Fred,
        That is understood, however I think that WISPA may try to lobby to
have the term "wireline" removed such that any technology that delivers the
defined broadband and voice services should be qualified to meet the 75%
requirement. This is still a bill and not a law so there are opportunities
to change this although I don't expect that one to go through without a
fight. In this case we might be able to ally ourselves with the cable
industry. I am sure they would love to see Telco's lose their USF subsidies
in markets that are served by cable.



Brian

-----Original Message-----
From: Fred Goldstein [mailto:fgoldst...@ionary.com] 
Sent: Thursday, July 29, 2010 9:42 AM
To: bwebs...@wirelessmapping.com; WISPA General List
Subject: Re: [WISPA] USF Reform Bill Introduced - The most compelling reason
to document and map your network coverage ever

At 7/29/2010 08:01 AM, Brian wrote:
>Hit me off list and I can offer some suggestions.

As I mentioned, the 75% rule only applies to wireline providers 
(i.e., cable), so mapping WISP coverage buys nothing.

The Boucher-Terry bill has nothing in it to help WISPs and plenty to 
hurt them, including a rather high tax to support your competitors.



>Brian
>
>
>-----Original Message-----
>From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
>Behalf Of RickG
>Sent: Wednesday, July 28, 2010 11:24 PM
>To: WISPA General List
>Subject: Re: [WISPA] USF Reform Bill Introduced - The most compelling
reason
>to document and map your network coverage ever
>
>I'd like to but I dont know where to begin and with my limited time I
>cant even try to figure it out.
>
>On Wed, Jul 28, 2010 at 12:37 PM, Brian Webster
><bwebs...@wirelessmapping.com> wrote:
> > Steve Coran just posted the message below to the WISPA FCC committee
list.
>I
> > took particular note to the following statement:
> >
> >
> >
> > - would reduce or deny support to wireline incumbents in areas where at
> > least 75% of households can receive voice and broadband from a
competitive
> > provider that does not receive support
> >
> >
> >
> > Now the way I read the above statement is that if a WISP covers 75% of a
> > current USF recipients service area, there will no longer be eligibility
>to
> > receive USF funds. Remember if they have broadband they also have access
>to
> > many VOIP providers even if you do not provide VOIP services. Vonage and
> > Skype come to mind, not to mention cellular coverage. This would be a
huge
> > factor in leveling the playing field for WISP's in rural markets! I
cannot
> > see a more compelling reason to document and map your networks than
this.
> > Not only will it prevent yet another subsidized competitor from coming
in
>to
> > your service area, but it will also erode funding  for any Telco who
> > currently receives USF in your markets. This would bring wireless as a
> > delivery method to the forefront because there are then no artificial
> > revenue streams subsidizing the cost to deliver last mile service. We
all
> > know that wireless has the least cost per household passed in low
density
> > markets.
> >
> >
> >
> > There are many ways to document and map your coverage areas. First and
> > foremost though is that you should file the Form 477 as required. Next
one
> > should map their network with an accurate service area where you would
> > confidently offer service. This can be done many ways (including paying
me
> > to do it). This also shows a very important reason to be participating
in
> > your state broadband mapping efforts. I would expect that those state
maps
> > will become one of the major verification sources to establish the 75%
> > coverage. The FCC 477 database will probably become another verification
> > source. If you are listed in both of them it would be very hard for
>someone
> > to say you don't exist and don't offer coverage in their areas.
> >
> >
> >
> > One of the downsides to this bill is that all broadband providers will
be
> > required to contribute to the fund. My gut feeling though is that if
>WISP's
> > were accurately mapped and documented it would show so much less of the
US
> > is unserved by broadband and thus the required funding through USF to
get
>it
> > there will be much less.
> >
> > Brian
> >
> > ----------------------------------
> >
> >
> >
> > Last week, Reps. Boucher (D-VA) and Terry (R-NE) introduced legislation
>that
> > would reform the Universal Service Fund.  The Press Release, Overview,
> > Section by Section summary and text of the bill are available at this
>link:
> >
> >
>http://www.boucher.house.gov/index.php?option=com_content&task=view&id=1579
&
>Itemid=122
> >
> >
> >
> > I have not read these documents, but plan to do so soon.  A few
highlights
> > that the trade press has noted:
> >
> >     - would reduce or deny support to wireline incumbents in areas where
>at
> > least 75% of households can receive voice and broadband from a
competitive
> > provider that does not receive support
> >
> >     - FCC would create cost model that includes broadband in figuring
> > support models
> >
> >     - competitive bidding among wireless carriers for USF support
> >
> >     - no more than two wireless CETCs could get support in the same area
> >
> >     - carriers would have 5 years to provide broadband throughout their
> > service areas, or would lose support
> >
> >     - all broadband providers would pay into USF to expand contribution
>base
> >
> >     - FCC to decide appropriate speed for broadband
> >
> >
> >
> > Rep. Boucher has said that the bill is on his "front burner" and that he
> > wants to get the legislation passed this Fall.  Please feel free to
>comment
> > on-list AFTER you've reviewed the documents so that you can promote
> > education of the WISPA membership and help shape whatever position WISPA
>may
> > wish to take as the bill works its way through Congress.  Thanks.
> >
> >
> >
> > Stephen E. Coran
> >
> > Rini Coran, PC
> >
> > 1140 19th Street, NW, Suite 600
> >
> > Washington, D.C. 20036
> >
> > 202.463.4310 - voice
> >
> > 202.669.3288 - cell
> >
> > 202.296.2014 - fax
> >
> > sco...@rinicoran.com - e-mail
> >
> > www.rinicoran.com
> >
> > www.telecommunicationslaw.com
> >
> >
> >
> >
> >
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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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