RE: [WISPA] USF fund reform

2006-03-30 Thread chris cooper
Erate is a federal program.
www.sl.universalservice.org
Its not a matter of whether or not the schools or state will allow you to
provide the service.  It's a competitive bidding process. How you pick your
way through the bidding process is an entirely different beast. Start
learning now if you want to bid on contracts in the late fall. All the
information you need is on the SLD website.  It will take a few weeks to
completely understand it all.  Really. To cook it all down, the whole
program is 1/3 federal $$, 1/3 rigged bidding processes and 1/3 fear.  You
need to position yourself correctly in the bidding process to overcome the
fixed bids.  You need to educate the school district tech coordinators.  99%
of them are overworked and so fearful of making a misstep and loosing their
funding that they just cant stomach change. If you start early and help
educate them on new services, higher speeds and serious savings you stand a
much better chance  of helping them overcome their fear, winning a few bids
and getting your hands on some of those federal $$.  

Chris 
Intelliwave

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of KyWiFi LLC
Sent: Thursday, March 30, 2006 2:32 AM
To: [EMAIL PROTECTED]; WISPA General List
Subject: Re: [WISPA] USF fund reform

Where does a WISP look to find out if their state/city will
allow them to provide broadband service to schools under
the erate program?

I tried searching google but didn't see any details listed for
our state.

-Shannon


- Original Message - 
From: Blair Davis [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Wednesday, March 29, 2006 6:03 PM
Subject: Re: [WISPA] USF fund reform


Same here in Michigan.  We provide internet and data services under the 
erate to several schools.

John Scrivner wrote:


 Years ago I looked into what it would take to sell access to the 
 school. erate is set up so that one company provides all telecom 
 needs to the school.  Voice, data etc.  The only companies that can 
 do that are the ilec or a clec. 



 This is not true in Illinois. We have what is called a SPIN number 
 which allows us to sell Internet to schools even if they get other 
 services from other providers. I am not an ILEC or a CLEC.
 Scriv



-- 
Blair Davis

AOL IM Screen Name --  Theory240

West Michigan Wireless ISP
269-686-8648

A division of:
Camp Communication Services, INC

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Re: [WISPA] USF fund reform

2006-03-29 Thread Marlon K. Schafer (509) 982-2181
I think you are missing the point here.  We're talking about a mechanism to 
bring broadband to the entire country!  Not just a small expansion for you.


Also, most rural telco's will die if they loose these funds.  Sure they're 
milking the system but they'll still fail without it.  Like it or not, they 
are important especially for the next several years.  You need backhaul 
right???  grin  Even they need time to change business models, products, 
infrastructure etc.


That help?
Marlon
(509) 982-2181   Equipment sales
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)And I run my own wisp!
64.146.146.12 (net meeting)
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: KyWiFi LLC [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Tuesday, March 28, 2006 1:11 PM
Subject: Re: [WISPA] USF fund reform



I agree, I would think that 12 months is plenty long enough,
definitely not more than 36 months. Take our company for
example, we deployed 7 broadcast sites in our first 12 months
of operation and we were profitable by month number 8 or 9
and this was WITHOUT any free money. If a company in
this line of work cannot achieve a profit in their first year or
two of operation, I don't see them being around long term.


Sincerely,
Shannon D. Denniston, Co-Founder
KyWiFi, LLC - Mt. Sterling, Kentucky
http://www.KyWiFi.com
http://www.KyWiFiVoice.com
Phone: 859.274.4033
A Broadband Phone  Internet Provider

==
Wireless Broadband, Local Calling and
UNLIMITED Long Distance only $69!

No Taxes, No Regulatory Fees, No Hassles

FREE Site Survey: http://www.KyWiFi.com
==


- Original Message - 
From: Jeromie Reeves [EMAIL PROTECTED]

To: WISPA General List wireless@wispa.org
Sent: Tuesday, March 28, 2006 3:30 PM
Subject: Re: [WISPA] USF fund reform


10 to 20 year time line? I would like to see 1 to 5 years. I do not see
how a network can not be profitable
in that time frame with free monies.

Jeromie

Marlon K. Schafer (509) 982-2181 wrote:


Hi All,

Here's what WISPA is prepared to submit to the commerce committee.
Thought you guys would like a peek at it first.



WISPA USF Reform Position Paper



   WISPA is a the WISP industry's only industry owned and
operated trade association.  We're a 501c6 corporation with a 7
person, membership elected board.



   The goals for USF should be clarified.  Are laptops for
kids part of the program goals?  Was it the original intent that USF
exclude small local entrepreneurs and give preferential treatment to
the incumbent? As USF changes, do the changes have a clear goal?  Is
this just a mechanism to try to put more funds into the program
otherwise leave it as is?  Or does Congress want to see substantial
changes in the program that do more to foster rather than stifle
innovation?



   WISPA believes that market forces should mostly be left to
their own.  Without government tweaking.  USF should be canceled
completely.  If a real need for outside funding in regions or small
pockets turns out to be needed, address those issues on a case by case
basis.  At the very least the USF program needs major reform as its
cost based fee structure encourages abuse.



   An example of artificially high costs would be in Odessa,
Washington.  In the early 2000 time frame the local telco replaced an
8 T-1 microwave link with a fiber optic line at a cost (or so we've
been told) of $600,000.  Even at the time, the cost of a microwave
replacement with more capacity would have been half or less.  This is
for a town of 1000 that's not on the way to anywhere.  The telco is
now in the process of adding more fiber to complete a fiber loop to
other areas.  This next 30 mile stretch is through many solid rock
canyons and the costs are expected to be even higher.



   This same telco has installed $60,000 DSL systems in rural
areas that have fewer than 15 houses within 18,000 feet of the hut.
Clearly these are cost raising mechanisms.



   We understand that USF is not likely to go away at this
time. The above telco gets 2/3rds of its income via subsidies and
would not likely survive without them.  Leaving such business
practices in place permanently is not good public policy though.



   WISPA proposes that a time limit on the USF program be
instituted.  Expand the program to include all communications
companies and use USF to help them build an infrastructure.  Once that
system is built, it needs to stand on its own two legs though.  If it
doesn't, then that's the company's fault and they can live with the
results of the network they built.  Somewhere between 10 and 20 years
should allow plenty of time for efficient network upgrades or
construction.  The program should not be viewed as a permanent profit
line item

Re: [WISPA] USF fund reform

2006-03-29 Thread Marlon K. Schafer (509) 982-2181
I'm not quite sure how to answer this one in this context.  Just went by 
snippets I'd heard over the years on that one.


I'll give you a couple of specific local examples though.
Years ago I looked into what it would take to sell access to the school. 
erate is set up so that one company provides all telecom needs to the 
school.  Voice, data etc.  The only companies that can do that are the ilec 
or a clec.  clec status runs $10,000 plus from what I've always been told. 
That puts the rate of return on the school's system somewhere in never never 
land if all you want is to provide bandwidth.  It's sad, we offer 8 meg 
connections here for $75 per month and they don't buy from me because the 
government won't pay that bill but will pay for the t-1 that they have now. 
Unless they have a 10 meg fiber feed like I do then they are paying hundreds 
per month like I am.


Second is our local hospital with their telemedicine program.  I used to 
sell the hospital internet.  They couldn't use my internet for their 
telemedicine program for security reasons.  It just HAD to be a ptp 
connection to the big hospital.  I even tried to split the costs of the t-1 
with them as they were only configured to use 348k anyhow.  Well, now the 
telemedicine program is somehow able to sell them internet as part of the 
same government funded system!  It's ok to put internet over the 
telemedicine system but not telemedicine over the internet.  Gotta love it.


In both cases there are LOCAL assets available to the government supported 
agencies and they can't use them because of the design of the grants etc. 
This needs to be changed.


Marlon
(509) 982-2181   Equipment sales
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)And I run my own wisp!
64.146.146.12 (net meeting)
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: chris cooper [EMAIL PROTECTED]
To: 'WISPA General List' wireless@wispa.org; 
isp-wireless@isp-wireless.com

Sent: Tuesday, March 28, 2006 9:31 AM
Subject: RE: [WISPA] USF fund reform




Marlon-

This paper mentions Wispa's desire to see changes in the erate program.
Im familiar with the issues involved with erate in Ohio.  What types of
competitive issues are other wisps facing in efforts to win erate
contracts?

Chris
Intelliwave

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Re: [WISPA] USF fund reform

2006-03-29 Thread John Scrivner


Years ago I looked into what it would take to sell access to the 
school. erate is set up so that one company provides all telecom needs 
to the school.  Voice, data etc.  The only companies that can do that 
are the ilec or a clec. 



This is not true in Illinois. We have what is called a SPIN number 
which allows us to sell Internet to schools even if they get other 
services from other providers. I am not an ILEC or a CLEC.

Scriv

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Re: [WISPA] USF fund reform

2006-03-29 Thread John J. Thomas

In some rural areas, it can be tough to do it in 1 to 5 years. What if you need 
to provide service to the 2 houses that are 15 miles from your current tower 
and there is 0 potential for growth? This would allow you to charge enough for 
long enough that you don't have to lose money. How about 5-10 years for build 
out?  I can't think of too many scenarios where you couldn't do it in 10 years.

John

-Original Message-
From: Jeromie Reeves [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 28, 2006 12:30 PM
To: 'WISPA General List'
Subject: Re: [WISPA] USF fund reform

10 to 20 year time line? I would like to see 1 to 5 years. I do not see 
how a network can not be profitable
in that time frame with free monies.

Jeromie

Marlon K. Schafer (509) 982-2181 wrote:

 Hi All,

 Here's what WISPA is prepared to submit to the commerce committee.
 Thought you guys would like a peek at it first.



 WISPA USF Reform Position Paper



WISPA is a the WISP industry's only industry owned and
 operated trade association.  We're a 501c6 corporation with a 7
 person, membership elected board.



The goals for USF should be clarified.  Are laptops for
 kids part of the program goals?  Was it the original intent that USF
 exclude small local entrepreneurs and give preferential treatment to
 the incumbent? As USF changes, do the changes have a clear goal?  Is
 this just a mechanism to try to put more funds into the program
 otherwise leave it as is?  Or does Congress want to see substantial
 changes in the program that do more to foster rather than stifle
 innovation?



WISPA believes that market forces should mostly be left to 
 their own.  Without government tweaking.  USF should be canceled
 completely.  If a real need for outside funding in regions or small
 pockets turns out to be needed, address those issues on a case by case
 basis.  At the very least the USF program needs major reform as its
 cost based fee structure encourages abuse.



An example of artificially high costs would be in Odessa,
 Washington.  In the early 2000 time frame the local telco replaced an 
 8 T-1 microwave link with a fiber optic line at a cost (or so we've
 been told) of $600,000.  Even at the time, the cost of a microwave
 replacement with more capacity would have been half or less.  This is 
 for a town of 1000 that's not on the way to anywhere.  The telco is
 now in the process of adding more fiber to complete a fiber loop to
 other areas.  This next 30 mile stretch is through many solid rock
 canyons and the costs are expected to be even higher.



This same telco has installed $60,000 DSL systems in rural 
 areas that have fewer than 15 houses within 18,000 feet of the hut.
 Clearly these are cost raising mechanisms.



We understand that USF is not likely to go away at this
 time. The above telco gets 2/3rds of its income via subsidies and
 would not likely survive without them.  Leaving such business
 practices in place permanently is not good public policy though.



WISPA proposes that a time limit on the USF program be
 instituted.  Expand the program to include all communications
 companies and use USF to help them build an infrastructure.  Once that
 system is built, it needs to stand on its own two legs though.  If it 
 doesn't, then that's the company's fault and they can live with the
 results of the network they built.  Somewhere between 10 and 20 years 
 should allow plenty of time for efficient network upgrades or
 construction.  The program should not be viewed as a permanent profit 
 line item for companies but rather be a short term
 capitalization/construction fund that will end and leave the company
 standing (or not) on its own  two feet at a set specific date.



 We believe that opening up USF to all operators would likely cause
 multiple networks to be built at the same time and the most efficient 
 ones would survive.  If, after USF was discontinued some areas were
 left with no viable options for service those specific cases could be 
 addressed under some more targeted program.  Funds should be collected
 and distributed based on customers serviced.  This would help prevent 
 speculation with the funds, rather the funds would reward those that
 have already stepped up to the plate.  Tying fund distribution with
 the FCC form 477 would also likely help lead to more accurate market
 data availability.



 WISPA also believes that USF's goals should be readdressed.  We don't 
 believe that using USF funds to provide laptop computers to 68,000 7th
 and 8th graders in Massachusetts is a proper use of the program.



 We would also like to see some changes in the way that USF is
 distributed. The E-Rate program excludes almost all entrepreneurial
 providers.  In some areas the local WISP offers greater service levels
 for less cost than the local hospital or school is paying via the
 E-Rate programs.  We're not allowed

Re: [WISPA] USF fund reform

2006-03-29 Thread John J. Thomas
Are you willing to put up a tower to serve 2 customers? Only if you think you 
can get your money back.

John


-Original Message-
From: KyWiFi LLC [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 28, 2006 01:11 PM
To: 'WISPA General List'
Subject: Re: [WISPA] USF fund reform

I agree, I would think that 12 months is plenty long enough,
definitely not more than 36 months. Take our company for
example, we deployed 7 broadcast sites in our first 12 months
of operation and we were profitable by month number 8 or 9
and this was WITHOUT any free money. If a company in
this line of work cannot achieve a profit in their first year or
two of operation, I don't see them being around long term.


Sincerely,
Shannon D. Denniston, Co-Founder
KyWiFi, LLC - Mt. Sterling, Kentucky
http://www.KyWiFi.com
http://www.KyWiFiVoice.com
Phone: 859.274.4033
A Broadband Phone  Internet Provider

==
Wireless Broadband, Local Calling and
UNLIMITED Long Distance only $69!

No Taxes, No Regulatory Fees, No Hassles

FREE Site Survey: http://www.KyWiFi.com
==


- Original Message - 
From: Jeromie Reeves [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Tuesday, March 28, 2006 3:30 PM
Subject: Re: [WISPA] USF fund reform


10 to 20 year time line? I would like to see 1 to 5 years. I do not see 
how a network can not be profitable
in that time frame with free monies.

Jeromie

Marlon K. Schafer (509) 982-2181 wrote:

 Hi All,

 Here's what WISPA is prepared to submit to the commerce committee.  
 Thought you guys would like a peek at it first.



 WISPA USF Reform Position Paper



WISPA is a the WISP industry's only industry owned and 
 operated trade association.  We're a 501c6 corporation with a 7 
 person, membership elected board.



The goals for USF should be clarified.  Are laptops for 
 kids part of the program goals?  Was it the original intent that USF 
 exclude small local entrepreneurs and give preferential treatment to 
 the incumbent? As USF changes, do the changes have a clear goal?  Is 
 this just a mechanism to try to put more funds into the program 
 otherwise leave it as is?  Or does Congress want to see substantial 
 changes in the program that do more to foster rather than stifle 
 innovation?



WISPA believes that market forces should mostly be left to 
 their own.  Without government tweaking.  USF should be canceled 
 completely.  If a real need for outside funding in regions or small 
 pockets turns out to be needed, address those issues on a case by case 
 basis.  At the very least the USF program needs major reform as its 
 cost based fee structure encourages abuse.



An example of artificially high costs would be in Odessa, 
 Washington.  In the early 2000 time frame the local telco replaced an 
 8 T-1 microwave link with a fiber optic line at a cost (or so we've 
 been told) of $600,000.  Even at the time, the cost of a microwave 
 replacement with more capacity would have been half or less.  This is 
 for a town of 1000 that's not on the way to anywhere.  The telco is 
 now in the process of adding more fiber to complete a fiber loop to 
 other areas.  This next 30 mile stretch is through many solid rock 
 canyons and the costs are expected to be even higher.



This same telco has installed $60,000 DSL systems in rural 
 areas that have fewer than 15 houses within 18,000 feet of the hut.  
 Clearly these are cost raising mechanisms.



We understand that USF is not likely to go away at this 
 time. The above telco gets 2/3rds of its income via subsidies and 
 would not likely survive without them.  Leaving such business 
 practices in place permanently is not good public policy though.



WISPA proposes that a time limit on the USF program be 
 instituted.  Expand the program to include all communications 
 companies and use USF to help them build an infrastructure.  Once that 
 system is built, it needs to stand on its own two legs though.  If it 
 doesn't, then that's the company's fault and they can live with the 
 results of the network they built.  Somewhere between 10 and 20 years 
 should allow plenty of time for efficient network upgrades or 
 construction.  The program should not be viewed as a permanent profit 
 line item for companies but rather be a short term 
 capitalization/construction fund that will end and leave the company 
 standing (or not) on its own  two feet at a set specific date.



 We believe that opening up USF to all operators would likely cause 
 multiple networks to be built at the same time and the most efficient 
 ones would survive.  If, after USF was discontinued some areas were 
 left with no viable options for service those specific cases could be 
 addressed under some more targeted program.  Funds should be collected 
 and distributed based on customers serviced.  This would help prevent

Re: [WISPA] USF fund reform

2006-03-29 Thread KyWiFi LLC
Generally speaking no. However, if the 2 customers are
commercial customers paying a few hundred or a few
thousand dollars per month, then yes, if the numbers work
out to our benefit. Cost is what makes or breaks a deal so
everything has to be analyzed properly. In most cases, a
$400 telephone pole deployment will suffice in place of a
tower. Our company has recently started to deploy roof top
repeaters to pick up additional customers. Under our business
model, we can normally justify the cost of the repeater even
if we are just picking up 1 additional residential customer. In
most cases, that 1 customer is willing to cover part or all of
the cost of the roof top repeater and its installation on a
neighbor's home/barn/silo.

What are the current requirements in order for a telco
to receive USF money? Are they required to provide service
to a specific % of the population in the areas where they receive
USF money? A good friend of mine was once quoted $11,000
by the local telco to run a phone line to his home (he lives a half
mile or so off his road in a rural area). I would think that the
telco must provide service to 100% of the population in the areas
for which they receive the USF money but this is evidently not
how it is structured. Also, how is the USF money currently
shared amongst multiple telcos in the same area/city?

How much USF money is there? What determines the amount
each telco receives?

-Shannon


- Original Message - 
From: John J. Thomas [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Thursday, March 30, 2006 12:47 AM
Subject: Re: [WISPA] USF fund reform


Are you willing to put up a tower to serve 2 customers? Only if you think you 
can get your 
money back.

John


-Original Message-
From: KyWiFi LLC [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 28, 2006 01:11 PM
To: 'WISPA General List'
Subject: Re: [WISPA] USF fund reform

I agree, I would think that 12 months is plenty long enough,
definitely not more than 36 months. Take our company for
example, we deployed 7 broadcast sites in our first 12 months
of operation and we were profitable by month number 8 or 9
and this was WITHOUT any free money. If a company in
this line of work cannot achieve a profit in their first year or
two of operation, I don't see them being around long term.


Sincerely,
Shannon D. Denniston, Co-Founder
KyWiFi, LLC - Mt. Sterling, Kentucky
http://www.KyWiFi.com
http://www.KyWiFiVoice.com
Phone: 859.274.4033
A Broadband Phone  Internet Provider

==
Wireless Broadband, Local Calling and
UNLIMITED Long Distance only $69!

No Taxes, No Regulatory Fees, No Hassles

FREE Site Survey: http://www.KyWiFi.com
==


- Original Message - 
From: Jeromie Reeves [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Tuesday, March 28, 2006 3:30 PM
Subject: Re: [WISPA] USF fund reform


10 to 20 year time line? I would like to see 1 to 5 years. I do not see
how a network can not be profitable
in that time frame with free monies.

Jeromie

Marlon K. Schafer (509) 982-2181 wrote:

 Hi All,

 Here's what WISPA is prepared to submit to the commerce committee.
 Thought you guys would like a peek at it first.



 WISPA USF Reform Position Paper



WISPA is a the WISP industry's only industry owned and
 operated trade association.  We're a 501c6 corporation with a 7
 person, membership elected board.



The goals for USF should be clarified.  Are laptops for
 kids part of the program goals?  Was it the original intent that USF
 exclude small local entrepreneurs and give preferential treatment to
 the incumbent? As USF changes, do the changes have a clear goal?  Is
 this just a mechanism to try to put more funds into the program
 otherwise leave it as is?  Or does Congress want to see substantial
 changes in the program that do more to foster rather than stifle
 innovation?



WISPA believes that market forces should mostly be left to
 their own.  Without government tweaking.  USF should be canceled
 completely.  If a real need for outside funding in regions or small
 pockets turns out to be needed, address those issues on a case by case
 basis.  At the very least the USF program needs major reform as its
 cost based fee structure encourages abuse.



An example of artificially high costs would be in Odessa,
 Washington.  In the early 2000 time frame the local telco replaced an
 8 T-1 microwave link with a fiber optic line at a cost (or so we've
 been told) of $600,000.  Even at the time, the cost of a microwave
 replacement with more capacity would have been half or less.  This is
 for a town of 1000 that's not on the way to anywhere.  The telco is
 now in the process of adding more fiber to complete a fiber loop to
 other areas.  This next 30 mile stretch is through many solid rock
 canyons and the costs are expected to be even higher.



This same telco has

[WISPA] USF fund reform

2006-03-28 Thread Marlon K. Schafer (509) 982-2181

Hi All,

Here's what WISPA is prepared to submit to the commerce committee.  Thought 
you guys would like a peek at it first.




WISPA USF Reform Position Paper



   WISPA is a the WISP industry's only industry owned and operated 
trade association.  We're a 501c6 corporation with a 7 person, membership 
elected board.




   The goals for USF should be clarified.  Are laptops for kids 
part of the program goals?  Was it the original intent that USF exclude 
small local entrepreneurs and give preferential treatment to the incumbent? 
As USF changes, do the changes have a clear goal?  Is this just a mechanism 
to try to put more funds into the program otherwise leave it as is?  Or does 
Congress want to see substantial changes in the program that do more to 
foster rather than stifle innovation?




   WISPA believes that market forces should mostly be left to their 
own.  Without government tweaking.  USF should be canceled completely.  If a 
real need for outside funding in regions or small pockets turns out to be 
needed, address those issues on a case by case basis.  At the very least the 
USF program needs major reform as its cost based fee structure encourages 
abuse.




   An example of artificially high costs would be in Odessa, 
Washington.  In the early 2000 time frame the local telco replaced an 8 T-1 
microwave link with a fiber optic line at a cost (or so we've been told) of 
$600,000.  Even at the time, the cost of a microwave replacement with more 
capacity would have been half or less.  This is for a town of 1000 that's 
not on the way to anywhere.  The telco is now in the process of adding more 
fiber to complete a fiber loop to other areas.  This next 30 mile stretch is 
through many solid rock canyons and the costs are expected to be even 
higher.




   This same telco has installed $60,000 DSL systems in rural areas 
that have fewer than 15 houses within 18,000 feet of the hut.  Clearly these 
are cost raising mechanisms.




   We understand that USF is not likely to go away at this time. 
The above telco gets 2/3rds of its income via subsidies and would not likely 
survive without them.  Leaving such business practices in place permanently 
is not good public policy though.




   WISPA proposes that a time limit on the USF program be 
instituted.  Expand the program to include all communications companies and 
use USF to help them build an infrastructure.  Once that system is built, it 
needs to stand on its own two legs though.  If it doesn't, then that's the 
company's fault and they can live with the results of the network they 
built.  Somewhere between 10 and 20 years should allow plenty of time for 
efficient network upgrades or construction.  The program should not be 
viewed as a permanent profit line item for companies but rather be a short 
term capitalization/construction fund that will end and leave the company 
standing (or not) on its own  two feet at a set specific date.




We believe that opening up USF to all operators would likely cause multiple 
networks to be built at the same time and the most efficient ones would 
survive.  If, after USF was discontinued some areas were left with no viable 
options for service those specific cases could be addressed under some more 
targeted program.  Funds should be collected and distributed based on 
customers serviced.  This would help prevent speculation with the funds, 
rather the funds would reward those that have already stepped up to the 
plate.  Tying fund distribution with the FCC form 477 would also likely help 
lead to more accurate market data availability.




WISPA also believes that USF's goals should be readdressed.  We don't 
believe that using USF funds to provide laptop computers to 68,000 7th and 
8th graders in Massachusetts is a proper use of the program.




We would also like to see some changes in the way that USF is distributed. 
The E-Rate program excludes almost all entrepreneurial providers.  In some 
areas the local WISP offers greater service levels for less cost than the 
local hospital or school is paying via the E-Rate programs.  We're not 
allowed to service those portions of the account that we could take care of 
because we don't have CLEC status or can't offer all services.




It seems to us that a complicated mechanism to compute pay in and pay out 
isn't needed or wanted at this time.  We propose that the current 
contributions simply be expanded to any broadband provider in any area that 
the incumbent currently contributes.  And in any area where USF funds are 
distributed all providers be given equal shares based on customer base.  And 
one customer equals one share.  No company should get more money for more 
services.  This would slow down the convergence of services into 
increasingly efficient networks in rural markets.




This model should encourage both competition and a shift from high cost to 
low cost network