Fred,

I assure you the WISPA FCC Committee is indeed on this.  You make great
points and we appreciate your review. You are definitely correct, that WISPs
NEED to get on the National Broadband Map NOW!  Those that don't will be
suffering from subsidized competition.  Anyone who does not know who to
contact, drop me a line.  I have contacts now for all states.  Maybe, I can
get that list up on the WISPA website under WISP Resources.  There is one
now, but it is not complete.  I now have 4-5 names per state I believe.

The guys at towercoverage.com are making it easy and inexpensive to make
your maps and get them uploaded to the National/State Maps as well.  

Where there is a Wisp, there is a way!

Respectfully,

Rick Harnish
Executive Director
WISPA
260-307-4000 cell
866-317-2851 Option 2 WISPA Office
Skype: rick.harnish.
rharn...@wispa.org
adm...@wispa.org (Trina and Rick)





> -----Original Message-----
> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
> Behalf Of Fred Goldstein
> Sent: Wednesday, November 28, 2012 5:17 PM
> To: wireless@wispa.org
> Subject: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!
> 
> The FCC's home page ( transition.fcc.gov ) has an item about Connect
America
> Fund, posted with no description.  This turns out to be a further NPRM
about
> Phase I funding.
> 
> As you may recall, CAF Phase I was the short-term (2012) step that offered
> $775 per line to price-cap ILECs (the Bells and other big
> ones) to bring "broadband" to "unserved" areas that they otherwise
wouldn't. It
> was budgeted for $300M but only about $115M was claimed, mostly by
> Frontier.  The Bells didn't take much.  CenturyLink however whined that
the
> definition of "served" should be changed to specifically exclude areas
WISPs, so
> they could get subsidy money to overbuild existing WISPs.  The FCC turned
that
> one down, though CenturyLink did take money for some other areas.
> 
> The new Further Notice of Proposed Rulemaking:
>
http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-
> 138A1.pdf
> asks what to do about the remaining Phase I money.  While they could of
> course just not spend it, lowering the USF tax (now around 17%!), that's
not one
> of the two options they are proposing to select from.  One option is to
simply
> add this funding to Phase II, which begins in 2013.  Phase II allows for
> competition in the awarding of funds; there will be a reverse auction, and
the
> bidder who asks for the least subsidy money gets it.
> 
> Most of the FNPRM, however, is devoted to the other option, essentially a
> second round of Phase I.  They propose changing Phase I rules to encourage
the
> ILECs to take more money.  There are a lot of questions about details, but
the
> basic ideas are along these lines:
> 
> 1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service, vs.
> 768k/200k in the first round.  This would be based on the National
Broadband
> Map, using 3M/768k as a surrogate for 4/1.  (The agencies apparently
hadn't
> agreed on speed tiers.)  So an area served by a WISP at 2M/500k, or by
Canopy
> 100s, would be deemed "unserved", since it's not 4/1.
> 
> 2)  Allow challenges to the national map.  So if an ILEC thinks an area is
> unserved even if a WISP claims it's served, they can argue the matter to
the
> FCC.  This works both ways, so I suppose an ISP could claim that the map
> omitted them by mistake.  But it points out that a WISP SHOULD MAKE SURE
> ITS COVERAGE AREAS ARE ON THE MAP!  (Just a little shouting in case anyone
> didn't hear it.)
> 
> They are supposed to come out with a list of unserved areas (census
> blocks0 next month.
> 
> There are some other interesting details.  Phase I awards are $775 per new
> customer.  That number may be adjusted in this second round.  Also, in
areas
> served by (rural, subsidized) Rate of Return Carriers, the subsidy number
comes
> from the FCC's High Cost Proxy Model.  In Phase 2, these areas get
subsidized
> according to a more elaborate cost model now being debated.
> 
> There is also the possibility that the Phase I recipient may have to build
a
> certain amount of "second mile" (basically, exchange feeder
> fiber) as well as "last mile" distribution.  But there's no clear
obligation to make
> this available at wholesale, which would be nice.
> They also ask about how to handle builds that have to go through served
areas
> in order to reach unserved ones.  So even if you're on the map, you could
get
> overbuilt by the ILEC.
> 
> Note that a Phase I awardee must apply to serve specific unserved areas
and
> applies to serve a certain number of unserved subscribers,
> *but* they do not actually have to use it where they said they would.  The
> applications are merely suggestions of where they might
> find their unserved customers.   They can actually spend it
> elsewhere, so long as they get at least one customer added per $775.
> 
> An open question is that several awardees said that their proposed service
> areas are confidential. The FCC has not decided if this is acceptable, so
it's an
> open question now.  I'd think that a WISP should be allowed to know if the
ILEC
> plans to build subsidized service to an area they're thinking of building
to, so
> this should be public information, not confidential.  So tell the FCC!
> 
> I am hoping the FCC Committee and others interested will take note of
this.  It
> probably won't reach the Federal Register for a while, and then the 30 day
> Comment period begins.
> 
>   --
>   Fred Goldstein    k1io   fgoldstein "at" ionary.com
>   ionary Consulting              http://www.ionary.com/
>   +1 617 795 2701
> 
> _______________________________________________
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