USF for broadband is scary...
The big problems...
1) There will be a push to use funds for fiber networks, (since so many are
pushing for higher speeds for consumers, and with USF mentality its not a
competition to spend cost effectively.).
2) There will be a push to give money to pre-existing USF recipients.
(Government doesn't want to compete with itself. And easier to work with
companies already proven to have experience in USF)
3) WISPs may not qualify if they dont reclass themselves as a LEC or Common
Carrier.
4) Even though many WISPs consider themselves rural, most WISP's subscriber
are still in areas that would be payees into the fund, not recipients of the
fund. So most WISPs could get hit with a 6% USF fee, taking away a strategic
selling advantage over LECs.
5) USF creates small monopolies, kills fair competition, and kills
start-ups. (I believe USF can only go to one entity in an area, I think)
6) One risk is that federal policy will tend to favor those that invest in
fiber, and disadvantage those that use old technology to encourage
investment in new technology.
I could see them, exempting FIOS from paying into the fund, because it
is broadband not regulated telecom, but RBOCs being recipients.
7) double edge sword.... Narrowing qualification for USF area, will prevent
fewer LEC competitiors to WISP pre-existing operations and expansion
markets.
However having narrower qualification could prevent more WISPs from being
eligible.
Many believe USF should be killed. But others believe that even though it
should be killed, if one votes for killing it, they will just be throwing
away their vote, becaues there will likely be some level of USF reform, and
WISPs would be better off influencing the rules, than fighting for something
that wont occur.
My opinion... We should be suggesting to FCC alternatives....
1) Allow any and all to qualify for funds that step up to deploy, at the
same subsidee rate within an area. Meaning qualification is areas not
entities.
(Many will argue that subsidized areas cant sustain competition, and
better chance of success with less duplication). Sure, no two subsidees to
the same house, but first one to the house gets to claim the subsidee for
it. Make it a race where all get paid for their progress and diversity.
2) Make sure ALL competitively advantaged companies pay into the fund. WISPs
should not have to pay into the funds for two reasons... 1) THeir upstream
already pays, and WISP is just an extension of the upstream. Fixed Wireless
is a disadvantaged technology for advanced broadband, and targets
underserved users in all areas of America. It would be counter productive to
start taxing WISPs with USF funds. Thus WISPs should be exempt. Broadband
provider below a certain size should be exempt from USF contribution.
3) Pre-existing recipients should NOT have preferencial treatment.
Actually, maybe the Dept of Justice should be asked to step in (responsible
for anti-trust and such) to prevent the unfair competitive advantage that
pre-existing USF recipients would have to gain USF Broadband subsidees.
4) Suggest replace the USF with customer Voucher system, (explained well by
MAtt LArson not to long ago). Where recipient choses their provider, and
can apply their voucher.
With Voucher system it takes away the false positive, because all can
qualify regardless of if a provider is already in an area. It levels the
playing field.
5) argue that in areas where there really isn;t enough subs for competition
to exist, it wont be a problem, because business men will analyze a market
and competitive environment and not waste their time deploying in an area
where there is already someone else that got a head start in a limited sub
market. .
6)Argue, the problem with USF may not be the terms of payee side. The
problem is program terms on how many is awarded.
7) Argue there are good enough technologies available to serve rural area
cost effectively with less USF subsidations. (AKA wireless).
8) Argue that there is little need for USF for broadband anymore. I believe
it is still possible to gain an outcome to kill USF. Ask New Jersey senator
what he thinks!
9) Subsidees should have DUAL purpose not single purpose. Meaning, it should
not just be to get broadband to rural area. It should also simulataneously
subsidize the growth of small yound companies to stronger companies to build
and strengthen an industry.
The reality....
Truth is.... If Verizon were to charge their non-rural subs 6%, and then be
forced to reallocated that 6% revenue to fund Verizon build-out, would that
be a Good thing? Forcing one company to deploy a specific percentage of
profit to rural America? That is the fundamental arguement that needs to be
answered first. (that removes the arguement verison should have to
subsidize their competitors). One reason USF has not been easy to kill is
that many believe that is an acceptable solution. Penalize the masses, to
help the minority, for a stronger total USA. I'd have to agree with the
idealology. The question now is... Is it still necessary? Has the work
already been done? Is DSL, T1s, and Fixed Wireless good enough for Super
Rural America? If we want to stop USF, we must prove that the job is
already done, and there is no need for USF anymore.
The second ethical question is... Should someone qualify for subsidees that
didn;t pay into the fund. I say yes, because its not about who is the
beneficiary, its about fortunateate consumers helping other less
fortunateate consumers. Its irrelevent who the recipient is, if it creates a
stronger broadband solution for the consumers of the area, and most
efficiently uses the funds available. ONce again we must strongly argue
that wireless is the most efficient use of funds for rural areas, quick to
deploy. And above all ONGOING Competitive environments not lcoal monopolies
not a specific speed technology, is what benefits consumer's most.
LAstly, Our theme song should be... "You cant always have what you want, but
if you try you can have what you need" :-)
Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband
----- Original Message -----
From: "Bret Clark" <bcl...@spectraaccess.com>
To: <wireless@wispa.org>
Sent: Monday, February 07, 2011 5:55 PM
Subject: [WISPA] FCC Favors Shifting Rural Subsidies To Broadband
> Ugh...not good. Last thing I need is to compete with the ILEC who is
> getting money from the Universal Slush Fund to provide government
> subsidized broadband in rural areas. And I can see every ILEC in America
> lobbing to ensure that the distribution of USF continues "as is" if the
> shift is made to broadband instead of telephone...basically filling the
> ILEC's coffers! The FCC is looking for comments, so we all need to make
> it quite clear that the funds should be available for any and all
> broadband providers!
>
> http://news.yahoo.com/s/nf/20110207/tc_nf/77213
>
> Bret
>
> Bret Clark
> Spectra Access
> 25 Lowell Street
> Manchester, NH 03101
> www.spectraaccess.com
>
>
>
>
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