At 7/13/2010 09:17 AM, Stuart Pierce wrote:
>I apologize, but WT% !?!? What and where is the documentation about 
>this change to USF, the plan to put WISP's out of business once and 
>for all. Who in their right mind would be in or start a WISP, when 
>it's crazy enough already ?

The problem with keeping track of the FCC is that they have multiple 
dockets going at once, some open for over a dozen years.

There has been a USF docket open since maybe forever (probably 1996 
when it was founded).  There has also been an open docket on 
intercarrier compensation (what IXCs and LECs pay each other) since 
2001.  Now at first glance you might not think these are related, but 
USF was created in order to allow intercarrier compensation to return 
towards cost, instead of having huge per-minute rates from IXCs as 
the sole subsidy to rural carriers.  And it doesn't take a PhD in 
economics from Chicago ;-) to understand that VoIP is part of the 
picture too, since a Skype call pays precisely zero.  So charge too 
much for long distance and you move people to VoIP, which is 
happening, so USF is how they hold the rural carriers harmless while 
fixing that issue.

In November, 2008, the FCC announced the next stage of its 
intercarrier compensation *and* USF dockets.  They put out a massive 
"further NPRM" and took Comments for the n'th time.  The USF portion 
of the plan called for phasing out all Competitive ETC support.  This 
followed an earlier freeze (I think that was temporary) on new CETCs, 
so existing ones get paid but new ones need not apply.  (That 
December, I put together a pair of lengthy Comments, on USF and 
Intercarrier, for a group of CLECs called the Coalition for Rational 
Universal Service and Intercarrier Reform.  You can find them on my 
web site, where I have pointers to some of my FCC Comments.) And in 
April of this year, they put out yet another NPRM on USF reform, 
again capping CETC support at current levels (no new ones need apply) 
and phasing all CETCs out over five years.

Now in the Broadband Internet NOI, they're trying to broaden the type 
of support that non-competiitve ETCs (that is, ILECs) get.  It is 
suggesting that the ILEC should get support for non-common-carrier 
ISP activities.

You put these all together and the word begins with "cluster".

>May as well fine Gilbert for calling Lebron James names when he left 
>Cleveland.

;-)

>---------- Original Message ----------------------------------
>From: Fred Goldstein <fgoldst...@ionary.com>
>Reply-To: WISPA General List <wireless@wispa.org>
>Date:  Tue, 13 Jul 2010 00:41:07 -0400
>
> >At 7/13/2010 12:31 AM, Chuck Hogg wrote:
> >>That's a double edged sword... You don't pay into USF currently as
> >>WISP's are not classified as such.  Then if we are, we'd have a hard
> >>time at it, but we'd be eligible for those funds.
> >
> >Try again, Chuck.
> >
> >The pending FCC proposal is a bit worse, where "bit" is roughly the
> >size of the Grand Canyon.  It basically says that USF taxation, now
> >at 15%, will be extended to ISPs.  BUT it also says that eligibility
> >to collect USF will be limited to one company in a given geographic
> >area, rather than the competitive situation now allowed.  This is how
> >they will control costs, without limiting how much an ILEC can
> >get.  (It is almost literally a blank check. I have an article about
> >this on my web site and TMCnet column.)  So if you are not the ILEC,
> >you can't become Eligible. But you may still be taxed in order to pay
> >the (Eligible) ILEC to operate as an ISP, without its offering even
> >common carrier DSL (which they have to today in order to be
> >Eligible).  They in turn will be subsidized to the extent required to
> >make their prices as low as urban rates.  In other words, you are
> >taxed to pay them to compete with you.
> >
> >I am finishing up editing my Comment in the current FCC Broadband
> >Internet NOI.  My comment on USF, which I won't actually include in
> >the final submission, is that their treatment of WISPs is tantamount
> >to the Chinese policy of billing the families of executed prisoners
> >for the bullet.
> >
> >
> >  --
> >  Fred Goldstein    k1io   fgoldstein "at" ionary.com
> >  ionary Consulting              http://www.ionary.com/
> >  +1 617 795 2701
> >
> >
> >
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  --
  Fred Goldstein    k1io   fgoldstein "at" ionary.com
  ionary Consulting              http://www.ionary.com/
  +1 617 795 2701 



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