At 11/21/2011 06:43 PM, Victoria Proffer wrote: >Great summary! Thanks!
>I saw the VoIP part too and the flag went up. This would tell me, it is >better to put VoIP on your network, sooner than later. > >I am curious what you thought of the Remote Fund that specifically mentioned >Fixed Wireless build out and ongoing support for WISPs. > >I have attached the Public Knowledge and Benton Foundation document that is >referenced in regards to building Community Networks. I love this idea! They have a lot of good ideas in that paper. Not that they were taken terribly seriously at this time. They mentioned Computer III as a model. That is indeed a good one; Computer II, after all (which was watered down by Computer III), is what made the public Internet possible. Its revocation has caused all sorts of trouble. But the FCC went out of their way to avoid touching any of the Computer Inquiries, or to use simple solutions that would have fallen out of them. Much of the complexity in their logic is an attempt to abuse the law to avoid the clear and simple concepts of the Computer Inquiries. So while the new Order is much better than what we would have gotten out of the previous Commission, it doubles down on that fundamental error, which of course was a major shibboleth of the Bells, who hated it with a purple passion. The middle mile question was left open for the Further NPRM, so more Comments may be welcome. >Also I thought it interesting that the FCC was requesting additional comment >on ECT status for WISPs and considering vetting on the federal, rather than >state level. Federal designation of ETCs already exists; I expect it will become more common in the future. >-----Original Message----- >From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On >Behalf Of Fred R. Goldstein >Sent: Monday, November 21, 2011 5:03 PM >To: WISPA General List >Subject: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > >On Friday, the FCC finally released the Order in their Intercarrier >Compensation and Universal Service Fund docket. The executive >summary had come out with the Adoption at last month's FCC Public >Meeting, but the 759-page (!) Order took a while to finish. > >The results, from a WISP perspective, are not nearly as bad as could >have been. The FCC has taken safeguards to make it easier for an >unsubsidized WISP to prevent subsidized competition from an incumbent LEC. > >The high-cost portions of the Universal Service Fund are being >restructured into the Connect America Fund. This will come into >being in three phases, each with different rules for Price Cap >Carriers and Rate of Return Carriers. About 95% of phone lines are >in the former category; the latter are basically small rural carriers >who depend upon USF. > >Phase I is just 2012. Price Cap Carriers will be offered $775 per >line to add 4/1 broadband serivce to "unserved" areas that they >weren't otherwise going to serve. They can choose how many lines >this applies to. If the location is "served" on the National >Broadband Map, or if the ILEC *knows* it's served by an unsubsidized >competitor, it's off limits. I think this must be at least 768k >fixed service. So this might be a good time to make sure the mappers >are aware of your service areas, or to think about short-term service >expansion. The date by which you must be on the map isn't set yet, >but it's presumably in 1H2012. > >Phase II starts in 2013. For this, Price Cap Carriers will be >offered support based on a cost model that the FCC will create in >2012. Once the model is complete, the ILEC will decide if it wants >to take that support for its territory on a state-by-state (all of a >state or nothing) basis. Again, only unserved areas will get >support, though an ILEC can use support to build common plant in an >area that is more than 50% unserved. So a new DSLAM that covers 40% >unserved would not be covered, but ont that covers 60% unserved would >be. So again it's important for WISPs to make their presence >known. If the ILEC turns down the state, USF support goes to the low >bidder. > >Phase III starts in 2018, and will be entirely bid-based, but the >details will be worked out in the future. > >A separate Extremely High Cost fund will allocate up to $100M/year >for locations too costly (by the model) to serve via the standard >subsidy. This will be separately bid, and it's assumed that fixed >wireless and satellite will be the mostly likely technologies. So >this could allow some subsidies to rustic-but-Bell-area WISPs. > >The FCC notes that while this gives ILECs first dibs on funding, it >also takes away Price Cap Carrier USF from areas served by >unsubsidized competitors, so WISPs could theoretically come out >better under the new rules. > >Now here's a catch: "Unsubsidized competitor" is defined as a >provider of both voice and broadband service. It's not entirely >obvious (you try parsing 759 pages of FCC-speak this quickly... ;-) ) >if that applies to the Price Cap Carrier model, or just the rural >Rate of Return case, since the PCCs already offer unsubsidized voice >across most of their territories, and the map isn't about voice. In >the rural Rate of Return Carrier case, voice will be more >important. This does not mean that the WISP must be a CLEC per se; >it might be high-quality (QoS) VoIP offered in conjunction with a >CLEC who has local numbers, for instance. But for some ISPs, this >might be a good time to start thinking about adding voice >service. (My talk at FISPA last month was about the case for whether >an ISP should start up a CLEC.) > >In areas served by rate-of-return carriers, the new rules phase out >(over 3 years) all USF support to an ILEC that is 100% overlapped >(voice and broadband) by an unsubsidized carrier, typically >cable. If there is less than 100% overlap, then support will be >reduced, but the actual methodology is left to be determined via the >Further NPRM. > >So on balance, the FCC has done a lot less harm to the rural WISP >community than it could have, while still encouraging ILECs to deploy >more broadband via subsidies. > > -- > Fred Goldstein k1io fgoldstein "at" ionary.com > ionary Consulting http://www.ionary.com/ > +1 617 795 2701 > > > >---------------------------------------------------------------------------- >---- >WISPA Wants You! 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