Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-22 Thread Steve Barnes
Scottie, I have the same issue here in Indiana with one exchange in particular. 
 I have been in contact with the Indiana Utility Regulatory Committee.  They 
are in process of helping us.  They could not understand why we could port and 
have access to all other exchanges in the same rate center but not that one.  

Steve Barnes
General Manager
PCS-WIN / RC-WiFi


-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf 
Of Scottie Arnett
Sent: Tuesday, November 22, 2011 12:58 AM
To: WISPA General List
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

We just happen to fall into one of those 3.65Ghz protected areas! But I have 
heard that the local telco has something going on there too!

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message -
From: Fred Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 10:38 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 At 11/21/2011 11:18 PM, Scottie Arnett wrote:
Re-reading your posts brings me to another question.has any VOIP
carriers ever used cellular carriers numbers? Is it even possible?

 First, wrt the Livingston exchange, 931-397 and 931-403 belong to US
 Cellular; the latter is pooled (they're using the 7's).  Nextel has
 -871, pooled (using 6 and 7).  Oddly, US Cellular but not S-N says it
 subtends a Gaineborough tandem, which is Twin Lakes, but most Twin
 Lakes exchanges subtend Nashville.

 As to VoIP via cellular numbers, well, its sort of odd, but it might
 be possible.  The new rules may actually say something about this -- 
 there was a VoIP company affiliated with a wireless company that was,
 uh, alleged to have been laundering its LD calls via the cellular
 company in order to get the lower termination rates.  They deny it of
 course... but that may have been addressed in the intercarrier
 rules.  I haven't gotten through it all yet. (It's freakin' huge.)  I
 actually had a client that was a wireless company whose business
 included lots and lots of modems, way back when, so it's not
 unprecedented to have, uh, incidental non-wireless traffic go
 through a wirless feed.  And heck, put up one 3.65 GHz base station
 (if it's allowed there) and declare it CMRS, and you're a cellco too!

 There's one lawyer I know who sort of specializes in this sort of thing.

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message -
From: Scottie Arnett sarn...@info-ed.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 10:14 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing 
ILECs


  Please explain about the Livingston exchange!!! I have been trying to
  break
  this barrier for almost 12 years.
 
  Scottie Arnett
  President
  Info-Ed, Inc.
  Electronics and More
  931-243-2101
  sarn...@info-ed.com
  - Original Message -
  From: Fred Goldstein fgoldst...@ionary.com
  To: WISPA General List wireless@wispa.org
  Sent: Monday, November 21, 2011 9:08 PM
  Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing
  ILECs
 
 
  At 11/21/2011 09:29 PM, you wrote:
 The only other telcos/cellcos here that have local numbers are US
 Cellular
 and Verizon. None of the big VOIP carriers do, such as
 Vonage/Packet8/take
 your pick. They have NO Clec's here either.
 
  I like to think of that as a challenge. ;-)  The good news is that
  they use the Nashville tandem, not their own, so the traffic exchange
  can be indirect.
 
  But it's true that there are no CLECs with numbers in TLTC's
  area.  Powertel, US Cellular, VZW and Sprint Nextel are the only
  other carriers there, all mobile.  No Celina numbers, either, if it
  matters. But Livingston has pooled prefix codes available.
 
 
   --
   Fred Goldsteink1io   fgoldstein at ionary.com
   ionary Consulting  http://www.ionary.com/
   +1 617 795 2701
 
 
 
 
 
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WISPA

Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-22 Thread Tom DeReggi
 The FCC just had to have a date, and was nice enough to not close it
 too early.  This also gives WISPs time to do some more construction
 and have it included.


Thats one way to look at it.  (And probably the more productive way, 
recognizing the timeline to protect opportunity.)

 The whole-state rule applies to the big ILECs.  If they say no, the
 rules for the auction aren't written yet, and may work on a smaller
 basis.  I think that's one of the things to discuss in the FNPRM
 Comments, which are due 24 January.

But why would big ILEC's say, no ?
Isn't this process pressuring the ILECs to say yes. Giving the ILECs a 
second chance to get another free ride, now for broadband?
If ILEC took subsidee for Voice in past, why would they not do the same for 
Data?
Small ILECs might say no, because they might not have the funding or 
resources to take on a super large project even with subsidee.
But Big Telco surely has the finances. We can use ATT as an example, who is 
advertising to cover all of America in 5 years, anyway.

Do you think there is any chance that the big telco might say no in some 
states, I dont want USF?

It has happened in the past, to some extent. I can give the example of 
Verizon pulling out of a low profit analog market, and letting a smaller LEC 
take over such as either Century tel or Frontier (forget which LEC, and 
which Eastern state).. Back then it made sense with Verizon focusing on FIOS 
preferring to bypass regulation, that FIOS allowed them.
But would that same justification still be there, when USF subsidees are 
there to compensate?

 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
..
 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.

Also, regarding those to comments in your original Email... I think the risk 
here is the same that it was with ARRA.
Whats the definition of unserved, and but more importantly what is the 
definition of area, and what is the protest proof process, and is WISP's 
coverage large enough to qualify an area as served?  And will gerrymandering 
allow a recipient to get around it?  Obviously, the National MAP, that 
documents all reported coverage from all carriers will help quite a bit. But 
I'm still concerned that many WISP's coverage will be to small of a take 
rate or area, to be proportional enough to mark an area as served.   I can 
tell you that in my rural markets, it would be near impossible to get over 
50% coverage, even if I served everyhome that I had coverage to.
Lets use a hypothetical example of the average member WISP having 1000 subs. 
There are not many areas that have less than 2000 potential subs.  I can 
tell you from community connect grant research, looking at census data, it 
was tough finding areas that gained maximum points of under 500 households.

Did it say anything in the rules, to define what an eligible size area is? 
Both for identifying served and unserved, not just USF qualification?

Wondering if NTIA/USDA is going to help identify preferred qualifying area 
on the broadband map?  I dont think it will be as simple as looking for 
blank spots.
IS there currently a map of ILEC coverage area of Voice, that can be 
overlaid to the broadband map?

A question likely to develop for WISPs is What are the safest places to 
invest in expanding coverage, meaning less likely to get overbuilt with 
subsidized competition?
The very Suburban/Urban and very Rural are becomming most likely for 
subsidee and harsh competition. Some where in the middle, such as barely 
rural, may be safer?

Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - 
From: Fred Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 9:08 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 At 11/21/2011 08:04 PM, you wrote:
Yes agreed, its not nearly as bad as it could have been. But I still say
ARRGGG!

  Price Cap Carriers will be offered $775 per
  line to add 4/1 broadband serivce to unserved areas

Thats much better for WISPs than if they agreed to pay our competitors
greater than $10,000 per sub for FIOS like Fiber.
WISPs atleast have a chance to compete against 4/1 services, and ILEC
reimbursement now inline with what it would cost a WISP to deploy, and not
to much more..

 Note that this is incremental $775, a subsidy to add to their
 capital budget, not the total investment.  Of course big ILECs tend
 to be wasteful spenders.

  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.

yeah, you gotta love help that says WISPs Go hurry up and build a
network at your cost quickly, we wont pay you, but if you dont build 
quick,
we'll pay

Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-22 Thread Sam Tetherow
] 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 Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701



 
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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-22 Thread Fred Goldstein
.

Now when auction time comes, AFAIK the size of each area to be 
auctioned has yet to be determined..

And for Rate of Return carriers, the rules will differ, and don't 
seem firm yet, so census blocks might not be the protected 
level.  You might need a much bigger footprint.

Did it say anything in the rules, to define what an eligible size area is?
Both for identifying served and unserved, not just USF qualification?

Wondering if NTIA/USDA is going to help identify preferred qualifying area
on the broadband map?  I dont think it will be as simple as looking for
blank spots.
IS there currently a map of ILEC coverage area of Voice, that can be
overlaid to the broadband map?

A few states do have it, but in general, ILEC coverage maps are not 
publicly available in GIS format.  They are however always included 
in baseline tariffs.  To be sure, the tariff maps you can find are 
usually n-th generation photocopies of hand-tool-drawn maps from the 
1940s or so, and illegible, but they're official.  And there are 
(expensive) commercial GIS layers showing each ILEC wire center's 
coverage boundary.

But this also ties in to Carrier of Last Resort obligations.  ILECs 
have state COLR obligations in most states, which is covered by their 
open-ended (monopoly/USF) finance model. An open question now is what 
happens to COLR if they lose their USF.  Does CAF come with COLR?

A question likely to develop for WISPs is What are the safest places to
invest in expanding coverage, meaning less likely to get overbuilt with
subsidized competition?
The very Suburban/Urban and very Rural are becomming most likely for
subsidee and harsh competition. Some where in the middle, such as barely
rural, may be safer?


I'm not done with the rules yet, but offhand my guess is the safest 
place is one served by a Price Cap Carrier (not a small rural telco) 
that is far from their major focus (cities).  But then the question 
is not really relevant for a lot of WISPs and local ISPs and 
CLECs.  We serve the areas we serve because that's our 
business.  It's finance capital that looks for cream areas to 
skim.  Locals need to be able to operate anywhere.  And that's a 
problem with some of the FCC rules, which assume that the operator is 
really mobile finance capital that will operate where it's most 
profitable, and to hell with potential customers in harder-to-serve 
areas.  These new rules are less evil in that regard than some others 
from the past decade, though -- they at least made some effort to 
balance it a little.


- Original Message -
From: Fred Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 9:08 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


  At 11/21/2011 08:04 PM, you wrote:
 Yes agreed, its not nearly as bad as it could have been. But I still say
 ARRGGG!
 
   Price Cap Carriers will be offered $775 per
   line to add 4/1 broadband serivce to unserved areas
 
 Thats much better for WISPs than if they agreed to pay our competitors
 greater than $10,000 per sub for FIOS like Fiber.
 WISPs atleast have a chance to compete against 4/1 services, and ILEC
 reimbursement now inline with what it would cost a WISP to deploy, and not
 to much more..
 
  Note that this is incremental $775, a subsidy to add to their
  capital budget, not the total investment.  Of course big ILECs tend
  to be wasteful spenders.
 
   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.
 
 yeah, you gotta love help that says WISPs Go hurry up and build a
 network at your cost quickly, we wont pay you, but if you dont build
 quick,
 we'll pay your competitor instead.
 (Sarcasm)
 
   The date by which you must be on the map isn't set yet,
   but it's presumably in 1H2012.
 
 Well, that is good, that they are looking at mapping for disqualification.
 Also good that not all WISPs reported their coverage in the past.
 The rules are good incentive for rural WISPs to report now.  Those rules
 may
 not have ever made it into the FCC rules, without the insight that it
 would
 be incentive to get reamining WISPs to report.  If WISPs had already
 reported, why would the FCC have needed to include consideration and
 incentive in the new rules?
 
  The FCC just had to have a date, and was nice enough to not close it
  too early.  This also gives WISPs time to do some more construction
  and have it included.
 
   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.
 
 Thats the bad part Only a select few monopoly like companies can
 afford
 to do complete State wide deployment, even when subsidized.
 So basically

Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-22 Thread Fred Goldstein
At 11/22/2011 11:53 AM, Sam Tetherow wrote:
Is there any provision in the document for reducing funding in the
future as areas get overbuilt?  Or are we really looking at a 6-8month
land grab?

Good question. I see two land grabs, actually, Phase 1 and 2, both in 
2012, but potentially a few months apart.  Otherwise, Phase 3 rules 
aren't firm yet. Once Phase 2 is awarded, it's there for five 
years.  Phase 3 is likely to have another unsubsidized-competitor 
test around 2017.  Probably to discuss in the FNPRM, which has a lot 
of questions I haven't all read yet.

  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701 




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[WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Fred R. Goldstein
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 Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701 




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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Scottie Arnett
How can you offer voice if you can not get local phone number's because of a 
rural telephone cooperative?

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message - 
From: Fred R. Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 5:02 PM
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 Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701



 
 WISPA Wants You! Join today!
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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Fred Goldstein
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

Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Tom DeReggi
Yes agreed, its not nearly as bad as it could have been. But I still say 
ARRGGG!

 Price Cap Carriers will be offered $775 per
 line to add 4/1 broadband serivce to unserved areas

Thats much better for WISPs than if they agreed to pay our competitors 
greater than $10,000 per sub for FIOS like Fiber.
WISPs atleast have a chance to compete against 4/1 services, and ILEC 
reimbursement now inline with what it would cost a WISP to deploy, and not 
to much more..

 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.

yeah, you gotta love help that says WISPs Go hurry up and build a 
network at your cost quickly, we wont pay you, but if you dont build quick, 
we'll pay your competitor instead.
(Sarcasm)

 The date by which you must be on the map isn't set yet,
 but it's presumably in 1H2012.

Well, that is good, that they are looking at mapping for disqualification. 
Also good that not all WISPs reported their coverage in the past.
The rules are good incentive for rural WISPs to report now.  Those rules may 
not have ever made it into the FCC rules, without the insight that it would 
be incentive to get reamining WISPs to report.  If WISPs had already 
reported, why would the FCC have needed to include consideration and 
incentive in the new rules?

 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.

Thats the bad part Only a select few monopoly like companies can afford 
to do complete State wide deployment, even when subsidized.
So basically, the FCC is saying Time to force the Monopolies to serve 
ALL Americans, and leave no unserved areas left for the competitive 
property.
Rather than fix the problem, the FCC is trying to secure that the remaining 
25% of America will have subsidized competitors to private investment.
There is no longer a consideration for the best party to serve a specific 
area. Preferrence is given to the big boy.
no different than Auctions, where only the most fortunate and dominant 
player can win.
The biggest flaw in telecom policy is the concept of Serving everyone or no 
one. Its the founation for every monopoly cable franchise type agreement, 
and now being replicated into CAF. Forcing acceptance on a complete 
state-by-state basis in my opinion is a major loss for the industry. Because 
the mind set hasn't changed from old telecom. They are still thinking state 
regulation and utility electricity, where there is only ONE primary 
provider per state.

Although, I will admit, these funds are targeted to UNSERVED areas, so 
atleast they aren't giving the whole state away. Just the least desirable 
part of the state for wireline to serve.

They are saying. WISPs, if you can serve someone new this year, great, 
go for it, its your last chance, before we give the market to someone else.

 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.

Yes, that may be good for WISPs.
Or, better positioned ILECs to become WISPs.

 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.

I fully agree with your conclusion.
Realistically, that could be considered a victory, for Rural WISPs.

With that said, I would have preferred the FCC to have the balls to name the 
new program what it really was...
They could have called it the CAIF - Connect America to ILECs fund.  or 
KCC-CAF - Kill Competiton and Choice, but Connect America Fund..

The interesting part will be to see how many RURAL ILECs will choose to 
accept $768 per sub, to build out to all remaining Americans in their state.
What else will be interesting will be to see if, the RBOC fund recipients 
really do what they are obligated to do afterwords.

I think it is an ambitious plan to try to get the remaining American's some 
form of broadband, which outcome would likely be good, I just cant say I 
agree with the method.

Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - 
From: Fred R. Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 6:02 PM
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

Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Fred Goldstein
At 11/21/2011 07:50 PM, Scottie Arnett wrote:
How can you offer voice if you can not get local phone number's because of a
rural telephone cooperative?

I don't believe a rural cooperative can prevent you from pulling 
numbers from the NANPA.  They are even required to interconnect with 
you for the exchange of traffic which, under the new rules, will 
*eventually* (like 9 years out) be at bilk-and-keep.  You might 
however have to interconnect indirectly, via a third-party tandem, 
and there's some issue of recourse if they block calls to you.  They 
are not required to lease you any network elements.  And they don't 
like to be, well, too cooperative...  but I'd first want to check 
with the lawyers to know exactly how much privilege an RTC still has.



  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701 




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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Fred Goldstein
At 11/21/2011 08:04 PM, you wrote:
Yes agreed, its not nearly as bad as it could have been. But I still say
ARRGGG!

  Price Cap Carriers will be offered $775 per
  line to add 4/1 broadband serivce to unserved areas

Thats much better for WISPs than if they agreed to pay our competitors
greater than $10,000 per sub for FIOS like Fiber.
WISPs atleast have a chance to compete against 4/1 services, and ILEC
reimbursement now inline with what it would cost a WISP to deploy, and not
to much more..

Note that this is incremental $775, a subsidy to add to their 
capital budget, not the total investment.  Of course big ILECs tend 
to be wasteful spenders.

  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.

yeah, you gotta love help that says WISPs Go hurry up and build a
network at your cost quickly, we wont pay you, but if you dont build quick,
we'll pay your competitor instead.
(Sarcasm)

  The date by which you must be on the map isn't set yet,
  but it's presumably in 1H2012.

Well, that is good, that they are looking at mapping for disqualification.
Also good that not all WISPs reported their coverage in the past.
The rules are good incentive for rural WISPs to report now.  Those rules may
not have ever made it into the FCC rules, without the insight that it would
be incentive to get reamining WISPs to report.  If WISPs had already
reported, why would the FCC have needed to include consideration and
incentive in the new rules?

The FCC just had to have a date, and was nice enough to not close it 
too early.  This also gives WISPs time to do some more construction 
and have it included.

  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.

Thats the bad part Only a select few monopoly like companies can afford
to do complete State wide deployment, even when subsidized.
So basically, the FCC is saying Time to force the Monopolies to serve
ALL Americans, and leave no unserved areas left for the competitive
property.

The whole-state rule applies to the big ILECs.  If they say no, the 
rules for the auction aren't written yet, and may work on a smaller 
basis.  I think that's one of the things to discuss in the FNPRM 
Comments, which are due 24 January.

...
  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.

Yes, that may be good for WISPs.
Or, better positioned ILECs to become WISPs.

Good question.  But due to caps on USF, ILECs might not want to play 
in that space.  Also, the Big Dog Theory might come into play -- big 
dogs want big bones.  A rural ILEC might play though, or a small CMRS.

  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.

I fully agree with your conclusion.
Realistically, that could be considered a victory, for Rural WISPs.

With that said, I would have preferred the FCC to have the balls to name the
new program what it really was...
They could have called it the CAIF - Connect America to ILECs fund.  or
KCC-CAF - Kill Competiton and Choice, but Connect America Fund..

The interesting part will be to see how many RURAL ILECs will choose to
accept $768 per sub, to build out to all remaining Americans in their state.
What else will be interesting will be to see if, the RBOC fund recipients
really do what they are obligated to do afterwords.

That number doesn't necessarily apply to Phase II -- if the bids are 
on a more granular area basis, they could go considerably 
higher.  And they'll be for five years of funding, though frankly I'd 
prefer just CapEx, since WISPs need capital and big ILECs just need 
to pay off their investors.

I think it is an ambitious plan to try to get the remaining American's some
form of broadband, which outcome would likely be good, I just cant say I
agree with the method.

I'm with you there.  It's far from ideal, but it could have been worse.

Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message -
From: Fred R. Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 6:02 PM
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

Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Scottie Arnett
The only other telcos/cellcos here that have local numbers are US Cellular 
and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take 
your pick. They have NO Clec's here either.

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message - 
From: Fred Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 8:01 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 At 11/21/2011 07:50 PM, Scottie Arnett wrote:
How can you offer voice if you can not get local phone number's because of 
a
rural telephone cooperative?

 I don't believe a rural cooperative can prevent you from pulling
 numbers from the NANPA.  They are even required to interconnect with
 you for the exchange of traffic which, under the new rules, will
 *eventually* (like 9 years out) be at bilk-and-keep.  You might
 however have to interconnect indirectly, via a third-party tandem,
 and there's some issue of recourse if they block calls to you.  They
 are not required to lease you any network elements.  And they don't
 like to be, well, too cooperative...  but I'd first want to check
 with the lawyers to know exactly how much privilege an RTC still has.



  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701



 
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 http://signup.wispa.org/
 

 WISPA Wireless List: wireless@wispa.org

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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Mike Hammett
http://www.localcallingguide.com/lca_switch.php?tandem=NSVNTNGN00T

Looks like all RLECs, but maybe you'd have luck with one of them.

-
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com



On 11/21/2011 8:29 PM, Scottie Arnett wrote:
 The only other telcos/cellcos here that have local numbers are US Cellular
 and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take
 your pick. They have NO Clec's here either.

 Scottie Arnett
 President
 Info-Ed, Inc.
 Electronics and More
 931-243-2101
 sarn...@info-ed.com
 - Original Message -
 From: Fred Goldsteinfgoldst...@ionary.com
 To: WISPA General Listwireless@wispa.org
 Sent: Monday, November 21, 2011 8:01 PM
 Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 At 11/21/2011 07:50 PM, Scottie Arnett wrote:
 How can you offer voice if you can not get local phone number's because of
 a
 rural telephone cooperative?
 I don't believe a rural cooperative can prevent you from pulling
 numbers from the NANPA.  They are even required to interconnect with
 you for the exchange of traffic which, under the new rules, will
 *eventually* (like 9 years out) be at bilk-and-keep.  You might
 however have to interconnect indirectly, via a third-party tandem,
 and there's some issue of recourse if they block calls to you.  They
 are not required to lease you any network elements.  And they don't
 like to be, well, too cooperative...  but I'd first want to check
 with the lawyers to know exactly how much privilege an RTC still has.



   --
   Fred Goldsteink1io   fgoldstein at ionary.com
   ionary Consulting  http://www.ionary.com/
   +1 617 795 2701



 
 WISPA Wants You! Join today!
 http://signup.wispa.org/
 

 WISPA Wireless List: wireless@wispa.org

 Subscribe/Unsubscribe:
 http://lists.wispa.org/mailman/listinfo/wireless

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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Fred Goldstein
At 11/21/2011 09:29 PM, you wrote:
The only other telcos/cellcos here that have local numbers are US Cellular
and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take
your pick. They have NO Clec's here either.

I like to think of that as a challenge. ;-)  The good news is that 
they use the Nashville tandem, not their own, so the traffic exchange 
can be indirect.

But it's true that there are no CLECs with numbers in TLTC's 
area.  Powertel, US Cellular, VZW and Sprint Nextel are the only 
other carriers there, all mobile.  No Celina numbers, either, if it 
matters. But Livingston has pooled prefix codes available.


  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701 




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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Scottie Arnett
TN is FULLL of cooperatives. From what I have found, the state of TN 
likes to protect them too.

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message - 
From: Mike Hammett wispawirel...@ics-il.net
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 8:42 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 http://www.localcallingguide.com/lca_switch.php?tandem=NSVNTNGN00T

 Looks like all RLECs, but maybe you'd have luck with one of them.

 -
 Mike Hammett
 Intelligent Computing Solutions
 http://www.ics-il.com



 On 11/21/2011 8:29 PM, Scottie Arnett wrote:
 The only other telcos/cellcos here that have local numbers are US 
 Cellular
 and Verizon. None of the big VOIP carriers do, such as 
 Vonage/Packet8/take
 your pick. They have NO Clec's here either.

 Scottie Arnett
 President
 Info-Ed, Inc.
 Electronics and More
 931-243-2101
 sarn...@info-ed.com
 - Original Message -
 From: Fred Goldsteinfgoldst...@ionary.com
 To: WISPA General Listwireless@wispa.org
 Sent: Monday, November 21, 2011 8:01 PM
 Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing 
 ILECs


 At 11/21/2011 07:50 PM, Scottie Arnett wrote:
 How can you offer voice if you can not get local phone number's because 
 of
 a
 rural telephone cooperative?
 I don't believe a rural cooperative can prevent you from pulling
 numbers from the NANPA.  They are even required to interconnect with
 you for the exchange of traffic which, under the new rules, will
 *eventually* (like 9 years out) be at bilk-and-keep.  You might
 however have to interconnect indirectly, via a third-party tandem,
 and there's some issue of recourse if they block calls to you.  They
 are not required to lease you any network elements.  And they don't
 like to be, well, too cooperative...  but I'd first want to check
 with the lawyers to know exactly how much privilege an RTC still has.



   --
   Fred Goldsteink1io   fgoldstein at ionary.com
   ionary Consulting  http://www.ionary.com/
   +1 617 795 2701



 
 WISPA Wants You! Join today!
 http://signup.wispa.org/
 

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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Scottie Arnett
Please explain about the Livingston exchange!!! I have been trying to break 
this barrier for almost 12 years.

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message - 
From: Fred Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 9:08 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 At 11/21/2011 09:29 PM, you wrote:
The only other telcos/cellcos here that have local numbers are US 
Cellular
and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take
your pick. They have NO Clec's here either.

 I like to think of that as a challenge. ;-)  The good news is that
 they use the Nashville tandem, not their own, so the traffic exchange
 can be indirect.

 But it's true that there are no CLECs with numbers in TLTC's
 area.  Powertel, US Cellular, VZW and Sprint Nextel are the only
 other carriers there, all mobile.  No Celina numbers, either, if it
 matters. But Livingston has pooled prefix codes available.


  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701



 
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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Scottie Arnett
Re-reading your posts brings me to another question.has any VOIP 
carriers ever used cellular carriers numbers? Is it even possible?

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message - 
From: Scottie Arnett sarn...@info-ed.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 10:14 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 Please explain about the Livingston exchange!!! I have been trying to 
 break
 this barrier for almost 12 years.

 Scottie Arnett
 President
 Info-Ed, Inc.
 Electronics and More
 931-243-2101
 sarn...@info-ed.com
 - Original Message - 
 From: Fred Goldstein fgoldst...@ionary.com
 To: WISPA General List wireless@wispa.org
 Sent: Monday, November 21, 2011 9:08 PM
 Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing 
 ILECs


 At 11/21/2011 09:29 PM, you wrote:
The only other telcos/cellcos here that have local numbers are US
Cellular
and Verizon. None of the big VOIP carriers do, such as 
Vonage/Packet8/take
your pick. They have NO Clec's here either.

 I like to think of that as a challenge. ;-)  The good news is that
 they use the Nashville tandem, not their own, so the traffic exchange
 can be indirect.

 But it's true that there are no CLECs with numbers in TLTC's
 area.  Powertel, US Cellular, VZW and Sprint Nextel are the only
 other carriers there, all mobile.  No Celina numbers, either, if it
 matters. But Livingston has pooled prefix codes available.


  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701



 
 WISPA Wants You! Join today!
 http://signup.wispa.org/
 

 WISPA Wireless List: wireless@wispa.org

 Subscribe/Unsubscribe:
 http://lists.wispa.org/mailman/listinfo/wireless

 Archives: http://lists.wispa.org/pipermail/wireless/



 
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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Fred Goldstein
At 11/21/2011 11:18 PM, Scottie Arnett wrote:
Re-reading your posts brings me to another question.has any VOIP
carriers ever used cellular carriers numbers? Is it even possible?

First, wrt the Livingston exchange, 931-397 and 931-403 belong to US 
Cellular; the latter is pooled (they're using the 7's).  Nextel has 
-871, pooled (using 6 and 7).  Oddly, US Cellular but not S-N says it 
subtends a Gaineborough tandem, which is Twin Lakes, but most Twin 
Lakes exchanges subtend Nashville.

As to VoIP via cellular numbers, well, its sort of odd, but it might 
be possible.  The new rules may actually say something about this -- 
there was a VoIP company affiliated with a wireless company that was, 
uh, alleged to have been laundering its LD calls via the cellular 
company in order to get the lower termination rates.  They deny it of 
course... but that may have been addressed in the intercarrier 
rules.  I haven't gotten through it all yet. (It's freakin' huge.)  I 
actually had a client that was a wireless company whose business 
included lots and lots of modems, way back when, so it's not 
unprecedented to have, uh, incidental non-wireless traffic go 
through a wirless feed.  And heck, put up one 3.65 GHz base station 
(if it's allowed there) and declare it CMRS, and you're a cellco too!

There's one lawyer I know who sort of specializes in this sort of thing.

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message -
From: Scottie Arnett sarn...@info-ed.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 10:14 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


  Please explain about the Livingston exchange!!! I have been trying to
  break
  this barrier for almost 12 years.
 
  Scottie Arnett
  President
  Info-Ed, Inc.
  Electronics and More
  931-243-2101
  sarn...@info-ed.com
  - Original Message -
  From: Fred Goldstein fgoldst...@ionary.com
  To: WISPA General List wireless@wispa.org
  Sent: Monday, November 21, 2011 9:08 PM
  Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing
  ILECs
 
 
  At 11/21/2011 09:29 PM, you wrote:
 The only other telcos/cellcos here that have local numbers are US
 Cellular
 and Verizon. None of the big VOIP carriers do, such as
 Vonage/Packet8/take
 your pick. They have NO Clec's here either.
 
  I like to think of that as a challenge. ;-)  The good news is that
  they use the Nashville tandem, not their own, so the traffic exchange
  can be indirect.
 
  But it's true that there are no CLECs with numbers in TLTC's
  area.  Powertel, US Cellular, VZW and Sprint Nextel are the only
  other carriers there, all mobile.  No Celina numbers, either, if it
  matters. But Livingston has pooled prefix codes available.
 
 
   --
   Fred Goldsteink1io   fgoldstein at ionary.com
   ionary Consulting  http://www.ionary.com/
   +1 617 795 2701
 
 
 
  
 
  WISPA Wants You! Join today!
  http://signup.wispa.org/
  
 
 
  WISPA Wireless List: wireless@wispa.org
 
  Subscribe/Unsubscribe:
  http://lists.wispa.org/mailman/listinfo/wireless
 
  Archives: http://lists.wispa.org/pipermail/wireless/
 
 
 
  
 
  WISPA Wants You! Join today!
  http://signup.wispa.org/
  
 
 
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  Subscribe/Unsubscribe:
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  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701 




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Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs

2011-11-21 Thread Scottie Arnett
We just happen to fall into one of those 3.65Ghz protected areas! But I have 
heard that the local telco has something going on there too!

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message - 
From: Fred Goldstein fgoldst...@ionary.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 10:38 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs


 At 11/21/2011 11:18 PM, Scottie Arnett wrote:
Re-reading your posts brings me to another question.has any VOIP
carriers ever used cellular carriers numbers? Is it even possible?

 First, wrt the Livingston exchange, 931-397 and 931-403 belong to US
 Cellular; the latter is pooled (they're using the 7's).  Nextel has
 -871, pooled (using 6 and 7).  Oddly, US Cellular but not S-N says it
 subtends a Gaineborough tandem, which is Twin Lakes, but most Twin
 Lakes exchanges subtend Nashville.

 As to VoIP via cellular numbers, well, its sort of odd, but it might
 be possible.  The new rules may actually say something about this -- 
 there was a VoIP company affiliated with a wireless company that was,
 uh, alleged to have been laundering its LD calls via the cellular
 company in order to get the lower termination rates.  They deny it of
 course... but that may have been addressed in the intercarrier
 rules.  I haven't gotten through it all yet. (It's freakin' huge.)  I
 actually had a client that was a wireless company whose business
 included lots and lots of modems, way back when, so it's not
 unprecedented to have, uh, incidental non-wireless traffic go
 through a wirless feed.  And heck, put up one 3.65 GHz base station
 (if it's allowed there) and declare it CMRS, and you're a cellco too!

 There's one lawyer I know who sort of specializes in this sort of thing.

Scottie Arnett
President
Info-Ed, Inc.
Electronics and More
931-243-2101
sarn...@info-ed.com
- Original Message -
From: Scottie Arnett sarn...@info-ed.com
To: WISPA General List wireless@wispa.org
Sent: Monday, November 21, 2011 10:14 PM
Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing 
ILECs


  Please explain about the Livingston exchange!!! I have been trying to
  break
  this barrier for almost 12 years.
 
  Scottie Arnett
  President
  Info-Ed, Inc.
  Electronics and More
  931-243-2101
  sarn...@info-ed.com
  - Original Message -
  From: Fred Goldstein fgoldst...@ionary.com
  To: WISPA General List wireless@wispa.org
  Sent: Monday, November 21, 2011 9:08 PM
  Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing
  ILECs
 
 
  At 11/21/2011 09:29 PM, you wrote:
 The only other telcos/cellcos here that have local numbers are US
 Cellular
 and Verizon. None of the big VOIP carriers do, such as
 Vonage/Packet8/take
 your pick. They have NO Clec's here either.
 
  I like to think of that as a challenge. ;-)  The good news is that
  they use the Nashville tandem, not their own, so the traffic exchange
  can be indirect.
 
  But it's true that there are no CLECs with numbers in TLTC's
  area.  Powertel, US Cellular, VZW and Sprint Nextel are the only
  other carriers there, all mobile.  No Celina numbers, either, if it
  matters. But Livingston has pooled prefix codes available.
 
 
   --
   Fred Goldsteink1io   fgoldstein at ionary.com
   ionary Consulting  http://www.ionary.com/
   +1 617 795 2701
 
 
 
 
 
  WISPA Wants You! Join today!
  http://signup.wispa.org/
 
 
 
  WISPA Wireless List: wireless@wispa.org
 
  Subscribe/Unsubscribe:
  http://lists.wispa.org/mailman/listinfo/wireless
 
  Archives: http://lists.wispa.org/pipermail/wireless/
 
 
 
 
 
  WISPA Wants You! Join today!
  http://signup.wispa.org/
 
 
 
  WISPA Wireless List: wireless@wispa.org
 
  Subscribe/Unsubscribe:
  http://lists.wispa.org/mailman/listinfo/wireless
 
  Archives: http://lists.wispa.org/pipermail/wireless/




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  --
  Fred Goldsteink1io   fgoldstein at ionary.com
  ionary Consulting  http://www.ionary.com/
  +1 617 795 2701



 
 WISPA Wants You! Join today!
 http://signup.wispa.org