It sounds like a lot of good was taken and contributed to that meeting. I'm glad you were there.
What interests me most will be to fully learn what scenergies will be found between our groups. At the end of the day, when it come to government increasing regulation, the sides become provider versus governbment. Under those circumstances, its amazing how many issues we share in common with these other groups. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband ----- Original Message ----- From: "Rick Harnish" <rharn...@wispa.org> To: "'WISPA General List'" <wireless@wispa.org> Sent: Thursday, May 20, 2010 4:25 PM Subject: Re: [WISPA] National Broadband Plan effects on Rural ILECsand SmallTelecom Provider's Tom, The general perception is that mobile broadband providers will be the most likely recipients of the Reverse Auction procedure. Voice is going mobile and they obviously have a solid lobbying front. It would seem logical that mobile providers could accept lower subsidies with lower overhead and still produce respectable revenue. I am not totally familiar with all the USF details but with landlines decreasing at a rapid rate it would seem logical that this shift would go to the resulting technology that replaces landlines. Of note, there will be only one USF subsidy recipient per NGU after the reverse auction is complete. Therefore, only one company will be subsidized in each geographical area. If that doesn't spell MONOPOLY, I don't know what does. The Rural ILEC's do not expect good things to come from the USF rewrite. Now those opinions presented may be biased. The presenters were Bob Gnapp of NECA and Douglas Meredith from John Starulakis, Inc. (JSI). The group welcomed my comments and I saw lots of head shaking (up and down) as I spoke. Although competitors, they understand the power of partnership, at least they seemed to. I suppose they could have just been courteous. I have reached out to Bob Gnapp from NECA today and he said: "Rick, I think your proposal to see what our associations may be able to accomplish together is a good one. I'll be in touch. Bob" There is realistically recognition from the Rural ILECs that unlicensed spectrum is competition, especially if they hold AWS or 700 MHz licenses. One speaker acted as though all spectrum would be auctioned to raise money to pay for the Broadband Stimulus and National Broadband Plan. That is one very important reason we need to achieve higher member participation throughout our industry. Respectfully, Rick Harnish > -----Original Message----- > From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On > Behalf Of Tom DeReggi > Sent: Thursday, May 20, 2010 4:07 PM > To: WISPA General List > Subject: Re: [WISPA] National Broadband Plan effects on Rural ILECs and > SmallTelecom Provider's > > Rick, > > Good info.... > > How open was that group (rural ILECs) to WISPA in general? Did they > agree or > disagree that there were scenergies to work togeather? I would think > that > Rural ILECs would benefit heavilly from the NBP goals that favored > subsidizing Rural ILECs. > Basically instead of USF recipients gaining funds for Phone, they > receive > the same funds to build broadband. Why wouldn't they want that? A > local > non-ILEC WISP surely wouldn't want that. > > "$24 billion needed to close the gap by 2020 (mostly accomplished > by USF modifications): > > "shift from supporting legacy telephone networks to directly > supporting > high-capacity broadband deployments" > > "Only one recipient per NGU" > > "One awardee per territory (county levels are suspected)" > > So what that says to me is that we are in trouble. NBP's intent is to > give > the remaing userved market to monoplies. > And more so it suggests USF could be one of the biggest threats to > WISPs, > because the program could generate enough funds to successfully fund > giving > all the remaining prime unserved markets to ILECs. > What it says to me is, NBP's intent is to REPEAT the mistake of the > Original > USF, by replicating the flaws for broadband. > > "HOW DOES THAT PROMOTE COMPETITION? IMHO, this creates > Mini-monopolies in each service territory " > > All I can say to that is, AMEN! I here ya. > > What bothers me the most is.... NOT ONE SINGLE WORD to preserving small > local operators and competition. > Not one word about strengthening the "provider industry" as a whole. > This is a plan to extinguish an industry, in favor of building mini > monopolies.. > Unless we stop that destrutive mind set, or derail progress, our > industry > is doomed. > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > ----- Original Message ----- > From: "Rick Harnish" <rharn...@wispa.org> > To: <memb...@wispa.org>; <motor...@afmug.com>; "'WISPA General List'" > <wireless@wispa.org> > Sent: Thursday, May 20, 2010 10:33 AM > Subject: [WISPA] National Broadband Plan effects on Rural ILECs and > SmallTelecom Provider's > > > Yesterday, I attended a conference of primarily Rural ILECs with a > focus on > the National Broadband Plan. It was very interesting to hear another > perspective of the plan other than from the wireless industry. Below I > will > outline some major talking points that were discussed. The first > speaker > was from NECA (National Exchange Carrier's Association). He started > out the > conversation by saying "The National Broadband Plan is a bad plan for > Rural > ILECs and Small telecommunication providers" > > > > Later in the program, I had a chance to introduce myself and WISPA. > Someone > asked the question, "What can we do to proactively voice our concerns". > I > recommended that small trade associations break down the barriers when > common interests are at stake. It is essential that partnering between > associations will give NPRM/NOI comments more credibility and a greater > likelihood be successful. Partnering may also lower lobbying and legal > costs which WILL BE substantial in the next few years. My prediction > is > that many small trade associations will exhaust all capital required to > effectively lobby to protect their particular industry interests and > will > cease to exist. It is important that STA's search for efficient > methods to > reach satisfactory conclusions. STA's must seek full support from > their > industry participants and in many cases, raise dues to meet the > lobbying > demand which is already on the table. It is also essential that > cooperative > lobbying efforts be adopted between associations to conserve funding. > > > > Someone asked me who I thought was behind the National Broadband Plan. > Having been a participant representing WISPA at the National Broadband > Coalition meetings, it became apparent to me that Washington lobbyists > and > attorneys have the most to gain by creating conflict and rewriting > telecom > rules. Do we need a strategic plan? Absolutely! Do we need > everything > that has been proposed? Absolutely NOT! From my perspective, this > proposed > plan is very two-faced. While proponents say they want to promote > competition, it appears that small competition will be forced out of > business. The devil is in the details. > > > > We can succeed but we need nearly total cooperation from all WISPs. > > We need to build our membership base substantially over the next few > months. > > > We need to seek out new Association partners. > > We need to improve our Broadband speeds > > We need to continue to lobby for more usable spectrum and use it > efficiently > > We need to continue to push manufacturers to improve performance, speed > and > capacity > > We need to better promote our industry and its capabilities > > We need to be less "selfish" with our hard-earned revenues as insurance > to > protect our businesses from over regulation by supporting our trade > association > > We need to be more proactive instead of reactive. > > We need to complain less and be more constructive. In fighting will > get us > nowhere. > > We need to reach out to neighboring WISPs in your state or area and > promote > the need to support WISPA > > > > The time is now, there is little time to waste. We either stand up and > be > recognized or we will begin to die a slow and painful death. I'm an > optimist by nature and I struggle to write these realities, but they > need to > be said. > > > > Below is an outline of the speech from yesterday. > > > > National Broadband Plan Overview: > > · "The NBP is a strategic plan; it is not a series of rules" > Carol > Mattey, Deputy Bureau Chief, FCC Wireline Competition Bureau. > > · Numerous NPRMs forthcoming (60 are proposed in the next > twelve > months) > > > > National Broadband Plan Goals: > > · Promote world leading mobile broadband > > · Foster competition and maximize benefits > > · Advance and secure public safety communications > > · Increase Broadband access and adoption > > o Introduces recommendations to reform federal USF programs and the > ICC > system > > · Speed Goals (by 2020) (Actual throughput between the > customer and > the closest Internet Gateway) > > o 4/1 Mbps national minimum > > o 100/50 Mbps to 100 million homes > > o 1 Gbps (downstream) to Anchor Institutions > > · "Over time these targets will continue to rise" > > o Reevaluate speeds every 4 years > > · Close the "broadband availability gap" > > o 14 million individuals in 7 million "housing units" > > § 50% in RBOC territory (which RBOC's were claimed to have done a > relatively poor job of broadband deployment) > > · $24 billion needed to close the gap by 2020 (mostly > accomplished > by USF modifications) > > o Does not include the cost of maintaining "served" areas > > · Additional congressional support suggested > > > > National Broadband Plan Time Frame > > · Implement USF and ICC reforms over 10 years in three stages > > o Stage 1 (2010-2011) - Mapping - data gathering, rulemaking, limited > implementation (Heavy reliance on data gathering so educated decisions > can > be made) > > o Stage 2 (2012-2016) - Most reforms begin > > o Stage 3 (2017-2020) -Complete transitions > > > > Proposed USF Reforms > > · Increase Broadband availability by: > > o "modernizing" the High Cost Fund to target Broadband deployment > > § Completely gutting existing USF programs and replacing with new > programs > > § "shift from supporting legacy telephone networks to directly > supporting > high-capacity broadband deployments" > > § 91% of funding proposed to go to Broadband capable networks > > o Remove Broadband adoption barriers by: > > § Modifying lifeline, rural health care and E-rate programs > > · Existing non-adopter concerns > > o Affordability > > o Internet of no relevance to their lives > > o Personal security concerns > > · New Funding Mechanisms > > o Mobility Fund > > § Provide support for deployment of 3G networks > > · Short lived > > · Nationwide ubiquitous coverage > > § Assist in ubiquitous 3G coverage > > · Provide footprint of future 4G services > > § One time disbursement in Stage 2 (2012 target) > > · To states lagging behind the national average > > · Capital expenditures only - no OPEX > > o Connect America Fund (CAF) > > § Provide support to preserve and advance Internet connectivity > > § Address the Broadband availability gap > > § Support only to geographic areas lacking a "private sector business > case" > > · "Neutral geographic units" > > o Not study areas (present model) > > o Mapping based on census level information > > o Proposed NGU's are counties > > § Eligibility > > · Provide 4/1 Mbps Broadband and "high quality" voice service > > · Only one recipient per NGU > > · Company and Technology agnostic > > o Incumbant or Competitor > > o Rural and Non-Rural > > · Meet "Broadband provider of last resort obligation" > > § Support Amounts > > · Include CAOEX and may include OPEX > > o "Fast Track" CAPEX only > > · Include Middle Mile costs > > · Support Levels based on "net gap" principle > > o Forward looking cost less revenues > > o Based on modeling > > · Distribution begins in Stage 2 > > o Cap USF support at 2010 levels (contribution factor is too high > presently and is a political hot potato) > > o Focus first on areas requiring lower support amounts (It is > estimated > that it will cost $56,000/subscriber to get the final 250,000 citizens > hooked up to Broadband", thus they will lag behind) > > o Selections for both funds to be market based > > § Competitive procurement auctions proposed > > · USF funding price for a given market will be set high > > · Bidders will bid down the price until the lowest bidder is > achieved > > · One awardee per territory (county levels are suspected) > > · Awardee will gain exclusive USF subsidies fCoor each > territory > > · HOW DOES THAT PROMOTE COMPETITION? IMHO, this creates > Mini-monopolies in each service territory > > · It is anticipated that mobile broadband providers will be the > big > winners in this scenario > > o Other Programs > > § Modify Lifeline and Link-up programs to include broadband services > (use > only service that includes voice) > > § Enhance health care and E-Rate programs (increasing speeds up to 1 > Gbps) > > § Other potential enhancements via pilot programs > > · CPE and modem subsidies to end user cost and increase > adoption > > o Funding Shift > > § Stage 1 > > · Begin to phase out CETC support (estimated savings $3.9 > billion) > > § Stage 2 > > · Redirect remaining CETC support (estimated savings $5.8 > billion) > > o One provider will get support instead of multiple competitors in a > given > NGU > > o Redirect Interstate Access Support (estimated savings $4.0 billion) > > o Require Rate-of-Return carriers to move to incentive regulation > (estimated savings $0) > > § Price capping > > § Designed for Monopoly areas > > o Freeze Interstate Common Line Support (estimated savings $1.8 > billion) > > § Lines dropping 5-8%/year > > o Total Savings $15.5 billion > > § Savings refocused to CAF Program $11 billion > > § Mobility Fund-Erate and Switched Access $4 billion > > § Stage 3 > > · Eliminate remaining legacy programs > > o High cost loop > > o Funding Mechanism > > § "Broaden the USF contribution base to ensure USF remains sustainable > over > time" > > · Approach to be determined in Stage 1 > > · Implementation to begin in Stage 2 > > > > Proposed ICC Reform > > * Generalizations: > > * Switched Access is decreasing > * Special Access is increasing > > * Stage 1 > > * Interim access arbitrage solution > > * Stage 2 > > * Reduce intrastate terminating rates to interstate levels > * Reduce all originating and terminating access rates to reciprocal > compensation levels > * Eliminate all per minute ICC rates by 2020 > > * Allow for "alternate compensation arrangements" > * Increased SLC, local rate rebalancing and possible USF funding for > lost revenue > > > > Other NBP Recommendations > > * Wireless spectrum and data roaming > * Computer ownership > * Digital literacy > * Public Safety > * Smart Grid development > * Promote competition > > * Pricing and performance transparency > * Review wholesale competition rules > * Infrastructure & Rights-of-way rule modifications > * Set Top boxes > > > > Respectively and Join <http://signup.wispa.org/> WISPA Today, > > > > Rick Harnish > > President > > WISPA > > 260-307-4000 cell > > 866-317-2851 WISPA Office > > Skype: rick.harnish. > > rharn...@wispa.org > > > > > > ----------------------------------------------------------------------- > --------- > WISPA Wants You! 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