Agreed, very much so! ----- Mike Hammett Intelligent Computing Solutions http://www.ics-il.com
On 7/29/2010 10:41 AM, Jeff Broadwick wrote: > I am so glad you moved over to the Wispa list Fred! I don't always agree > with you, but I REALLY appreciate how much thought and detail you put into > your responses. > > > 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 Fred Goldstein > Sent: Thursday, July 29, 2010 11:20 AM > To: 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 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&i >>> d=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/ > > > > -------------------------------------------------------------------------------- > WISPA Wants You! 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