Hi,
I'll try to summarize the meeting, but there are a few action items that
I'd like everyone to seriously consider.
First, a couple of bullet points to be aware of:
- There were several parties that suggested (and felt strongly about)
only accepting CASF grant challenges from providers who have already
filed Form 477 data in the past.
- There were similar feelings towards accepting late challenges.
- Current availability is measured at the census block level. There
were suggestions (and some agreement) that this should perhaps be done
at the parcel level (house by house).
- I pointed out the contradiction of counting households served by fixed
wireless as "unserved", but also approving CASF grants to serve
"unserved" areas with fixed wireless. Wouldn't they still be
"unserved?" The staff acknowledged the contradiction, and asked for
suggestions to improve the situation.
In short, fixed wireless isn't being taken seriously as a viable
long-term option for broadband services. The CPUC staff acknowledges
the benefit it provides now, and even the possibility of being a good
option in the future. However, the other industry players chuckled at
the mention of fixed wireless.
I think the disconnect with the CPUC comes from lack of cooperation on
our part. They're a data-driven organization. They have to back up
their decisions with facts, studies, reports, etc. If we're not giving
them good data, then we don't exist. That said, I'm not a fan of the
latest format of their data request for fixed wireless (locations of all
antennas, radio make/model, etc.), though I do understand why they've
gone that direction. A lot of WISPs were providing large hand-drawn
coverage maps that just aren't specific enough.
So where do we go from here? My intention is to come up with some kind
of compromise so that we can get the CPUC the data they need to
substantiate the fixed wireless industry, what it has already done, and
what it can do in the future. Back when the original request for data
came from the NTIA, there weren't a lot of options. Now, there are at
least a couple of reasonably priced commercial options (separate
services, and integrated into billing software) for generating coverage
maps and creating a list of served census blocks that should coincide
with the CPUC's underlying requirements.
My first thought would be to approach a neutral vendor like
towercoverage.com, and work with them so that they could generate a
dataset that would be acceptable to the CPUC. I have no bias towards
towercoverage.com, just that they already provide this service for
filing the FCC Form 477 data. I would also have to work with the CPUC
to come up with a format that they would be okay with, though I believe
the mobile wireless format is close enough, or could work with minor
modifications.
I created a short survey (linked below) to gauge the interest level, get
feedback, etc. I plan on filling comments regardless of the response
level, but I would much rather the comments be based on the feedback
from other operators, and not just my own.
https://goo.gl/forms/Zsu06Jake0aEF68H2
You're also welcome to send your own informal comments as instructed in
the attached email. However, I think we would benefit from multiple
operators sending a consistent message. If there's a good enough
response, I'll create a template response that we can send individually
or signed as a group.
Thanks for your time,
-Kristian
-------- Forwarded Message --------
Subject: CASF Staff Draft Proposal Comment Period
Date: Sat, 27 May 2017 00:29:53 +0000
From: TD_AR <[email protected]>
To: '[email protected]' <[email protected]>
NOATemplate Sample
STATE OF CALIFORNIAEdmund G. Brown Jr.,/Governor///
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
May 26, 2017
To: Parties on the CASF Distribution (Service) List:
Thank you to those who participated in the CASF workshop yesterday. I
extend the offer to anyone wishing to provide written comments on the
staff proposal to do so by end of day, June 14^th , directly to
[email protected] <mailto:[email protected]>
As I explained during the workshop yesterday, these written comments are
part of a staff informal inquiry. Because this is an informal effort,
there is no requirement to serve written comments to the CASF
distribution / service list.
I intend to present a refined staff proposal to the assigned ALJ and
Commissioner of the existing CASF proceeding OIR 12-10-012. Should the
proceeding be expanded, or the Commission wishes to initiate a separate
proceeding, you will have the opportunity to file formal comments as
part of such proceeding before any rules are changed.
Thanks again for your thoughtful suggestion for improving the CASF program.
Sincerely,
Robert Wullenjohn
Manager, Broadband, Video and Market Branch
Communications Division, CPUC
*__*
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