At 7/29/2010 10:34 AM, Brian Webster wrote: >Yes but if the cable companies could also ally with wireless carriers to get >other areas excluded from USF subsidies, the field would be a more level one >should the cable companies try to compete in other markets. We might also >get Clearwire and the cellular carriers to support the position although >most of their deployments will probably be in areas that would never have >qualified for USF to begin with. If the terms wireline are kept in the bill >it would appear that wireless services might also be excluded from receiving >any USF funds which basically keeps USF funds in the exclusive hands of the >Telco's as it has been. > >Personally I think that if we don't out and out oppose the bill for USF >reform, but rather do something like this as a minor change, the WISP >industry can make out better. USF reform will happen and USF funds will be >spent on deploying broadband to unserved areas no matter what. What we need >to do is make sure the law does not fund builds in areas already served by >WISP's and other technologies. If the battle could also be fought and won to >allow WISP's access to the funds for broadband deployments then great. When >going up against the cable and Telco lobbies, one has to be wise about >picking their battles as the funding to fight this will be limited.
And on a related note, Patrick Leary wrote, >You'd think there would be an excellent legal argument to fight that. >Seems it'd be difficult to enact a law that in effect discriminates >against certain classes of providers, especially since WISPs are the >only "pure play" broadband providers out there. Theorectically the >re-configured USF is meant to propel broadband...so how could the feds >exclude the only entity that provides broadband first, other services >second. All other providers have "broadband" as a secondary play. Patrick's first... We're talking about a new law, so the legal argument boils down to whatever the law says is legal, is legal, unless it's a flagrant constitutional violation. Which I don't see, since the main issue here is simply who gets government handouts, and handing out money (and taxing) is sort of the normal role of government. The problem is that the system is so corrupt by now that the handouts appear to be irrational. In practice they're not; they just aren't done for the public good. Back to Brian's point... You first have to think about whose bill this is. Boucher doesn't make this stuff up himself. Nor does his staff, though they know more about it than most congressional staffers. Boucher's job in Washington is, and has always been, to carry Verizon's water. When he puts a bill in the hopper, it comes from them. Tom Tauke's staff probably drafted most of the bill. So what is Verizon asking for? You again have to look at what USF is all about. It was created as part of intercarrier compensation reform. Before USF, toll settlements to rural carriers were high enough to pay the subsidies. Make a 30 cent call and the rural carrier gets 50 cents for terminating it. This worked because Long Distance was a huge luxury and thus could be milked. As the cost of delivering LD went down, the amount that could be diverted to supporting the ILECs went up. But the system broke down under competition, especially from VoIP, but also from something called "reality" -- you can't perpetuate a rotten system like that forever. It was hugely inefficient. So intercarrier payments from IXCs to LECs no longer pay the whole freight, and explicit USF makes up the difference. The IXCs, however, are the main payers of USF. They count the cards differently but the kitty still goes the same way. In the 1980s, Verizon (then called Bell Atlantic) was a LEC and on the receiving end of IXC switched access charges. But now the Bells get much lower switched access rates, so it's not a big revenue source for them. Instead, you have Verizon owning the former MCI and Worldcom assets and Southwestern Bell owning the former AT&T Corp. assets, so the two mega-Bells are probably net payers, not recipients, of subsidies to the rurals, both via USF and access charges. Sprint, of course, no longer has any affiliated LECs, so it's a big net loser too. Those three companies thus want to lower the bill. The rural carriers, from the few remaining mom-and-pops to the coops up to big CenturyTel and Citizens/Frontier, want even more. So they are using "broadband" as an excuse. Give them more USF money and they'll extend DSL out further, even FTTH. Hey, it's not *their* money! They don't build gold-plated networks. It's solid 14k gold. (Not 24k. They're too modest for that, and besides 14k is harder.) So what the Boucher bill does is push the FCC along the path it was considering anyway, with some tweaks. The 75% clause is there to cut off support to ILECs that have been almost fully overbuilt by cable, not because cable cares (they don't get USF), but because it may lower the total cost of the USF, and let's face it, PacketCable is just as good as most POTS. It's not Skype! It's not even on the Internet. Verizon HATES the cable industry, especially Comcast, but if the presence of cable can be used against USF subsidy-suckers, then it's counted. USF still only goes to "ETCs", as before, and getting to be an ETC may not be easy. The FCC has largely frozen out new competitors, and their plan is to limit USF high-cost support to ILECs only. The Boucher bill opens it up by creating a subsidized wireless franchise too, so Verizon and its best buddy ATT can split up the country that way. (Sprint and other can bid too, though they're less likely to win.) The odds of a WISP getting USF out of this bill are roughly those of getting a unicorn to ride on to visit customer sites. Now let's get back to the technical issue. The bill not only specifies "wireline", but it requires standard-quality telephony. That means, basically, full-QoS POTS with local phone numbers. Can a WISP deliver that? Yes, but it's not trivial. It requires QoS-engineered networks. It requires high reliability, battery backup, etc. It may be hard for any "routed" network can meet the grade, but that can be fixed in software. It also requires that you use, or be, a local CLEC for the voice service. This is pretty scary for most ISPs, but if there were a good reason for it, then it could be handled. There are a few ways. If there is a local CLEC already, the WISP can partner with it. Or a CLEC can sell wholesale dial tone (SIP, MGCP or H.248, for instance) to the WISP, though that requires the WISP to be a CLEC too. Or the WISP/CLEC can outsource the whole thing to a company who operates a centralized call agent, and who places down a media gateway at the local tandem and does all the work. There are a number of variations possible here and I see some of them in my CLEC work, though the "rent-a-switch" and "rent-a-call-agent" business hasn't developed as far as I'd like it to. But since the WISP still doesn't get USF, there's not much reason to try, unless the WISP wants the voice revenue. Which isn't a bad thing, actually... you can deliver it for a much lower *cost* than the rural ILEC. But you can't undercut the ILEC's *price*, since USF is paying most of the freight. That's the trouble with the whole system. And Boucher and Terry, who represent largely rural constituencies, are not interested in fixing that! In theory, if the law didn't specify wireline and the WISP-CLEC could pass the 75% test, then the ILEC would take a big hit and have to raise its prices, which would be politically unpopular. That's the only upside, and it's a long shot at best. >Brian > > >-----Original Message----- >From: Jeff Broadwick [mailto:jeffl...@comcast.net] >Sent: Thursday, July 29, 2010 10:07 AM >To: bwebs...@wirelessmapping.com; 'WISPA General List' >Subject: RE: [WISPA] USF Reform Bill Introduced - The most compellingreason >to document and map your network coverage ever > >Is cable not considered a "wireline" service? > > >Regards, > >Jeff > > >Jeff Broadwick >ImageStream >800-813-5123 x106 (US/Can) >+1 574-935-8484 x106 (Int'l) > >-----Original Message----- >From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On >Behalf Of Brian Webster >Sent: Thursday, July 29, 2010 10:02 AM >To: 'Fred Goldstein'; 'WISPA General List' >Subject: Re: [WISPA] USF Reform Bill Introduced - The most compellingreason >to document and map your network coverage ever > >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. > > > > > > > > -- Fred Goldstein k1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 -------------------------------------------------------------------------------- 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/
