I live in one of these rural coop areas. I bet the rates here are much lower 
than the people in the city pay. The last home telephone I had(2008) ran me 
around $24/mth including all taxes, etc... with no long distance. The telco 
workers make twice to three times the hourly prevailing wage in this area, 
but on par with what a telco worker would make in say New Jersey. I think 
something is flawed in this? They are supposed to be non-profit and they 
making so much money, instead of giving it back to the coop members, they 
just give everyone raises and bonuses. I would like to know just how much 
they get in USF in my area.

"> Oh, voice?  Well, the real scandal of USF is that the ILEC-ETC is
> allowed to do practically anything so long as it's useful for
> voice.  They can build Fiber to the Ranch, for $20,000+/home (CapEx)
> or more, or $1000/month per sub (though they propose making it harder
> to get >$250/line/mo), if it also delivers voice, *even if* they
> already have copper to the ranch *and* an unlicensed WISP.  Check out
> Border to Border in Texas.  So USF does fund broadband; it just does
> it indirectly, by letting them build a broadband-ready network with
> subsidy money.  The ISP they run across it is then "incidental", not
> *directly* subsidized, but if the wire or fiber is already there, how
> much does more it cost to drop on broadband Internet?  Thanks to this
> policy, many rural ILECs have better broadband coverage than
> unsubsidized Bells."

This is the one that really gets under my skin. I compete against it every 
day and they get BIP/BTOP funding in addition. I think they need to FORCE 
every company getting funding from the government or USF to either separate 
their ISP/telco activities and resell to any ISP at the same rate as their 
ISP, or be FORCED to open their network for other ISP's to use at a 
competitive rate. I guess you could say I would like to see it got back to 
the Computer Inquiries.

Nice explanation Fred.

Scottie

----- Original Message ----- 
From: "Fred Goldstein" <fgoldst...@ionary.com>
To: "WISPA General List" <wireless@wispa.org>
Sent: Saturday, February 12, 2011 12:48 PM
Subject: [WISPA] A quick primer on USF


> First off, this last thread's title was offensive, so I changed
> it.  The current Administration is not doing much that previous ones
> didn't do, and that's the problem.  The FCC sees the spectrum as a
> source of revenue (auctions), and Congress sees the FCC as a source
> of subsidy money to rural states.
>
> USF exists because the Telecom Act requires it.  USF replaced an even
> uglier system wherein rural telcos charged really really high
> switched access per minute rates to LD carriers at either end of the
> call.  VoIP would have killed that anyway... so now there are
> explicit cash subsidies.
>
> Let's set aside the smaller parts of USF (Schools & Libraries, Rural
> Health Care, and Low Income) and focus on the one on the table now,
> High Cost Support.  This is the one that gets the bulk of the tax
> money anyway.  The statutory requirement is that rural telephone
> rates be comparable (not identical) to urban ones.  So if it really
> costs $100/month to provide telephone service in East Overshoe, then
> the East Overshoe Telephone Cooperative is entitled to USF to let
> them hold down the rate.
>
> But it's a lot more complicated than that.  Cost is averaged across a
> "study area", which is in general the operating territory of one
> (historic, pre-merger) telephone company in one state.  So South
> Central Bell- Mississippi is one study area, and South Central Bell-
> Tennessee is another.  Verizon has at least two study areas in
> California, though, one ex-Contel and one ex-GTE.  CenturyTel has a
> heap of them all over the place, as does TDS.
>
> The point of averaging across a study area is that low-cost urban
> areas cross-subsidize high-cost rural ones.  So Qwest in Omaha is
> supposed to subsidize Qwest in the rural parts of Nebraska.  Thus the
> big recipients are the small telephone companies who do not have
> urban areas.  That would be bad enough, but a small telephone company
> typically has a separate corporate structure, including IT, CS, etc.,
> which supports very few subscribers.  So the OpEx per subscriber can
> be really high too, because small telcos are inefficient.  If TDS or
> CenturyTel buys them, they often keep the study areas separate...
> cost goes down but the money still flows!  (The pending NPRM does
> however at least open the issue of merging study areas.)  And the
> Bells, especially Qwest/USWest, have sold off a lot of rural
> areas.  So they have lowered their average cost. This doesn't lower
> their rate, though, because they don't get USF anyway, and they are
> on price caps, not rate of return, so they keep their rates and raise
> their margins.  The rural chains that buy the rural turf eventually
> (this takes a couple of years, though again the pending NPRM may
> reduce this interval, which the FCC cutely calls "The Parent Trap")
> get new subsidy flows for them.  So we're screwed both ways.
>
> When TA96 passed, the FCC at the time was pro-competition (Hundt,
> Kennard) and they wanted to make USF pro-competition too.  So they
> created the "Equal Support Rule".  This is a tiny bit like Jeremie's
> suggested voucher system.  A USF-eligible carrier is called an ETC
> (eligible telecommunications carrier). A Competitive ETC (CETC) could
> move into an area whose ILEC got USF.  The CETC would then get the
> same amount *per line* as the ILEC-ETC.  So if East Overshoe
> Telephone got $80/month/line, then Northern Wireless could get
> $80/month/line for selling a fixed-wireless telephone line (using
> their cellular network and a POTS-phone adapter).  Northern Wireless
> (I made that name up but it alludes to a once-huge CETC) would not
> need to show its own costs, as competitors don't fit the ILEC accounting 
> model.
>
> Now you'd think that this was a great idea, like a voucher, but it
> had a big problem.  The ILEC-ETC is usually under Rate of Return
> regulation.  So their profit margin is fixed.  Most of their costs
> are fixed too.  So if the CETC takes lines away, the ILEC-ETC is
> still entitled to keep the subsidy level needed to maintain their
> rate of return and the same low prices.  So they keep their subsidy,
> and USF ends up paying twice!  This is the FCC's justification for
> wanting to do away with competitive ETCs entirely -- they could have
> simply removed Equal Support, but they're killing CETC in toto,
> regardless of what the law actually says.  A few years ago, they
> capped CETC support.  If a new CETC comes into an area, their subsidy
> comes out of other CETCs, no longer equal support.  The total is
> supposed to phase down to 0 over five years.
>
> BTW the biggest CETCs were cellular carriers, including Sprint, AT&T
> Mobility and its predecessors, and some Verizon Wireless
> acquisitions.  VZ and I think Sprint agreed to phase out their CETC
> support as merger conditions.  CLECs got a rather small share of the
> pie.  WISPS need not apply, since they're not carriers, and the
> support was technically for voice.
>
> Oh, voice?  Well, the real scandal of USF is that the ILEC-ETC is
> allowed to do practically anything so long as it's useful for
> voice.  They can build Fiber to the Ranch, for $20,000+/home (CapEx)
> or more, or $1000/month per sub (though they propose making it harder
> to get >$250/line/mo), if it also delivers voice, *even if* they
> already have copper to the ranch *and* an unlicensed WISP.  Check out
> Border to Border in Texas.  So USF does fund broadband; it just does
> it indirectly, by letting them build a broadband-ready network with
> subsidy money.  The ISP they run across it is then "incidental", not
> *directly* subsidized, but if the wire or fiber is already there, how
> much does more it cost to drop on broadband Internet?  Thanks to this
> policy, many rural ILECs have better broadband coverage than
> unsubsidized Bells.
>
> We pay for this.  USF is funded by a tax on "interstate
> telecommunications". That includes long distance calls, circuits, and
> interconnected VoIP (assumed 64.9% interstate, IIRC, but I'm typing
> this off-line on my laptop in a rural location -- I haven't paid VZW
> for tethering and for some reason it no longer works on my cell phone
> ;-] ).  This is technically a "fee" rather than "tax" because it
> doesn't go to the Treasury's General Fund, but it is enforced like a
> tax (big fines if you don't pay).  It goes to USAC, who runs
> USF.  It's a self-adjusting tax.  Every quarter, they compute a new
> rate, and it takes effect automatically.  It started out around 3%
> and is now around 15.5%.
>
> The FCC's new set of proposals has a couple of major impacts.  It
> continues the phase-out of CETC support.  It also creates a new fund,
> "Connect America", which explicitly covers "broadband", as if that
> were a noun.  (Broadband what? It's an adjective.)  This will be
> distibuted by reverse auction; the ETC who asks the least to serve a
> given area gets the exclusive support.  If may be the ILEC.  Whether
> or not it's the ILEC, the ILEC-ETC *continues* to get their current
> support.  Connect America is incremental.  So the ILECs can get even more.
>
> BTW there's a separate pending proposal to create a new USF to fund
> mobile wireless -- licensed CMRS, not WISP.  This may be related to
> the recently announced 98% goal, though it seem to me that Verizon
> had planned that for its LTE network anyway!  BTW the Frontline
> Wireless plan that almost happened in 2007 was required to have 99.3%
> population coverage, though (speaking as one of their network
> designers) that was sort of optimistic, and a sane proposal (that
> might have happened) would have needed a lower number.
>
>  --
>  Fred Goldstein    k1io   fgoldstein "at" ionary.com
>  ionary Consulting              http://www.ionary.com/
>  +1 617 795 2701
>
>
>
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