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-------------------------------------------------- From: "Tom DeReggi" <wirelessn...@rapiddsl.net> Sent: Friday, May 28, 2010 9:36 AM To: "WISPA General List" <wireless@wispa.org> 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 a specific frequency set. I'm betting that we could actually have a thriving "unlicensed cellular" industry thriving in 3 years if we had spectrum that was "free" (we don't pay millions to use). Think what you could do if you could use a MIMO type of base station/handset, operating at 600 mhz, using licensed type power, with "clean spectrum" type of sensitivity, and the whole thing was tcp/ip, with the handset doing VOIP over your network, having your own switching / etc, at your network's edge. All you'd need to do is write roaming agreements with your neighboring towns and you're set to start taking away even the POTS lines in your small isolated town. Frankly, your "tower equipment" could be less than $5k/tower and the cost of the rest of the VOIP stuff (not handset) is already known. All we'd need is a good mobile MAC for our wireless... ( anyone ever heard that discussion before?) > 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. The big costs of sites has less to do with towers, than it has to do with obtaining the use of the land they sit upon. Most rural communities are not surrounded by private landowners who think a lease of $300/year is great for a plot the size of their shed. Instead, many are surrounded by state/federal land which is all but perfectly impossible to get to use, unless you have an army of lawyers, lobbyists, and really deep pockets. > > 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. Naw, how about the use of state or federal land for $500/year and no $200,000 environmental impact statements needing to be filed? That's way more useful than a bunch of cumbersome rules designed to force benefits or advantages to specific players. Actually, I'd just call that corruption. -------------------------------------------------------------------------------- WISPA Wants You! 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