>> >>> >>> WISPA Wants You! Join today! >>> http://signup.wispa.org/ >>> >>> >>> WISPA Wireless List: wireless@wispa.org >>> >>> Subscribe/Unsubscribe: >>> http://lists.wispa.org/mailman/listinfo/wireless >>> >>> Archives: http://lists.wispa.org/pipermail/wireless/ >>> >> >> >> >> >> >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
ould be required to provide minimal > markup interconnection or bandwidth to other ISP's in the same trade area, > subject to how much capacity exists vs use. (distance should be debated) > 10. That ALL infrastructure investment be fully expensable -as in 100% > write-off in year one, as it concerns taxes.Basically, that puts every > ISP in the position of being able to write off and not be taxed on growing > or expansion.This should be permanent tax policy for EVERYONE, > everywhere. > > This conceptual idea is technology agnostic.It recognizes that UNIVERSAL > coverage is really a phantom, because we do live in a country with totally > isolated pockets of humanity.It recognizes that permanent subsidy is > both unwise and unworkable. It encourages competitive behavior, rational > business plans based on other than subsidized revenues.It preserves a > very small level of subsidy for the truly isolated, even promotes > competition within it. > > This idea recognizes and codifies that subsidy = threat of regulation and > that free markets with a competitive environment do NOT need any regulation > to provide workable services to consumers. > > This expires the vast amount of subsidy all by itself, with built in > incentives to reach the point where it expires. > > It allows operators to opt out and be unregulated, even if they're in a > qualified area, and their coverage has no impact on the subsidy > qualifications.No pay, no pain. > > It gives Congress an additional incentive to permanently block the FCC's > ideas, and yet at the same time, address specific concerns as it relates to > net neutrality. > > I believe this idea to be sellable to a wide array of interests - both > political and industry. It is sellable to the public - who is currently > very mindful of where the government's money is being "blown". There is > no incentive to game the system. Providers are not encouraged to get the > money up front and provide mediocre services.There is no risk, it does > not put public money at risk, it does not indebt providers. > > It provides incentive to build more middle mile, even competitive middle > mile, with at least a couple of years of enhanced revenue to pay down the > capital costs, maybe more. > > > > ++ > Neofast, Inc, Making internet easy > 541-969-8200 509-386-4589 > ++ > > -- > From: "Rick Harnish" > Sent: Thursday, May 20, 2010 10:41 AM > To:;; "'WISPA General List'" > > Subject: [WISPA] How the FCC Proposes the Regulate Broadband > > >> * FCC Proposes a THIRD WAY to Regulate Broadband >> >> * Appeal Comcast decision >> >> * Not likely to succeed as the vote was 3-0 in favor of Comcast >> >> * Go to Congress and get specific authority >> >> * Too long of a process >> >> * 1. Reinforce its ancillary authority argument >> >> * Suggested by the Court but not considered by the FCC because of >> scope issues. >> >> * 2. Reclassify Internet communications as telecommunications service >> to restore direct authority over Broadband communication networks >> * 3. THIRD WAY - Move all Broadband Internet access service to Title >> II and lightly regulate this service >> >> * Who is the Target? >> >> * Rural Carriers offer Broadband Internet access service as a Title II >> telecommunications service (no effect) >> * RBOC's, wireless, cable and Broadband over powerline providers offer >> Broadband Internet access Service as Title 1. >> >> * These are the providers that will be subject to Title II regulations >> * These entities can and will push back very hard >> >> * Purpose of the THIRD WAY >> >> * The Third Way isn't about Network Neutrality. >> >> * The proposed Title II regulation of Broadband Internet access >> service does not regulate or control the entire transport to the Internet >> cloud >> >> * The Third Way IS about regulation of last mile Broadband for other >> purposes. >> >> * "At the outset, it must be made absolutely clear that the issue of >> reclassification goes far beyond our open Internet proceeding. It >> involves >> some of the most important parts of our National Broadband Plan - >> universal >> service, privacy, transparency, and cyber security. Without >> reclassification, the road to achieving each of those issues is laden with >> land mines and likely to fail." Commissioner Mignon Cly
Re: [WISPA] How the FCC Proposes the Regulate Broadband
Tom, I've always assumed that the debate on this topic is going to be out of public view. What I've said is not news to anyone, it's not any secret and being proposed to WISPA publicly will change nothing, influence nothing, in terms of how anyone else chooses strategy or positions. I hope it's well debated. I hope you eventually reach a point where your policy stands at WISPA are publicly advocated and clear. I'm waiting. ++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ -- From: "Tom DeReggi" Sent: Thursday, May 27, 2010 6:58 PM To: "WISPA General List" Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > MDK, > > I applaud your Email. It will take some time to fully digest all the > relevent points that were addressed. > I dont agree with everything that you suggested, but I do agree with a > signfiicant part of it. > One realization that you brought up which I agree with is regarding that > we > will reach a time where a line will need to be drawn in the sand, and > we'll > need to know which side of the line we are going to be standing on. On > some > of these topics, playing both sides simply isn't going to be possible. > > I have a couple quick comments > > 1) Anything posted on the general list will be google indexed for the > world > to see. Including the apposing side. > In my opinion, it is not wise to debate WISPA's strategy to combat these > important issue, in that environment. > For that reason, I have been disccussing NBP and TItleII reclassification > topics on the member list which is only available to wispa members to > read. > Its also important that WISPA represent's WISPA member. When debating on > an > open list, its really hard for me to decipher which comments are comming > from members and which are not. For example, a Verizon lobbiest could be > masking themselves as a WISP, and I'd never know. > I'd also like to re-engage legislative committee list, to start > formulating > a plan, so members list does not get saturated with policy posts. I > welcome > members to join legislative committe who are interested in debating this. > The more members that join the committee, the bigger the change the > conclusion will be a reflection of member's opinion. > > 2) I think much debate is needed regarding strategy for these important > topics. I think its to early to ask members to vote on what our stance > should be. Because there has been little debate to challenge potential > stances, and many members may not yet be fully versed with all the facts, > so > some may make an uninformed decission, that could have results different > than what they expected by taking their stance. > > 3) Stategy is needed. Its easy to come up with what we want. The hard part > is to justify and convince policy makers to give us that. And what we want > may not be realistic to achieve. This is serious business, we dont want to > pick a stance that will leave us with nothing at all at the end, because > we > didn;t face realitiy. We cant forget that FCC and Congress also already > have > an idea of what they want. There are many complicated issues here. Its > not > that I dont want to poll members, I am very interested in what they have > to > say and think. But there is also a huge advantage to creating a think tank > environment first, challenged by council, and to share results with > memebrship for them to consider before deciding their position.. > > For example, Congress and FCC have an obligation to help consumers, and > consumers want their broadband options improved. To help, money is needed. > USF has been identified as a money source, by the FCC and Congress. Its > very > unlikely they'll vote to wipe out a money source that actively regenerates > funds. Its so much more likely they'll try to repurpose those funds, to > solve a problem. Sure we can fight to shutdown USF, many of us would > prefer > that, but the flip side is if USF is not shut down, and we do not lobby > for > how to best repurpose it, it will be guaranteed that fund will go to or > competitors in mass proportions, and we will get harmed by that, I'd argue > possibly even extinguished by that. Another example was BTOP Round2. In > Round2, much funds will go for inter- networking government locations. In > one sense its an outrage that huge amounts of money will go to build > networks that may not be needed, and take revenue away from the price > sector > providers. And few WISPs will see a dime of it. But on the flip side it > w
Re: [WISPA] How the FCC Proposes the Regulate Broadband
Please note that I said "refundable" tax credits. That is, if your credits are more than your taxes, you get a check back. This could be done so that your refunds would be quarterly. ++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ -- From: "Scottie Arnett" Sent: Thursday, May 27, 2010 8:24 PM To: "WISPA General List" Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > > Considering past tax rebates, or credits, to take full advantage would > require that you are way in the black. This would help newer WISP > somewhat, but most are in the red from the beginning. It would definitely > help sustained WISP's that have been at it for a few years. > > Scottie > >> -- >> /* >> Jason Philbrook | Midcoast Internet Solutions - Wireless and DSL >> KB1IOJ| Broadband Internet Access, Dialup, and Hosting >> http://f64.nu/ | for Midcoast Mainehttp://www.midcoast.com/ >> */ >> >> >> >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ >> > > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
This is in no way way to put your responses down JP...but in almost all your responses you have responded as a WISP that is making money > Yes, I expect USF money to be used as bait in how this plays out. > > > I see no reason to have permanent USF subsidy. It is money down the toilet > over the long > run and a tax that seriously hinders people's ability to afford > communications services. > A big part of current USF money goes to "switching" which I see as an > antiquated > hierarchy where small rural towns have their own switch, with all it's > maintenance and > support. With the advent of cheap high capacity fiber created by ARRA > projects and > private upgrades, smaller digital switches, wholesale access to switch > partitions, and > VOIP, there is no technical reason to permanently subsidize modern > distributed > switching. If permanent support for "switching" were tapered off, the > rural phone > companies could find cheaper ways to do voice switching. The cellcos > almost all have > some sort of architecture where all their sites in the state go back to > single > state-wide switches. When not used for switching, permanent USF pays for > monopoly > infrastructure that discourages rural competition by irrationally priced > services. > The current USF charges are a "tax" as you put it in high density areas on telco charges. That is used to give rural telcos money to build out and sustain telephone coverage to very under served(remote areas...like 10-20 houses per square mile). The current plan on USF is to only let one entity have access to this. If you have any competitor that is an ILEC or CLEC, you can pretty much kiss your luck of getting this good by! It would put too much work on an already understaffed FCC, and they already favor telcos over anything else. > A tax rebate would be highly preferable to USF, as it would be a reduction > in taxation > rather than an increase in taxation. Either way, non-permanent support is > the only thing > I can advocate. > > I like the idea of non-permanent support for unserved/underserved areas. > My state's > ConnectME fund is looking at a one-time ISP payment (per customer) to > support high-cost > installations to unserved locations. The details of how much and under > what conditions > are undecided, but it would address the high CPE/installation costs that > plague > broadband expansion and would not cause long term dependence on > government. This would > be an alternative to the present system of government funded > infrastructure projects. > This would be less apt to stir a hornets nest of capitalism versus > government funded > project overbuilding, which is more and more apt to happen. > Considering past tax rebates, or credits, to take full advantage would require that you are way in the black. This would help newer WISP somewhat, but most are in the red from the beginning. It would definitely help sustained WISP's that have been at it for a few years. Scottie > -- > /* > Jason Philbrook | Midcoast Internet Solutions - Wireless and DSL > KB1IOJ| Broadband Internet Access, Dialup, and Hosting > http://f64.nu/ | for Midcoast Mainehttp://www.midcoast.com/ > */ > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ > WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
o reclassify broadband as TItleII, and probably the bigest topic that has the potential to devide membership. For sure, I think it is impairative that we learn the percentage of members that are ILECs and USF recipients. We need to know that, before we can consider a stance. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "MDK" To: "WISPA General List" Sent: Thursday, May 27, 2010 5:55 AM Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > As I write, is it 1:40 AM, I'm tired as heck, but have been mulling this > question for days, and have finally taken the time to do this. First, to > my self-motivated "enemies" who can't stand anything I say "Nuts!", I'm > right and I know it. Now, for the rest, who are interested in more than > just shallow mockery, here's serious conversation on serious topics, and > the excuse to dismiss me for those who can't bring themselves to be > serious. > > Some comments on the strategy for opposing FCC intervention. > > As is highlighted below - and has been discussed at considerable length in > other venues... The NBP, the regulation of internet services, and "net > neutrality" all hinge upon a couple of rather firm anchors. As we know, > the FCC lost in the courts when it attempted to simply re-write the intent > of current law.The first "anchor" for implementation of anything is to > surmount the law as it sits right now.Either by Congressional action, > or > by administratively bypassing it. > > The current administration has demonstrated in several other areas they > are > willing to coordinate completely bypassing the legislative process, and > regulate via "administrative rule". IE, agencies simply write new rules > that force the intent of the administration, even if it conflicts with > current law, or has no basis in law. There's considerable example and > evidence of this, by the EPA and other agencies. > > It would be my estimate that this is the approach the FCC will try - and > it > is coordinated directly, but unofficially, from the White House. This > approach has mixed support and resistance in Congress. Some of the > Democrats would prefer this, rather than Congress taking up a > controversial > topic. However, it is legally "iffy". And, there's a majority in > Congress which is mostly Republicans and some Democrats who actually > oppose > the FCC attempting to simply rule by fiat. It's a "turf" thing, > actually. > Few in Congress are strongly supportive of enterprise, and the resistance > is > mostly about Congress objecting to the FCC usurping their role. > > Thus, it would seem to be a poor strategy to rely on Congressional efforts > or even lobbying Congress to proactively act - though it should be done - > to > oppose the FCC, perhaps by proactive legislation, to block the FCC from > doing any of this. It's a poor strategy to depend on it happening, but > that happening would be probably the best possible outcome - assuming the > law passed would protect our freedom to be in business and STAY > unregulated. > > As I said above, there are some key pins on which this whole thing > revolves, > and it has been pointed out, that USF funding - and a re-write of that tax > and spending is key.It's the "carrot and stick" approach. Not quite > the traditional meaning, but the carrot used to get you closer or to > agree, > so you'll get close enough to beat with the stick. > > So, MONEY is the key.If there is no MONEY to buy your acceptance with, > there is near universal industry opposition to regulation.In that > situation, we could be political allies with, and benefit from the > lobbying > warchests of a wide array of players in the telecom and internet > industries, > as well as a wide array of both ideological and even some "progressive" > institutions. > > As long as there is money on the table - as long as any administration or > agency or even Congress has the means to buy off resistance - there is no > reliable massive block of resistance. As was pointed out in other > emails, > an alliance with small and rural CLEC's and others is going to be shaky, > because if the regulators put money on the table for them, they abandon > the > "common defense" and we're on our own. > > For that matter, WISPA's membership and even just the readership of this > list is extremely and deeply divided. There are those who see the > purpose > of WISPA as one to lobby to repurpose or red
Re: [WISPA] How the FCC Proposes the Regulate Broadband
I agree with small. I wonder if Census Block would work. Where I am it will be a long time before it makes sense to cover 95% of a couple of zip codes. 1 to 2 houses per square mile in hills and trees. But with census blocks I can hit 95% of a lot of them. Also, since the Form 477 moved to census blocks, the FCC can know who is reporting for the block to help determine eligibility. One thing that would be interesting is how anyone will determine 95% coverage. I am not arguing against it, just that it will be a hard to measure quantity. MDK wrote: > Thanks...I was not writing this as if it were a mature proposal... but > rather as something to stimulate debate.I'm sure that other people see > pitfalls in things I don't, and may perceive unintended consequences I have > not. I don't consider it be anywhere near "best of all worlds", but it > seems both sellable and viable, in our political and economic climate, and > it's structure is one of a self-exterminating subsidy, save a very few > extremely remote places. > > I had further thoughts about this... > > 1. The "area" of coverage needs to be small.That is, coverage for an > "area" definition should be no larger than a zip code.The point being > that such granularity yields up the ability to actually COVER some place > without being a multi-million dollar operation. That the areas in > question should be defined as those having common economic ties, and > separation by geography should result in area boundaries. By its very > nature, this would initially encourage a lot of extisting competition to > expand coverage, and then would achieve the goals we all see as worthy. > And end any subsidy permanently. > > 2.That ISP's should be able to freely contract with each other to > "cover" an area.Let's imagine some smallish town in Wyoming, where a > WISP opens up shop.This hypothetical zip code boundary is served by a > WISP, except for one area that's served by a remote DSLAM from another town. > The original ISP located in this area doesn't cover that small isolated area > because it's already served, and because geography makes it very difficult. > In this case, the ISP in the area can contract with the isp that serves the > small bit, reaching the 95% threshold... The serving provider then applies > for and gets the rebate for those he serves, and the contracted ISP gets > the same - but only for those in that region contracted by the local > provider. Imagine two WISP's who share a zip code, where one serves the > northern part, and one the southern part.One can become the original and > contract with his competitor legally, to achieve a "single provider" > coverage for a whole area, and whatever subsidy is paid directly to the > serving provider, though each makes up only a part of a region and the two > together really only equal a single whole. > > What I've suggested is a stance by WISPA that can and will be criticized by > at least some as being "ideological".I consider it a practical stance, > not ideological, but that's just me. Before WISPA and its members take > any such stand, it should be consider "A big deal", and debated by the > membership as such. > > If, for instance, WISPA did adopt such a stand My harsh criticism would > end and I would financially support WISPA, as that was and remains my > original belief in what a trade organization should be doing.Though > we're a business, we're all citizens at the same time, and our collective > stand should be conservative, sober, and one of national fiscal > responsibility. That may make WISPA unique, but it seems like a stand > that would be applauded and promoted widely by a lot of people with extreme > concern for their country... and for general direction of our national > character. > > > > ++++++++++++++ > Neofast, Inc, Making internet easy > 541-969-8200 509-386-4589 > ++ > > -- > From: "Brian Webster" > Sent: Thursday, May 27, 2010 5:25 AM > To: "'WISPA General List'" > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > > >> Mark, >> This is an interesting and well thought out proposal. Thank you for >> taking the time to post and for also not making it politically charged. It >> might be a good idea to create a condensed version of this proposal with >> simple bullet points. Politicians and other government officials have a >> short attention span s
Re: [WISPA] How the FCC Proposes the Regulate Broadband
Thanks...I was not writing this as if it were a mature proposal... but rather as something to stimulate debate.I'm sure that other people see pitfalls in things I don't, and may perceive unintended consequences I have not. I don't consider it be anywhere near "best of all worlds", but it seems both sellable and viable, in our political and economic climate, and it's structure is one of a self-exterminating subsidy, save a very few extremely remote places. I had further thoughts about this... 1. The "area" of coverage needs to be small.That is, coverage for an "area" definition should be no larger than a zip code.The point being that such granularity yields up the ability to actually COVER some place without being a multi-million dollar operation. That the areas in question should be defined as those having common economic ties, and separation by geography should result in area boundaries. By its very nature, this would initially encourage a lot of extisting competition to expand coverage, and then would achieve the goals we all see as worthy. And end any subsidy permanently. 2.That ISP's should be able to freely contract with each other to "cover" an area.Let's imagine some smallish town in Wyoming, where a WISP opens up shop.This hypothetical zip code boundary is served by a WISP, except for one area that's served by a remote DSLAM from another town. The original ISP located in this area doesn't cover that small isolated area because it's already served, and because geography makes it very difficult. In this case, the ISP in the area can contract with the isp that serves the small bit, reaching the 95% threshold... The serving provider then applies for and gets the rebate for those he serves, and the contracted ISP gets the same - but only for those in that region contracted by the local provider. Imagine two WISP's who share a zip code, where one serves the northern part, and one the southern part.One can become the original and contract with his competitor legally, to achieve a "single provider" coverage for a whole area, and whatever subsidy is paid directly to the serving provider, though each makes up only a part of a region and the two together really only equal a single whole. What I've suggested is a stance by WISPA that can and will be criticized by at least some as being "ideological".I consider it a practical stance, not ideological, but that's just me. Before WISPA and its members take any such stand, it should be consider "A big deal", and debated by the membership as such. If, for instance, WISPA did adopt such a stand My harsh criticism would end and I would financially support WISPA, as that was and remains my original belief in what a trade organization should be doing.Though we're a business, we're all citizens at the same time, and our collective stand should be conservative, sober, and one of national fiscal responsibility. That may make WISPA unique, but it seems like a stand that would be applauded and promoted widely by a lot of people with extreme concern for their country... and for general direction of our national character. ++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ ---------------------- From: "Brian Webster" Sent: Thursday, May 27, 2010 5:25 AM To: "'WISPA General List'" Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > Mark, > This is an interesting and well thought out proposal. Thank you for > taking the time to post and for also not making it politically charged. It > might be a good idea to create a condensed version of this proposal with > simple bullet points. Politicians and other government officials have a > short attention span so a Readers Digest version of this same idea would > help in gathering interest and support for the concept. If they express > serious interest, a more detailed description can be presented to them. > Having to read your full description will get lost on those who skim ideas > in the interest of saving time. A condensed version would also be easier > to > present to the proper WISPA committees to begin discussion. I know quite a > few WISPA members do not read the general list in as much detail as they > do > other lists. I'd be willing to present your concept to the proper > committees > for consideration. > > > > Brian > WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
On Thu, May 27, 2010 at 02:55:21AM -0700, MDK wrote: > As long as there is money on the table - as long as any administration or > agency or even Congress has the means to buy off resistance - there is no > reliable massive block of resistance. As was pointed out in other emails, > an alliance with small and rural CLEC's and others is going to be shaky, > because if the regulators put money on the table for them, they abandon the > "common defense" and we're on our own. Yes, I expect USF money to be used as bait in how this plays out. > Next, we need to address fundamental questions - Ideas must be sellable to > Congress, they must obtain at least a modicum of support, and they should > be equitable to all - putting free market principles to work.It must not > institute permanent subsidy, which discourages the establishment of business > models which are fundamentally sound WITHOUT public money. I see no reason to have permanent USF subsidy. It is money down the toilet over the long run and a tax that seriously hinders people's ability to afford communications services. A big part of current USF money goes to "switching" which I see as an antiquated hierarchy where small rural towns have their own switch, with all it's maintenance and support. With the advent of cheap high capacity fiber created by ARRA projects and private upgrades, smaller digital switches, wholesale access to switch partitions, and VOIP, there is no technical reason to permanently subsidize modern distributed switching. If permanent support for "switching" were tapered off, the rural phone companies could find cheaper ways to do voice switching. The cellcos almost all have some sort of architecture where all their sites in the state go back to single state-wide switches. When not used for switching, permanent USF pays for monopoly infrastructure that discourages rural competition by irrationally priced services. > 4. No ILEC is ever eligible for any subsidy within the boundaries of it's > incumbency, whether it is expanding broadband to unserved portions of its > incumbency or not.Whether or not CLEC status should be included should > be a subject of debate. CLECs tend to be doing stuff that meets a need the ILECs aren't filling. I'm fine with non-permanent support to that. > 5. That any financial incentive consist solely as a refundable tax rebate > per consumer serviced per month, with the consumers being defined as those > who reside in an area currently without broadband, or in an area where > infrastructure does not currently exist to serve at least 95% of all > residences within that area.Area definition should be tied to local > trade areas.Consumers would be defined as customers of the ISP, be it > residential, business, or organization - like schools, businesses, or even > other ISP's. > 6. Rebate eligibility expires upon: 2 years after a 3rd provider or 2nd > "different" technology covers at least 95% of all consumers within the > defined areas.( example, DSL access is limited to a smallish rural > area, so the 1st and 2nd WISP can both claim rebates per consumer, but the > DSL provider cannot unless it expands to reach 95% of the people. WISP's > cannot qualify EITHER, unless or until they can cover 95%. Even if 2 > WISP's fully cover, rebates continue until a third joins - then the > trigger allows that WISP subsidy for 2 years,, or the telco rolls out > universal DSL, at which the telco and WISP's continue for 2 years and then > expires. Even if one/any/all go out of business after this threshold is > crossed, the expiration is permanent,) A tax rebate would be highly preferable to USF, as it would be a reduction in taxation rather than an increase in taxation. Either way, non-permanent support is the only thing I can advocate. I like the idea of non-permanent support for unserved/underserved areas. My state's ConnectME fund is looking at a one-time ISP payment (per customer) to support high-cost installations to unserved locations. The details of how much and under what conditions are undecided, but it would address the high CPE/installation costs that plague broadband expansion and would not cause long term dependence on government. This would be an alternative to the present system of government funded infrastructure projects. This would be less apt to stir a hornets nest of capitalism versus government funded project overbuilding, which is more and more apt to happen. > 10. That ALL infrastructure investment be fully expensable -as in 100% > write-off in year one, as it concerns taxes.Basically, that puts every > ISP in the position of being able to write off and not be taxed on growing > or expansion.This should be permanent tax policy for EVERYONE, > everywhere. This has some precedent. Something like the §179 which lets the self employed fully deduct big SUVs and work trucks. This was m
Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY
It won't happen today. My day is shot. I will forward this to the Board. Maybe someone else can step in and assist. Thanks, Rick > -Original Message- > From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On > Behalf Of Josh Luthman > Sent: Thursday, May 27, 2010 12:46 PM > To: WISPA General List > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY > > Punctuation, too. I can't answer most of these because I can't grasp > what's being asked. > > Josh Luthman > Office: 937-552-2340 > Direct: 937-552-2343 > 1100 Wayne St > Suite 1337 > Troy, OH 45373 > > Success is not final, failure is not fatal: it is the courage to > continue that counts. > --- Winston Churchill > > > > On Thu, May 27, 2010 at 12:42 PM, Leon D. Zetekoff > wrote: > > On 5/27/2010 12:13 PM, Rick Harnish wrote: > >> > >> Done > >> > >> Please take the survey. http://www.surveymonkey.com/s/XC5DF7F > There are > >> 10 > >> questions on two pages. You must answer all statements with Agree, > >> Undecided or Disagree to proceed. > >> > >> I would have liked to have asked whether the responders are a member > or a > >> non-member but we are only allowed 10 questions per survey and I > didn't > >> have > >> room. > >> > >> T > >> > > > > Hi RIck...can the grammar be improved? > > > > leon > > > > No virus found in this outgoing message. > > Checked by AVG - www.avg.com > > Version: 9.0.819 / Virus Database: 271.1.1/2897 - Release Date: > 05/26/10 > > 02:25:00 > > > > > > > > - > --- > > WISPA Wants You! Join today! > > http://signup.wispa.org/ > > - > --- > > > > WISPA Wireless List: wireless@wispa.org > > > > Subscribe/Unsubscribe: > > http://lists.wispa.org/mailman/listinfo/wireless > > > > Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > --- > - > WISPA Wants You! Join today! > http://signup.wispa.org/ > --- > - > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY
Punctuation, too. I can't answer most of these because I can't grasp what's being asked. Josh Luthman Office: 937-552-2340 Direct: 937-552-2343 1100 Wayne St Suite 1337 Troy, OH 45373 “Success is not final, failure is not fatal: it is the courage to continue that counts.” --- Winston Churchill On Thu, May 27, 2010 at 12:42 PM, Leon D. Zetekoff wrote: > On 5/27/2010 12:13 PM, Rick Harnish wrote: >> >> Done >> >> Please take the survey. http://www.surveymonkey.com/s/XC5DF7F There are >> 10 >> questions on two pages. You must answer all statements with Agree, >> Undecided or Disagree to proceed. >> >> I would have liked to have asked whether the responders are a member or a >> non-member but we are only allowed 10 questions per survey and I didn't >> have >> room. >> >> T >> > > Hi RIck...can the grammar be improved? > > leon > > No virus found in this outgoing message. > Checked by AVG - www.avg.com > Version: 9.0.819 / Virus Database: 271.1.1/2897 - Release Date: 05/26/10 > 02:25:00 > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ > WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY
On 5/27/2010 12:13 PM, Rick Harnish wrote: Done Please take the survey. http://www.surveymonkey.com/s/XC5DF7F There are 10 questions on two pages. You must answer all statements with Agree, Undecided or Disagree to proceed. I would have liked to have asked whether the responders are a member or a non-member but we are only allowed 10 questions per survey and I didn't have room. T Hi RIck...can the grammar be improved? leon No virus found in this outgoing message. Checked by AVG - www.avg.com Version: 9.0.819 / Virus Database: 271.1.1/2897 - Release Date: 05/26/10 02:25:00 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband SURVEY
Done Please take the survey. http://www.surveymonkey.com/s/XC5DF7F There are 10 questions on two pages. You must answer all statements with Agree, Undecided or Disagree to proceed. I would have liked to have asked whether the responders are a member or a non-member but we are only allowed 10 questions per survey and I didn't have room. Thanks, Rick Harnish > -Original Message- > From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On > Behalf Of David E. Smith > Sent: Thursday, May 27, 2010 11:29 AM > To: WISPA General List > Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband > > On Thu, May 27, 2010 at 04:55, MDK wrote: > > [ snip: a lot of interesting ideas with which I personally disagree > but they're still interesting ideas ] > > > This idea recognizes and codifies that subsidy = threat of regulation > and > > that free markets with a competitive environment do NOT need any > regulation > > to provide workable services to consumers. > > Does WISPA have any mechanism in place for polling the membership, to > see whether MDK's ideas really have the kind of support he thinks they > do? I think the membership is large enough that it's not necessarily > fair/wise to assume that nine board members can accurately assess > these things. > > MDK: ever consider running for a spot on the board? That's one way to > be sure WISPA is listening to your views. :) > > David Smith > MVN.net > > > --- > - > WISPA Wants You! Join today! > http://signup.wispa.org/ > --- > - > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
On Thu, May 27, 2010 at 04:55, MDK wrote: [ snip: a lot of interesting ideas with which I personally disagree but they're still interesting ideas ] > This idea recognizes and codifies that subsidy = threat of regulation and > that free markets with a competitive environment do NOT need any regulation > to provide workable services to consumers. Does WISPA have any mechanism in place for polling the membership, to see whether MDK's ideas really have the kind of support he thinks they do? I think the membership is large enough that it's not necessarily fair/wise to assume that nine board members can accurately assess these things. MDK: ever consider running for a spot on the board? That's one way to be sure WISPA is listening to your views. :) David Smith MVN.net WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] How the FCC Proposes the Regulate Broadband
Mark, This is an interesting and well thought out proposal. Thank you for taking the time to post and for also not making it politically charged. It might be a good idea to create a condensed version of this proposal with simple bullet points. Politicians and other government officials have a short attention span so a Readers Digest version of this same idea would help in gathering interest and support for the concept. If they express serious interest, a more detailed description can be presented to them. Having to read your full description will get lost on those who skim ideas in the interest of saving time. A condensed version would also be easier to present to the proper WISPA committees to begin discussion. I know quite a few WISPA members do not read the general list in as much detail as they do other lists. I'd be willing to present your concept to the proper committees for consideration. Brian -Original Message- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of MDK Sent: Thursday, May 27, 2010 5:55 AM To: WISPA General List Subject: Re: [WISPA] How the FCC Proposes the Regulate Broadband As I write, is it 1:40 AM, I'm tired as heck, but have been mulling this question for days, and have finally taken the time to do this. First, to my self-motivated "enemies" who can't stand anything I say "Nuts!", I'm right and I know it. Now, for the rest, who are interested in more than just shallow mockery, here's serious conversation on serious topics, and the excuse to dismiss me for those who can't bring themselves to be serious. Some comments on the strategy for opposing FCC intervention. As is highlighted below - and has been discussed at considerable length in other venues... The NBP, the regulation of internet services, and "net neutrality" all hinge upon a couple of rather firm anchors. As we know, the FCC lost in the courts when it attempted to simply re-write the intent of current law.The first "anchor" for implementation of anything is to surmount the law as it sits right now.Either by Congressional action, or by administratively bypassing it. The current administration has demonstrated in several other areas they are willing to coordinate completely bypassing the legislative process, and regulate via "administrative rule". IE, agencies simply write new rules that force the intent of the administration, even if it conflicts with current law, or has no basis in law. There's considerable example and evidence of this, by the EPA and other agencies. It would be my estimate that this is the approach the FCC will try - and it is coordinated directly, but unofficially, from the White House. This approach has mixed support and resistance in Congress. Some of the Democrats would prefer this, rather than Congress taking up a controversial topic. However, it is legally "iffy". And, there's a majority in Congress which is mostly Republicans and some Democrats who actually oppose the FCC attempting to simply rule by fiat. It's a "turf" thing, actually. Few in Congress are strongly supportive of enterprise, and the resistance is mostly about Congress objecting to the FCC usurping their role. Thus, it would seem to be a poor strategy to rely on Congressional efforts or even lobbying Congress to proactively act - though it should be done - to oppose the FCC, perhaps by proactive legislation, to block the FCC from doing any of this. It's a poor strategy to depend on it happening, but that happening would be probably the best possible outcome - assuming the law passed would protect our freedom to be in business and STAY unregulated. As I said above, there are some key pins on which this whole thing revolves, and it has been pointed out, that USF funding - and a re-write of that tax and spending is key.It's the "carrot and stick" approach. Not quite the traditional meaning, but the carrot used to get you closer or to agree, so you'll get close enough to beat with the stick. So, MONEY is the key.If there is no MONEY to buy your acceptance with, there is near universal industry opposition to regulation.In that situation, we could be political allies with, and benefit from the lobbying warchests of a wide array of players in the telecom and internet industries, as well as a wide array of both ideological and even some "progressive" institutions. As long as there is money on the table - as long as any administration or agency or even Congress has the means to buy off resistance - there is no reliable massive block of resistance. As was pointed out in other emails, an alliance with small and rural CLEC's and others is going to be shaky, because if the regulators put money on the table for them, they abandon the &quo
Re: [WISPA] How the FCC Proposes the Regulate Broadband
that WISP subsidy for 2 years,, or the telco rolls out universal DSL, at which the telco and WISP's continue for 2 years and then expires. Even if one/any/all go out of business after this threshold is crossed, the expiration is permanent,) 7. No ISP which opts out of eligibility or competes in any market without eligibility can have its services regulated."net neutrality" and other such schemes can only apply to subsidized, uncompetitive markets. When the market is competitive by being served by at least 2 technologies and 3 providers, at near "universal" coverage, then no provider regulation is needed. 8. Middle mile providers who serve ISP's who qualify for incentive rebates are also eligible for rebate per consumer serviced by qualified ISP's who participate.Up to two middle mile providers per ISP can claim subsidy. Middle mile providers would be defined as non-ILEC providers of bandwidth who do not sell connections to residential or otherwise retail individual customers. "Net neutrality" and other regulation can apply to middle mile providers, too- if they claim any eligible rebates. 9. ISP's who build their own "middle mile" by moving data more than 30 statute miles (not path, but just distance) to get to a non-ILEC connection could also qualify for tax rebates, but would be required to provide minimal markup interconnection or bandwidth to other ISP's in the same trade area, subject to how much capacity exists vs use. (distance should be debated) 10. That ALL infrastructure investment be fully expensable -as in 100% write-off in year one, as it concerns taxes.Basically, that puts every ISP in the position of being able to write off and not be taxed on growing or expansion.This should be permanent tax policy for EVERYONE, everywhere. This conceptual idea is technology agnostic.It recognizes that UNIVERSAL coverage is really a phantom, because we do live in a country with totally isolated pockets of humanity.It recognizes that permanent subsidy is both unwise and unworkable. It encourages competitive behavior, rational business plans based on other than subsidized revenues.It preserves a very small level of subsidy for the truly isolated, even promotes competition within it. This idea recognizes and codifies that subsidy = threat of regulation and that free markets with a competitive environment do NOT need any regulation to provide workable services to consumers. This expires the vast amount of subsidy all by itself, with built in incentives to reach the point where it expires. It allows operators to opt out and be unregulated, even if they're in a qualified area, and their coverage has no impact on the subsidy qualifications.No pay, no pain. It gives Congress an additional incentive to permanently block the FCC's ideas, and yet at the same time, address specific concerns as it relates to net neutrality. I believe this idea to be sellable to a wide array of interests - both political and industry. It is sellable to the public - who is currently very mindful of where the government's money is being "blown". There is no incentive to game the system. Providers are not encouraged to get the money up front and provide mediocre services.There is no risk, it does not put public money at risk, it does not indebt providers. It provides incentive to build more middle mile, even competitive middle mile, with at least a couple of years of enhanced revenue to pay down the capital costs, maybe more. ++ Neofast, Inc, Making internet easy 541-969-8200 509-386-4589 ++ -- From: "Rick Harnish" Sent: Thursday, May 20, 2010 10:41 AM To: ; ; "'WISPA General List'" Subject: [WISPA] How the FCC Proposes the Regulate Broadband > * FCC Proposes a THIRD WAY to Regulate Broadband > > * Appeal Comcast decision > > * Not likely to succeed as the vote was 3-0 in favor of Comcast > > * Go to Congress and get specific authority > > * Too long of a process > > * 1. Reinforce its ancillary authority argument > > * Suggested by the Court but not considered by the FCC because of > scope issues. > > * 2. Reclassify Internet communications as telecommunications service > to restore direct authority over Broadband communication networks > * 3. THIRD WAY - Move all Broadband Internet access service to Title > II and lightly regulate this service > > * Who is the Target? > > * Rural Carriers offer Broadband Internet access service as a Title II > telecommunications service (no effect) > * RBOC's, wireless, cable and Broadband over powerline providers offer > Broadband Internet access Service as Title 1. > > * These ar
[WISPA] How the FCC Proposes the Regulate Broadband
This is from the second speaker at the conference yesterday. How the FCC Proposes the Regulate Broadband Legal Authority * Many recommendations call into question whether the FCC has the authority to act. For example: * USF reform - Does the FCC have authority to add Broadband to USF? * ICC reform - Does the FCC have authority to mandate changes to state access rates? * Comcast v. FCC April 6, 2010 Court Opinion * Comcast argued that the FCC did not have authority to regulate how Comcast managed its network. * Appellate Court (DC Circuit): 3 judge panel unanimously agreed with Comcast. * FCC was left without a legal foundation providing the necessary authority to enforce its Network Neutrality principles. * Cast doubt on the ability to regulate Broadband under Title 1. * FCC Proposes a THIRD WAY to Regulate Broadband * Appeal Comcast decision * Not likely to succeed as the vote was 3-0 in favor of Comcast * Go to Congress and get specific authority * Too long of a process * 1. Reinforce its ancillary authority argument * Suggested by the Court but not considered by the FCC because of scope issues. * 2. Reclassify Internet communications as telecommunications service to restore direct authority over Broadband communication networks * 3. THIRD WAY - Move all Broadband Internet access service to Title II and lightly regulate this service * Who is the Target? * Rural Carriers offer Broadband Internet access service as a Title II telecommunications service (no effect) * RBOC's, wireless, cable and Broadband over powerline providers offer Broadband Internet access Service as Title 1. * These are the providers that will be subject to Title II regulations * These entities can and will push back very hard * Purpose of the THIRD WAY * The Third Way isn't about Network Neutrality. * The proposed Title II regulation of Broadband Internet access service does not regulate or control the entire transport to the Internet cloud * The Third Way IS about regulation of last mile Broadband for other purposes. * "At the outset, it must be made absolutely clear that the issue of reclassification goes far beyond our open Internet proceeding. It involves some of the most important parts of our National Broadband Plan - universal service, privacy, transparency, and cyber security. Without reclassification, the road to achieving each of those issues is laden with land mines and likely to fail." Commissioner Mignon Clyburn - May 11, 2010 * Propsed Regulations * Section 201 * Requires Internet providers to interconnect and charge reasonable rates * Section 202 * Prevents price and service discrimination * Section 208 * Sets up FCC Complaint processes * Section 222 * Protects customer privacy and proprietary commercial information * Section 254 * Allows use of Universal Service Fund for Broadband * Section 255 * Ensures disability access * Problems with the Third Way * Major push back on this approach by the target providers (not Title II presently) * Problem achieving the goal of the reform - The Third Way doesn't deliver Network Neutrality for example. * Effective regulation of Broadband has to include "customer-to-cloud" transmission. This approach only addresses the last mile and ignores the middle mile transmission. * Avoids regulation of any services provided over the transmission. * Effort is initiated to ensure Net Neutral principles. However, the management of the pipe does not need to be with the pipe provider, instead it can be with the ISP managing and controlling the middle mile to the Internet * The effort includes USF reform * Section 254 requires that USF be used for telecom service. If Broadband isn't a telecom service, the whole notion of USF reform can't happen easily under the NBP. * Next Steps for Title "I.V" * FCC will issue a Notice of Inquiry (NOI) on the matter. * FCC has announced that it will move straight to a Declaratory Ruling after the NOI. * FCC has to create a record that allows the reversal of numerous prior decisions. * This will be a very complicated process Respectfully, Rick Harnish President WISPA 260-307-4000 cell 866-317-2851 WISPA Office Skype: rick.harnish. rharn...@wispa.org WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
