Agreed. It is time for WISPA to take the next step. ~V~
-----Original Message----- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Rick Harnish Sent: Thursday, May 20, 2010 9:33 AM To: memb...@wispa.org; motor...@afmug.com; 'WISPA General List' Subject: [WISPA] National Broadband Plan effects on Rural ILECs and Small Telecom Provider's Yesterday, I attended a conference of primarily Rural ILECs with a focus on the National Broadband Plan. It was very interesting to hear another perspective of the plan other than from the wireless industry. Below I will outline some major talking points that were discussed. The first speaker was from NECA (National Exchange Carriers Association). He started out the conversation by saying The National Broadband Plan is a bad plan for Rural ILECs and Small telecommunication providers Later in the program, I had a chance to introduce myself and WISPA. Someone asked the question, What can we do to proactively voice our concerns. I recommended that small trade associations break down the barriers when common interests are at stake. It is essential that partnering between associations will give NPRM/NOI comments more credibility and a greater likelihood be successful. Partnering may also lower lobbying and legal costs which WILL BE substantial in the next few years. My prediction is that many small trade associations will exhaust all capital required to effectively lobby to protect their particular industry interests and will cease to exist. It is important that STAs search for efficient methods to reach satisfactory conclusions. STAs must seek full support from their industry participants and in many cases, raise dues to meet the lobbying demand which is already on the table. It is also essential that cooperative lobbying efforts be adopted between associations to conserve funding. Someone asked me who I thought was behind the National Broadband Plan. Having been a participant representing WISPA at the National Broadband Coalition meetings, it became apparent to me that Washington lobbyists and attorneys have the most to gain by creating conflict and rewriting telecom rules. Do we need a strategic plan? Absolutely! Do we need everything that has been proposed? Absolutely NOT! From my perspective, this proposed plan is very two-faced. While proponents say they want to promote competition, it appears that small competition will be forced out of business. The devil is in the details. We can succeed but we need nearly total cooperation from all WISPs. We need to build our membership base substantially over the next few months. We need to seek out new Association partners. We need to improve our Broadband speeds We need to continue to lobby for more usable spectrum and use it efficiently We need to continue to push manufacturers to improve performance, speed and capacity We need to better promote our industry and its capabilities We need to be less selfish with our hard-earned revenues as insurance to protect our businesses from over regulation by supporting our trade association We need to be more proactive instead of reactive. We need to complain less and be more constructive. In fighting will get us nowhere. We need to reach out to neighboring WISPs in your state or area and promote the need to support WISPA The time is now, there is little time to waste. We either stand up and be recognized or we will begin to die a slow and painful death. Im an optimist by nature and I struggle to write these realities, but they need to be said. Below is an outline of the speech from yesterday. National Broadband Plan Overview: · The NBP is a strategic plan; it is not a series of rules Carol Mattey, Deputy Bureau Chief, FCC Wireline Competition Bureau. · Numerous NPRMs forthcoming (60 are proposed in the next twelve months) National Broadband Plan Goals: · Promote world leading mobile broadband · Foster competition and maximize benefits · Advance and secure public safety communications · Increase Broadband access and adoption o Introduces recommendations to reform federal USF programs and the ICC system · Speed Goals (by 2020) (Actual throughput between the customer and the closest Internet Gateway) o 4/1 Mbps national minimum o 100/50 Mbps to 100 million homes o 1 Gbps (downstream) to Anchor Institutions · Over time these targets will continue to rise o Reevaluate speeds every 4 years · Close the broadband availability gap o 14 million individuals in 7 million housing units § 50% in RBOC territory (which RBOCs were claimed to have done a relatively poor job of broadband deployment) · $24 billion needed to close the gap by 2020 (mostly accomplished by USF modifications) o Does not include the cost of maintaining served areas · Additional congressional support suggested National Broadband Plan Time Frame · Implement USF and ICC reforms over 10 years in three stages o Stage 1 (2010-2011) Mapping data gathering, rulemaking, limited implementation (Heavy reliance on data gathering so educated decisions can be made) o Stage 2 (2012-2016) Most reforms begin o Stage 3 (2017-2020) Complete transitions Proposed USF Reforms · Increase Broadband availability by: o modernizing the High Cost Fund to target Broadband deployment § Completely gutting existing USF programs and replacing with new programs § shift from supporting legacy telephone networks to directly supporting high-capacity broadband deployments § 91% of funding proposed to go to Broadband capable networks o Remove Broadband adoption barriers by: § Modifying lifeline, rural health care and E-rate programs · Existing non-adopter concerns o Affordability o Internet of no relevance to their lives o Personal security concerns · New Funding Mechanisms o Mobility Fund § Provide support for deployment of 3G networks · Short lived · Nationwide ubiquitous coverage § Assist in ubiquitous 3G coverage · Provide footprint of future 4G services § One time disbursement in Stage 2 (2012 target) · To states lagging behind the national average · Capital expenditures only no OPEX o Connect America Fund (CAF) § Provide support to preserve and advance Internet connectivity § Address the Broadband availability gap § Support only to geographic areas lacking a private sector business case · Neutral geographic units o Not study areas (present model) o Mapping based on census level information o Proposed NGUs are counties § Eligibility · Provide 4/1 Mbps Broadband and high quality voice service · Only one recipient per NGU · Company and Technology agnostic o Incumbant or Competitor o Rural and Non-Rural · Meet Broadband provider of last resort obligation § Support Amounts · Include CAOEX and may include OPEX o Fast Track CAPEX only · Include Middle Mile costs · Support Levels based on net gap principle o Forward looking cost less revenues o Based on modeling · Distribution begins in Stage 2 o Cap USF support at 2010 levels (contribution factor is too high presently and is a political hot potato) o Focus first on areas requiring lower support amounts (It is estimated that it will cost $56,000/subscriber to get the final 250,000 citizens hooked up to Broadband, thus they will lag behind) o Selections for both funds to be market based § Competitive procurement auctions proposed · USF funding price for a given market will be set high · Bidders will bid down the price until the lowest bidder is achieved · One awardee per territory (county levels are suspected) · Awardee will gain exclusive USF subsidies fCoor each territory · HOW DOES THAT PROMOTE COMPETITION? IMHO, this creates Mini-monopolies in each service territory · It is anticipated that mobile broadband providers will be the big winners in this scenario o Other Programs § Modify Lifeline and Link-up programs to include broadband services (use only service that includes voice) § Enhance health care and E-Rate programs (increasing speeds up to 1 Gbps) § Other potential enhancements via pilot programs · CPE and modem subsidies to end user cost and increase adoption o Funding Shift § Stage 1 · Begin to phase out CETC support (estimated savings $3.9 billion) § Stage 2 · Redirect remaining CETC support (estimated savings $5.8 billion) o One provider will get support instead of multiple competitors in a given NGU o Redirect Interstate Access Support (estimated savings $4.0 billion) o Require Rate-of-Return carriers to move to incentive regulation (estimated savings $0) § Price capping § Designed for Monopoly areas o Freeze Interstate Common Line Support (estimated savings $1.8 billion) § Lines dropping 5-8%/year o Total Savings $15.5 billion § Savings refocused to CAF Program $11 billion § Mobility Fund-Erate and Switched Access $4 billion § Stage 3 · Eliminate remaining legacy programs o High cost loop o Funding Mechanism § Broaden the USF contribution base to ensure USF remains sustainable over time · Approach to be determined in Stage 1 · Implementation to begin in Stage 2 Proposed ICC Reform * Generalizations: * Switched Access is decreasing * Special Access is increasing * Stage 1 * Interim access arbitrage solution * Stage 2 * Reduce intrastate terminating rates to interstate levels * Reduce all originating and terminating access rates to reciprocal compensation levels * Eliminate all per minute ICC rates by 2020 * Allow for alternate compensation arrangements * Increased SLC, local rate rebalancing and possible USF funding for lost revenue Other NBP Recommendations * Wireless spectrum and data roaming * Computer ownership * Digital literacy * Public Safety * Smart Grid development * Promote competition * Pricing and performance transparency * Review wholesale competition rules * Infrastructure & Rights-of-way rule modifications * Set Top boxes Respectively and Join <http://signup.wispa.org/> WISPA Today, Rick Harnish President WISPA 260-307-4000 cell 866-317-2851 WISPA Office Skype: rick.harnish. rharn...@wispa.org ---------------------------------------------------------------------------- ---- WISPA Wants You! 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