Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Fred Goldstein]

At 11/30/2012 03:26 PM, Brian Webster wrote:
>The rule as it stands now is 3 meg down and 768 up. The 4 meg down and 1 meg
>up was something put in the National Broadband Plan by the white house team.
>Problem with that is the National Broadband Map (of which was already spec'd
>out when they wrote that plan) uses download speed tier breakouts of 3 and 6
>meg and 768 and 1.5 meg. There will be no way to actually compute the 4 meg
>1 meg rule unless they change the national broadband map AND they get all
>carriers to revise their reporting. The rule is not really 4 meg and 1 meg
>either, it's an aggregate to 5 meg, you could be doing 3 meg down and 2 up
>and meet the standard. Remember that is currently just your advertised
>maximum download and upload speed. Not all of your customers have to
>subscribe to that. A WISP even using 900 MHz could limit those plans to say
>only 1 to 5% of the customers on an AP and technically still be within the
>rules.

Yes, the FCC and the mapping folks are out of sync. So the FCC 
proposal says that 4/1 would officially be the new speed *but* really 
it's just being on the map at 3/.768, since that's the closest map 
speed.  They call the map a lower speed "surrogate" for 4/1.

If you think that's a disconnect, just try to get the FCC's Wireline 
[prevention of] Competition Bureau to play nice with the Wireless 
Telecommunications Bureau.  Even Abe Lincoln would have trouble 
getting that team of rivals to work together.

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

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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Brian Webster]

A WISP could also offer these speeds and raise the price for this plan to
account for the total number of regular speed clients they might lose due to
capacity issues with the higher speed plan. Nowhere do the rules state that
you have to offer those speeds at any given price.

Thank You,
Brian Webster
www.wirelessmapping.com
www.Broadband-Mapping.com


-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Brian Webster
Sent: Friday, November 30, 2012 3:27 PM
To: 'WISPA General List'
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!

The rule as it stands now is 3 meg down and 768 up. The 4 meg down and 1 meg
up was something put in the National Broadband Plan by the white house team.
Problem with that is the National Broadband Map (of which was already spec'd
out when they wrote that plan) uses download speed tier breakouts of 3 and 6
meg and 768 and 1.5 meg. There will be no way to actually compute the 4 meg
1 meg rule unless they change the national broadband map AND they get all
carriers to revise their reporting. The rule is not really 4 meg and 1 meg
either, it's an aggregate to 5 meg, you could be doing 3 meg down and 2 up
and meet the standard. Remember that is currently just your advertised
maximum download and upload speed. Not all of your customers have to
subscribe to that. A WISP even using 900 MHz could limit those plans to say
only 1 to 5% of the customers on an AP and technically still be within the
rules.

Thank You,
Brian Webster
www.wirelessmapping.com
www.Broadband-Mapping.com


-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Fred Goldstein
Sent: Friday, November 30, 2012 11:59 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!

At 11/30/2012 11:45 AM, Matt wrote:
> > approach is used, you could comment that raising it from 768/200 to
> > 4/1 is excessive, and perhaps say a 1.5/384 standard is more 
> > appropriate.  Even Canopy 100 can probably claim that (if it's not
loaded), though YMMV.
>
>Are you saying no one is providing service past 1.5/384 with Canopy 100?

I'm referring to the 900 MHz version with a 4 Mbps one-way burst rate.  That
won't pass the 4/1 test.


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

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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Brian Webster]

The rule as it stands now is 3 meg down and 768 up. The 4 meg down and 1 meg
up was something put in the National Broadband Plan by the white house team.
Problem with that is the National Broadband Map (of which was already spec'd
out when they wrote that plan) uses download speed tier breakouts of 3 and 6
meg and 768 and 1.5 meg. There will be no way to actually compute the 4 meg
1 meg rule unless they change the national broadband map AND they get all
carriers to revise their reporting. The rule is not really 4 meg and 1 meg
either, it's an aggregate to 5 meg, you could be doing 3 meg down and 2 up
and meet the standard. Remember that is currently just your advertised
maximum download and upload speed. Not all of your customers have to
subscribe to that. A WISP even using 900 MHz could limit those plans to say
only 1 to 5% of the customers on an AP and technically still be within the
rules.

Thank You,
Brian Webster
www.wirelessmapping.com
www.Broadband-Mapping.com


-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Fred Goldstein
Sent: Friday, November 30, 2012 11:59 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!

At 11/30/2012 11:45 AM, Matt wrote:
> > approach is used, you could comment that raising it from 768/200 to 
> > 4/1 is excessive, and perhaps say a 1.5/384 standard is more 
> > appropriate.  Even Canopy 100 can probably claim that (if it's not
loaded), though YMMV.
>
>Are you saying no one is providing service past 1.5/384 with Canopy 100?

I'm referring to the 900 MHz version with a 4 Mbps one-way burst rate.  That
won't pass the 4/1 test.


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

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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Matt]

>> > approach is used, you could comment that raising it from 768/200 to 4/1 is
>> > excessive, and perhaps say a 1.5/384 standard is more appropriate.  Even
>> > Canopy 100 can probably claim that (if it's not loaded), though YMMV.
>>
>>Are you saying no one is providing service past 1.5/384 with Canopy 100?
>
> I'm referring to the 900 MHz version with a 4 Mbps one-way burst
> rate.  That won't pass the 4/1 test.

Ok, makes sense.  Wireless utility meter readers trashed most of 900
spectrum for us.
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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Fred Goldstein]

At 11/30/2012 11:45 AM, Matt wrote:
> > approach is used, you could comment that raising it from 768/200 to 4/1 is
> > excessive, and perhaps say a 1.5/384 standard is more appropriate.  Even
> > Canopy 100 can probably claim that (if it's not loaded), though YMMV.
>
>Are you saying no one is providing service past 1.5/384 with Canopy 100?

I'm referring to the 900 MHz version with a 4 Mbps one-way burst 
rate.  That won't pass the 4/1 test.


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

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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Doug Clark]

I assumed he meant that Canopy 900mHz can not provide speeds above that.   
 
 
 
 
---Original Message---
 
From: Matt
Date: 11/30/2012 9:46:04 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!
 
> approach is used, you could comment that raising it from 768/200 to 4/1 is
> excessive, and perhaps say a 1.5/384 standard is more appropriate.  Even
> Canopy 100 can probably claim that (if it's not loaded), though YMMV.
 
Are you saying no one is providing service past 1.5/384 with Canopy 100?
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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Matt]

> approach is used, you could comment that raising it from 768/200 to 4/1 is
> excessive, and perhaps say a 1.5/384 standard is more appropriate.  Even
> Canopy 100 can probably claim that (if it's not loaded), though YMMV.

Are you saying no one is providing service past 1.5/384 with Canopy 100?
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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Jeff Broadwick - Lists]

If you aren't on the map, you don't exist to the Feds...not a good situation to 
be in, in this regulatory climate.

Jeff

Sent from my iPhone

On Nov 30, 2012, at 11:09 AM, Fred Goldstein  wrote:

> At 11/30/2012 10:17 AM, Rick Harnish wrote:
>> Content-Type: multipart/alternative;
>>  boundary="=_NextPart_000_031F_01CDCEE3.F0FCA680"
>> Content-Language: en-us
>> 
>> I don’t think it is fruitless at all.  I’m sure there are a lot of companies 
>> (DSL, Satellite, Mobile and some cable) that are on the map but cannot 
>> guarantee sustained speeds of 4 by 1.  Actually, the 4 by 1 criteria is what 
>> is being suggested in the rewrite.  It has not been adopted yet.  
> 
> Satellite and mobile coverage are not considered "served" for the purposes of 
> finding a USF "unsubsidized competitor"; WISPs and wireline services are.
> 
> But Rick's last sentence is important:  This is a proposal, not yet a rule.  
> It is open for Comment.  They are trying to find a way to give away more USF 
> money, and disqualifying more unsubsidized competitors (WISPs) is one option 
> on the table.  Comments that take exception to that approach could help 
> influence them. 
> 
> The FNPRM proposes selecting between two alternative approaches.  One is to 
> raise the unsubsidized bar to 4/1.  The other is to end Phase I and put the 
> remaining money into Phase II, which comes later.  Certainly the latter 
> approach is better for WISPs in the short term.  If the extended Phase I 
> approach is used, you could comment that raising it from 768/200 to 4/1 is 
> excessive, and perhaps say a 1.5/384 standard is more appropriate.  Even 
> Canopy 100 can probably claim that (if it's not loaded), though YMMV.
> 
> So being on the map doesn't hurt and may help.
> 
>> From: wireless-boun...@wispa.org [ mailto:wireless-boun...@wispa.org] On 
>> Behalf Of Doug Clark
>> Sent: Friday, November 30, 2012 10:01 AM
>> To: WISPA General List
>> Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!
>> 
>>  
>> 
>> Correct me if I am wrong here Rick,  it will be fruitless to do the map 
>> unless you are able to maintain customer speeds of 4megs down and 1 meg up.  
>> If you service your customer at speeds lower
>> 
>> than that then it does not matter, the FCC will fund the Telcos...
>  --
>  Fred Goldsteink1io   fgoldstein "at" ionary.com   
>  ionary Consultinghttp://www.ionary.com/ 
>  +1 617 795 2701
> 
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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Doug Clark]

Excellent point. 
 
 
 
 
---Original Message---
 
From: Fred Goldstein
Date: 11/30/2012 9:10:00 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!
 
At 11/30/2012 10:17 AM, Rick Harnish wrote:

Content-Type: multipart/alternative;
 boundary="=_NextPart_000_031F_01CDCEE3.F0FCA680"
Content-Language: en-us

I don’t think it is fruitless at all.  I’m sure there are a lot of companies
(DSL, Satellite, Mobile and some cable) that are on the map but cannot
guarantee sustained speeds of 4 by 1.  Actually, the 4 by 1 criteria is what
is being suggested in the rewrite.  It has not been adopted yet.  


Satellite and mobile coverage are not considered "served" for the purposes
of finding a USF "unsubsidized competitor"; WISPs and wireline services are.

But Rick's last sentence is important:  This is a proposal, not yet a rule. 
It is open for Comment.  They are trying to find a way to give away more USF
money, and disqualifying more unsubsidized competitors (WISPs) is one option
on the table.  Comments that take exception to that approach could help
influence them. 

The FNPRM proposes selecting between two alternative approaches.  One is to
raise the unsubsidized bar to 4/1.  The other is to end Phase I and put the
remaining money into Phase II, which comes later.  Certainly the latter
approach is better for WISPs in the short term.  If the extended Phase I
approach is used, you could comment that raising it from 768/200 to 4/1 is
excessive, and perhaps say a 1.5/384 standard is more appropriate.  Even
Canopy 100 can probably claim that (if it's not loaded), though YMMV.

So being on the map doesn't hurt and may help.


From: wireless-boun...@wispa.org [ mailto:wireless-boun...@wispa.org] On
Behalf Of Doug Clark
Sent: Friday, November 30, 2012 10:01 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!

 

Correct me if I am wrong here Rick,  it will be fruitless to do the map
unless you are able to maintain customer speeds of 4megs down and 1 meg up. 
If you service your customer at speeds lower

than that then it does not matter, the FCC will fund the Telcos... 


 --
 Fred Goldsteink1io   fgoldstein "at" ionary.com   
 ionary Consultinghttp://www.ionary.com/ 
 +1 617 795 2701
 ___
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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Fred Goldstein]

At 11/30/2012 10:17 AM, Rick Harnish wrote:

Content-Type: multipart/alternative;
boundary="=_NextPart_000_031F_01CDCEE3.F0FCA680"
Content-Language: en-us

I don't think it is fruitless at all.  I'm sure there are a lot of 
companies (DSL, Satellite, Mobile and some cable) that are on the 
map but cannot guarantee sustained speeds of 4 by 1.  Actually, the 
4 by 1 criteria is what is being suggested in the rewrite.  It has 
not been adopted yet.


Satellite and mobile coverage are not considered "served" for the 
purposes of finding a USF "unsubsidized competitor"; WISPs and 
wireline services are.


But Rick's last sentence is important:  This is a proposal, not yet a 
rule.  It is open for Comment.  They are trying to find a way to give 
away more USF money, and disqualifying more unsubsidized competitors 
(WISPs) is one option on the table.  Comments that take exception to 
that approach could help influence them.


The FNPRM proposes selecting between two alternative approaches.  One 
is to raise the unsubsidized bar to 4/1.  The other is to end Phase I 
and put the remaining money into Phase II, which comes 
later.  Certainly the latter approach is better for WISPs in the 
short term.  If the extended Phase I approach is used, you could 
comment that raising it from 768/200 to 4/1 is excessive, and perhaps 
say a 1.5/384 standard is more appropriate.  Even Canopy 100 can 
probably claim that (if it's not loaded), though YMMV.


So being on the map doesn't hurt and may help.

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] 
On Behalf Of Doug Clark

Sent: Friday, November 30, 2012 10:01 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!



Correct me if I am wrong here Rick,  it will be fruitless to do the 
map unless you are able to maintain customer speeds of 4megs down 
and 1 meg up.  If you service your customer at speeds lower


than that then it does not matter, the FCC will fund the Telcos...



 --
 Fred Goldsteink1io   fgoldstein "at" ionary.com
 ionary Consulting  http://www.ionary.com/
 +1 617 795 2701 ___
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Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Doug Clark]

Correct me if I am wrong here Rick,  it will be fruitless to do the map
unless you are able to maintain customer speeds of 4megs down and 1 meg up. 
If you service your customer at speeds lower
than that then it does not matter, the FCC will fund the Telcos... 
 
 
 
 
~Doug
---Original Message---
 
From: Rick Harnish
Date: 11/29/2012 2:53:28 PM
To: 'WISPA General List'
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!
 
Are you on the Louisiana Broadband Map?
http://www.bakerbb.com/labroadbandmapping/
 
My contact in Louisiana is:
Mr. Craig Johnson
Louisiana State University
E313 Howe-Russell Geoscience Complex
Louisiana State University
Baton Rouge, LA 70803
cjohn...@lsu.edu
 
I do however see Michael Baker Group is the contractor. I suggest calling
them to find out who from their group is working on Louisiana.
 
Michael Baker Corporation
100 Airside Dr
Moon Township, PA 15108-2783
(800) 553-1153
 
Where there is a Wisp, there is a way!
 
Respectfully,
 
Rick Harnish
Executive Director
WISPA
260-307-4000 cell
866-317-2851 Option 2 WISPA Office
Skype: rick.harnish.
rharn...@wispa.org
adm...@wispa.org (Trina and Rick)
 
 
 
 
 
> -Original Message-
> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
> Behalf Of Cliff Leboeuf
> Sent: Thursday, November 29, 2012 4:01 PM
> To: WISPA General List
> Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!
>
> Rick, I thought that we did this task, but please tell me how I can
confirm. - Cliff
>
>
>
>
>
> On 11/28/12 4:45 PM, "Rick Harnish"  wrote:
>
> >Fred,
> >
> >I assure you the WISPA FCC Committee is indeed on this.  You make great
> >points and we appreciate your review. You are definitely correct, that
> >WISPs NEED to get on the National Broadband Map NOW!  Those that don't
> >will be suffering from subsidized competition.  Anyone who does not
> >know who to contact, drop me a line.  I have contacts now for all
> >states.  Maybe, I can get that list up on the WISPA website under WISP
> >Resources.  There is one now, but it is not complete.  I now have 4-5
> >names per state I believe.
> >
> >The guys at towercoverage.com are making it easy and inexpensive to
> >make your maps and get them uploaded to the National/State Maps as well.
> >
> >Where there is a Wisp, there is a way!
> >
> >Respectfully,
> >
> >Rick Harnish
> >Executive Director
> >WISPA
> >260-307-4000 cell
> >866-317-2851 Option 2 WISPA Office
> >Skype: rick.harnish.
> >rharn...@wispa.org
> >adm...@wispa.org (Trina and Rick)
> >
> >
> >
> >
> >
> >> -Original Message-
> >> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org]
> >> On Behalf Of Fred Goldstein
> >> Sent: Wednesday, November 28, 2012 5:17 PM
> >> To: wireless@wispa.org
> >> Subject: [WISPA] FCC Connect America Fund -- It's Bc!
> >>
> >> The FCC's home page ( transition.fcc.gov ) has an item about Connect
> >America
> >> Fund, posted with no description.  This turns out to be a further
> >> NPRM
> >about
> >> Phase I funding.
> >>
> >> As you may recall, CAF Phase I was the short-term (2012) step that
> >>offered
> >> $775 per line to price-cap ILECs (the Bells and other big
> >> ones) to bring "broadband" to "unserved" areas that they otherwise
> >wouldn't. It
> >> was budgeted for $300M but only about $115M was claimed, mostly by
> >> Frontier.  The Bells didn't take much.  CenturyLink however whined
> >> that
> >the
> >> definition of "served" should be changed to specifically exclude
> >> areas
> >WISPs, so
> >> they could get subsidy money to overbuild existing WISPs.  The FCC
> >>turned
> >that
> >> one down, though CenturyLink did take money for some other areas.
> >>
> >> The new Further Notice of Proposed Rulemaking:
> >>
> >http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC
> >-12
> >-
> >> 138A1.pdf
> >> asks what to do about the remaining Phase I money.  While they could
> >> of course just not spend it, lowering the USF tax (now around 17%!),
> >> that's
> >not one
> >> of the two options they are proposing to select from.  One option is
> >> to
> >simply
> >> add this funding to Phase II, which begins in 2013.  Phase II allows
> >>for  competition in the awarding of funds; there will be a reverse
> >&g

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Rick Harnish]

Are you on the Louisiana Broadband Map?
http://www.bakerbb.com/labroadbandmapping/

My contact in Louisiana is:
Mr. Craig Johnson
Louisiana State University
E313 Howe-Russell Geoscience Complex
Louisiana State University
Baton Rouge, LA 70803
cjohn...@lsu.edu

I do however see Michael Baker Group is the contractor. I suggest calling
them to find out who from their group is working on Louisiana.

Michael Baker Corporation
100 Airside Dr
Moon Township, PA 15108-2783
(800) 553-1153

Where there is a Wisp, there is a way!

Respectfully,

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





> -Original Message-
> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
> Behalf Of Cliff Leboeuf
> Sent: Thursday, November 29, 2012 4:01 PM
> To: WISPA General List
> Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!
> 
> Rick, I thought that we did this task, but please tell me how I can
confirm. - Cliff
> 
> 
> 
> 
> 
> On 11/28/12 4:45 PM, "Rick Harnish"  wrote:
> 
> >Fred,
> >
> >I assure you the WISPA FCC Committee is indeed on this.  You make great
> >points and we appreciate your review. You are definitely correct, that
> >WISPs NEED to get on the National Broadband Map NOW!  Those that don't
> >will be suffering from subsidized competition.  Anyone who does not
> >know who to contact, drop me a line.  I have contacts now for all
> >states.  Maybe, I can get that list up on the WISPA website under WISP
> >Resources.  There is one now, but it is not complete.  I now have 4-5
> >names per state I believe.
> >
> >The guys at towercoverage.com are making it easy and inexpensive to
> >make your maps and get them uploaded to the National/State Maps as well.
> >
> >Where there is a Wisp, there is a way!
> >
> >Respectfully,
> >
> >Rick Harnish
> >Executive Director
> >WISPA
> >260-307-4000 cell
> >866-317-2851 Option 2 WISPA Office
> >Skype: rick.harnish.
> >rharn...@wispa.org
> >adm...@wispa.org (Trina and Rick)
> >
> >
> >
> >
> >
> >> -Original Message-
> >> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org]
> >> On Behalf Of Fred Goldstein
> >> Sent: Wednesday, November 28, 2012 5:17 PM
> >> To: wireless@wispa.org
> >> Subject: [WISPA] FCC Connect America Fund -- It's Bc!
> >>
> >> The FCC's home page ( transition.fcc.gov ) has an item about Connect
> >America
> >> Fund, posted with no description.  This turns out to be a further
> >> NPRM
> >about
> >> Phase I funding.
> >>
> >> As you may recall, CAF Phase I was the short-term (2012) step that
> >>offered
> >> $775 per line to price-cap ILECs (the Bells and other big
> >> ones) to bring "broadband" to "unserved" areas that they otherwise
> >wouldn't. It
> >> was budgeted for $300M but only about $115M was claimed, mostly by
> >> Frontier.  The Bells didn't take much.  CenturyLink however whined
> >> that
> >the
> >> definition of "served" should be changed to specifically exclude
> >> areas
> >WISPs, so
> >> they could get subsidy money to overbuild existing WISPs.  The FCC
> >>turned
> >that
> >> one down, though CenturyLink did take money for some other areas.
> >>
> >> The new Further Notice of Proposed Rulemaking:
> >>
> >http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC
> >-12
> >-
> >> 138A1.pdf
> >> asks what to do about the remaining Phase I money.  While they could
> >> of course just not spend it, lowering the USF tax (now around 17%!),
> >> that's
> >not one
> >> of the two options they are proposing to select from.  One option is
> >> to
> >simply
> >> add this funding to Phase II, which begins in 2013.  Phase II allows
> >>for  competition in the awarding of funds; there will be a reverse
> >>auction, and
> >the
> >> bidder who asks for the least subsidy money gets it.
> >>
> >> Most of the FNPRM, however, is devoted to the other option,
> >>essentially a  second round of Phase I.  They propose changing Phase I
> >>rules to encourage
> >the
> >> ILECs to take more money.  There are a lot of questions about
> >>details, but
> >the
> >> basic ideas are along these line

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Cliff Leboeuf]

Rick, I thought that we did this task, but please tell me how I can
confirm. - Cliff





On 11/28/12 4:45 PM, "Rick Harnish"  wrote:

>Fred,
>
>I assure you the WISPA FCC Committee is indeed on this.  You make great
>points and we appreciate your review. You are definitely correct, that
>WISPs
>NEED to get on the National Broadband Map NOW!  Those that don't will be
>suffering from subsidized competition.  Anyone who does not know who to
>contact, drop me a line.  I have contacts now for all states.  Maybe, I
>can
>get that list up on the WISPA website under WISP Resources.  There is one
>now, but it is not complete.  I now have 4-5 names per state I believe.
>
>The guys at towercoverage.com are making it easy and inexpensive to make
>your maps and get them uploaded to the National/State Maps as well.
>
>Where there is a Wisp, there is a way!
>
>Respectfully,
>
>Rick Harnish
>Executive Director
>WISPA
>260-307-4000 cell
>866-317-2851 Option 2 WISPA Office
>Skype: rick.harnish.
>rharn...@wispa.org
>adm...@wispa.org (Trina and Rick)
>
>
>
>
>
>> -Original Message-
>> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
>> Behalf Of Fred Goldstein
>> Sent: Wednesday, November 28, 2012 5:17 PM
>> To: wireless@wispa.org
>> Subject: [WISPA] FCC Connect America Fund -- It's Bc!
>> 
>> The FCC's home page ( transition.fcc.gov ) has an item about Connect
>America
>> Fund, posted with no description.  This turns out to be a further NPRM
>about
>> Phase I funding.
>> 
>> As you may recall, CAF Phase I was the short-term (2012) step that
>>offered
>> $775 per line to price-cap ILECs (the Bells and other big
>> ones) to bring "broadband" to "unserved" areas that they otherwise
>wouldn't. It
>> was budgeted for $300M but only about $115M was claimed, mostly by
>> Frontier.  The Bells didn't take much.  CenturyLink however whined that
>the
>> definition of "served" should be changed to specifically exclude areas
>WISPs, so
>> they could get subsidy money to overbuild existing WISPs.  The FCC
>>turned
>that
>> one down, though CenturyLink did take money for some other areas.
>> 
>> The new Further Notice of Proposed Rulemaking:
>>
>http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12
>-
>> 138A1.pdf
>> asks what to do about the remaining Phase I money.  While they could of
>> course just not spend it, lowering the USF tax (now around 17%!), that's
>not one
>> of the two options they are proposing to select from.  One option is to
>simply
>> add this funding to Phase II, which begins in 2013.  Phase II allows for
>> competition in the awarding of funds; there will be a reverse auction,
>>and
>the
>> bidder who asks for the least subsidy money gets it.
>> 
>> Most of the FNPRM, however, is devoted to the other option, essentially
>>a
>> second round of Phase I.  They propose changing Phase I rules to
>>encourage
>the
>> ILECs to take more money.  There are a lot of questions about details,
>>but
>the
>> basic ideas are along these lines:
>> 
>> 1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service,
>>vs.
>> 768k/200k in the first round.  This would be based on the National
>Broadband
>> Map, using 3M/768k as a surrogate for 4/1.  (The agencies apparently
>hadn't
>> agreed on speed tiers.)  So an area served by a WISP at 2M/500k, or by
>Canopy
>> 100s, would be deemed "unserved", since it's not 4/1.
>> 
>> 2)  Allow challenges to the national map.  So if an ILEC thinks an area
>>is
>> unserved even if a WISP claims it's served, they can argue the matter to
>the
>> FCC.  This works both ways, so I suppose an ISP could claim that the map
>> omitted them by mistake.  But it points out that a WISP SHOULD MAKE SURE
>> ITS COVERAGE AREAS ARE ON THE MAP!  (Just a little shouting in case
>>anyone
>> didn't hear it.)
>> 
>> They are supposed to come out with a list of unserved areas (census
>> blocks0 next month.
>> 
>> There are some other interesting details.  Phase I awards are $775 per
>>new
>> customer.  That number may be adjusted in this second round.  Also, in
>areas
>> served by (rural, subsidized) Rate of Return Carriers, the subsidy
>>number
>comes
>> from the FCC's High Cost Proxy Model.  In Phase 2, these areas get
>subsidized
>> according to a more elaborate cost model now being de

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Brian Webster]

Rick,
It is important to note that generating a coverage map(s) on
Towercoverage.com does not create a map that is easily acceptable to the
state mapping agencies and it certainly cannot just be uploaded to the
national broadband map. There is a great deal of post processing work to
make any of those usable for the National Broadband map. The site does
export a nice list of tower sites and other data that is part of the
required information to be submitted. Some states may still not accept the
data from this site depending on the skills of their GIS and mapping
contractors. We do not want to mislead WISP's in to thinking that if they
sign up with that site that would all they need to do to supply mapping data
and participating on that site does not guarantee that their mapping data
will be included either.

Thank you,
Brian Webster
Telecom Project Coordinator
Partnership for Connected Illinois
(217) 886-4228 Main Number
(217) 886-4229 Direct Line
(217) 718-4546 Fax
http://www.BroadbandIllinois.org

-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Rick Harnish
Sent: Wednesday, November 28, 2012 5:45 PM
To: 'WISPA General List'
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!

Fred,

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

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

Where there is a Wisp, there is a way!

Respectfully,

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





> -Original Message-
> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] 
> On Behalf Of Fred Goldstein
> Sent: Wednesday, November 28, 2012 5:17 PM
> To: wireless@wispa.org
> Subject: [WISPA] FCC Connect America Fund -- It's Bc!
> 
> The FCC's home page ( transition.fcc.gov ) has an item about Connect
America
> Fund, posted with no description.  This turns out to be a further NPRM
about
> Phase I funding.
> 
> As you may recall, CAF Phase I was the short-term (2012) step that 
> offered
> $775 per line to price-cap ILECs (the Bells and other big
> ones) to bring "broadband" to "unserved" areas that they otherwise
wouldn't. It
> was budgeted for $300M but only about $115M was claimed, mostly by 
> Frontier.  The Bells didn't take much.  CenturyLink however whined 
> that
the
> definition of "served" should be changed to specifically exclude areas
WISPs, so
> they could get subsidy money to overbuild existing WISPs.  The FCC 
> turned
that
> one down, though CenturyLink did take money for some other areas.
> 
> The new Further Notice of Proposed Rulemaking:
>
http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-
> 138A1.pdf
> asks what to do about the remaining Phase I money.  While they could 
> of course just not spend it, lowering the USF tax (now around 17%!), 
> that's
not one
> of the two options they are proposing to select from.  One option is 
> to
simply
> add this funding to Phase II, which begins in 2013.  Phase II allows 
> for competition in the awarding of funds; there will be a reverse 
> auction, and
the
> bidder who asks for the least subsidy money gets it.
> 
> Most of the FNPRM, however, is devoted to the other option, 
> essentially a second round of Phase I.  They propose changing Phase I 
> rules to encourage
the
> ILECs to take more money.  There are a lot of questions about details, 
> but
the
> basic ideas are along these lines:
> 
> 1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service, vs.
> 768k/200k in the first round.  This would be based on the National
Broadband
> Map, using 3M/768k as a surrogate for 4/1.  (The agencies apparently
hadn't
> agreed on speed tiers.)  So an area served by a WISP at 2M/500k, or by
Canopy
> 100s, would be deemed "unserved", since it's not 4/1.
> 
> 2)  Allow challenges to the national map.  So if an ILEC thinks an 
> area is unserved even if a WISP claims it's served, they can argue the 
> matter to
the
> FCC.  This works both ways, so I suppose an ISP could claim t

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Fred Goldstein]

At 11/28/2012 05:56 PM, Blair Davis wrote:
For a one time payment of $775 per home, I can connect ALL the 
unconnected homes in my county...


But that is not how it works, is it?


Alas, Phase I is for incumbents only.

Phase II, when it happens next year, will allow others to bid.  This 
will probably not be a one-time capital subsidy (which is not how USF 
normally works) but the more routine monthly subsidy, which is 
typically used to pay off RUS loans.


Just who is eligible to bid on Phase is not determined yet.

I'll be buried in red tape and paper for the rest of my life, 
right?  And, of course, since I took their money, they can now tell 
me how to run my network and so on...


That would be a problem.  The rural ILECs who live on USF have staff 
or consultants to handle it for them.  It's their main business, 
after all; running the network is secondary.



I'd be happy if I can just block everyone else in my county from getting it.


If you're on the map with 3/.768, you're probably okay.  Those who 
are not on the map should follow Rich's advice; there are ways to 
make it fairly easy.




On 11/28/2012 5:16 PM, Fred Goldstein wrote:


The FCC's home page ( transition.fcc.gov ) has an item about Connect
America Fund, posted with no description.  This turns out to be a
further NPRM about Phase I funding.

As you may recall, CAF Phase I was the short-term (2012) step that
offered $775 per line to price-cap ILECs (the Bells and other big
ones) to bring "broadband" to "unserved" areas that they otherwise
wouldn't. It was budgeted for $300M but only about $115M was claimed,
mostly by Frontier.  The Bells didn't take much.  CenturyLink however
whined that the definition of "served" should be changed to
specifically exclude areas WISPs, so they could get subsidy money to
overbuild existing WISPs.  The FCC turned that one down, though
CenturyLink did take money for some other areas.

The new Further Notice of Proposed Rulemaking:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-138A1.pdf 


asks what to do about the remaining Phase I money.  While they could
of course just not spend it, lowering the USF tax (now around 17%!),
that's not one of the two options they are proposing to select
from.  One option is to simply add this funding to Phase II, which
begins in 2013.  Phase II allows for competition in the awarding of
funds; there will be a reverse auction, and the bidder who asks for
the least subsidy money gets it.

Most of the FNPRM, however, is devoted to the other option,
essentially a second round of Phase I.  They propose changing Phase I
rules to encourage the ILECs to take more money.  There are a lot of
questions about details, but the basic ideas are along these lines:

1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service,
vs. 768k/200k in the first round.  This would be based on the
National Broadband Map, using 3M/768k as a surrogate for 4/1.  (The
agencies apparently hadn't agreed on speed tiers.)  So an area served
by a WISP at 2M/500k, or by Canopy 100s, would be deemed "unserved",
since it's not 4/1.

2)  Allow challenges to the national map.  So if an ILEC thinks an
area is unserved even if a WISP claims it's served, they can argue
the matter to the FCC.  This works both ways, so I suppose an ISP
could claim that the map omitted them by mistake.  But it points out
that a WISP SHOULD MAKE SURE ITS COVERAGE AREAS ARE ON THE
MAP!  (Just a little shouting in case anyone didn't hear it.)

They are supposed to come out with a list of unserved areas (census
blocks0 next month.

There are some other interesting details.  Phase I awards are $775
per new customer.  That number may be adjusted in this second
round.  Also, in areas served by (rural, subsidized) Rate of Return
Carriers, the subsidy number comes from the FCC's High Cost Proxy
Model.  In Phase 2, these areas get subsidized according to a more
elaborate cost model now being debated.

There is also the possibility that the Phase I recipient may have to
build a certain amount of "second mile" (basically, exchange feeder
fiber) as well as "last mile" distribution.  But there's no clear
obligation to make this available at wholesale, which would be nice.
They also ask about how to handle builds that have to go through
served areas in order to reach unserved ones.  So even if you're on
the map, you could get overbuilt by the ILEC.

Note that a Phase I awardee must apply to serve specific unserved
areas and applies to serve a certain number of unserved subscribers,
*but* they do not actually have to use it where they said they
would.  The applications are merely suggestions of where they might
find their unserved customers.   They can actually spend it
elsewhere, so long as they get at least one customer added per $775.

An open question is that several awardees said that their proposed
service areas are conf

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Blair Davis]

  
  
For a one time payment of $775 per home, I can connect ALL the
unconnected homes in my county...

But that is not how it works, is it?

I'll be buried in red tape and paper for the rest of my life,
right?  And, of course, since I took their money, they can now tell
me how to run my network and so on...

I'd be happy if I can just block everyone else in my county from
getting it.

--


On 11/28/2012 5:16 PM, Fred Goldstein
  wrote:


  The FCC's home page ( transition.fcc.gov ) has an item about Connect 
America Fund, posted with no description.  This turns out to be a 
further NPRM about Phase I funding.

As you may recall, CAF Phase I was the short-term (2012) step that 
offered $775 per line to price-cap ILECs (the Bells and other big 
ones) to bring "broadband" to "unserved" areas that they otherwise 
wouldn't. It was budgeted for $300M but only about $115M was claimed, 
mostly by Frontier.  The Bells didn't take much.  CenturyLink however 
whined that the definition of "served" should be changed to 
specifically exclude areas WISPs, so they could get subsidy money to 
overbuild existing WISPs.  The FCC turned that one down, though 
CenturyLink did take money for some other areas.

The new Further Notice of Proposed Rulemaking:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-138A1.pdf 
asks what to do about the remaining Phase I money.  While they could 
of course just not spend it, lowering the USF tax (now around 17%!), 
that's not one of the two options they are proposing to select 
from.  One option is to simply add this funding to Phase II, which 
begins in 2013.  Phase II allows for competition in the awarding of 
funds; there will be a reverse auction, and the bidder who asks for 
the least subsidy money gets it.

Most of the FNPRM, however, is devoted to the other option, 
essentially a second round of Phase I.  They propose changing Phase I 
rules to encourage the ILECs to take more money.  There are a lot of 
questions about details, but the basic ideas are along these lines:

1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service, 
vs. 768k/200k in the first round.  This would be based on the 
National Broadband Map, using 3M/768k as a surrogate for 4/1.  (The 
agencies apparently hadn't agreed on speed tiers.)  So an area served 
by a WISP at 2M/500k, or by Canopy 100s, would be deemed "unserved", 
since it's not 4/1.

2)  Allow challenges to the national map.  So if an ILEC thinks an 
area is unserved even if a WISP claims it's served, they can argue 
the matter to the FCC.  This works both ways, so I suppose an ISP 
could claim that the map omitted them by mistake.  But it points out 
that a WISP SHOULD MAKE SURE ITS COVERAGE AREAS ARE ON THE 
MAP!  (Just a little shouting in case anyone didn't hear it.)

They are supposed to come out with a list of unserved areas (census 
blocks0 next month.

There are some other interesting details.  Phase I awards are $775 
per new customer.  That number may be adjusted in this second 
round.  Also, in areas served by (rural, subsidized) Rate of Return 
Carriers, the subsidy number comes from the FCC's High Cost Proxy 
Model.  In Phase 2, these areas get subsidized according to a more 
elaborate cost model now being debated.

There is also the possibility that the Phase I recipient may have to 
build a certain amount of "second mile" (basically, exchange feeder 
fiber) as well as "last mile" distribution.  But there's no clear 
obligation to make this available at wholesale, which would be nice. 
They also ask about how to handle builds that have to go through 
served areas in order to reach unserved ones.  So even if you're on 
the map, you could get overbuilt by the ILEC.

Note that a Phase I awardee must apply to serve specific unserved 
areas and applies to serve a certain number of unserved subscribers, 
*but* they do not actually have to use it where they said they 
would.  The applications are merely suggestions of where they might 
find their unserved customers.   They can actually spend it 
elsewhere, so long as they get at least one customer added per $775.

An open question is that several awardees said that their proposed 
service areas are confidential. The FCC has not decided if this is 
acceptable, so it's an open question now.  I'd think that a WISP 
should be allowed to know if the ILEC plans to build subsidized 
service to an area they're thinking of building to, so this should be 
public information, not confidential.  So tell the FCC!

I am hoping the FCC Committee and others interested will take note of 
this.  It probably won't reach the Federal Register for a while, and 
then the 30 day Comment period begins.

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

___
Wireless maili

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Mike Hammett]

Perhaps renewed efforts with the vendors?



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

- Original Message -
From: "Rick Harnish" 
To: "WISPA General List" 
Sent: Wednesday, November 28, 2012 4:45:15 PM
Subject: Re: [WISPA] FCC Connect America Fund -- It's Bc!

Fred,

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

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

Where there is a Wisp, there is a way!

Respectfully,

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





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

Re: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Rick Harnish]

Fred,

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

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

Where there is a Wisp, there is a way!

Respectfully,

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





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

[WISPA] FCC Connect America Fund -- It's Baaaackkkk!

[Fred Goldstein]

The FCC's home page ( transition.fcc.gov ) has an item about Connect 
America Fund, posted with no description.  This turns out to be a 
further NPRM about Phase I funding.

As you may recall, CAF Phase I was the short-term (2012) step that 
offered $775 per line to price-cap ILECs (the Bells and other big 
ones) to bring "broadband" to "unserved" areas that they otherwise 
wouldn't. It was budgeted for $300M but only about $115M was claimed, 
mostly by Frontier.  The Bells didn't take much.  CenturyLink however 
whined that the definition of "served" should be changed to 
specifically exclude areas WISPs, so they could get subsidy money to 
overbuild existing WISPs.  The FCC turned that one down, though 
CenturyLink did take money for some other areas.

The new Further Notice of Proposed Rulemaking:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-138A1.pdf
 
asks what to do about the remaining Phase I money.  While they could 
of course just not spend it, lowering the USF tax (now around 17%!), 
that's not one of the two options they are proposing to select 
from.  One option is to simply add this funding to Phase II, which 
begins in 2013.  Phase II allows for competition in the awarding of 
funds; there will be a reverse auction, and the bidder who asks for 
the least subsidy money gets it.

Most of the FNPRM, however, is devoted to the other option, 
essentially a second round of Phase I.  They propose changing Phase I 
rules to encourage the ILECs to take more money.  There are a lot of 
questions about details, but the basic ideas are along these lines:

1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service, 
vs. 768k/200k in the first round.  This would be based on the 
National Broadband Map, using 3M/768k as a surrogate for 4/1.  (The 
agencies apparently hadn't agreed on speed tiers.)  So an area served 
by a WISP at 2M/500k, or by Canopy 100s, would be deemed "unserved", 
since it's not 4/1.

2)  Allow challenges to the national map.  So if an ILEC thinks an 
area is unserved even if a WISP claims it's served, they can argue 
the matter to the FCC.  This works both ways, so I suppose an ISP 
could claim that the map omitted them by mistake.  But it points out 
that a WISP SHOULD MAKE SURE ITS COVERAGE AREAS ARE ON THE 
MAP!  (Just a little shouting in case anyone didn't hear it.)

They are supposed to come out with a list of unserved areas (census 
blocks0 next month.

There are some other interesting details.  Phase I awards are $775 
per new customer.  That number may be adjusted in this second 
round.  Also, in areas served by (rural, subsidized) Rate of Return 
Carriers, the subsidy number comes from the FCC's High Cost Proxy 
Model.  In Phase 2, these areas get subsidized according to a more 
elaborate cost model now being debated.

There is also the possibility that the Phase I recipient may have to 
build a certain amount of "second mile" (basically, exchange feeder 
fiber) as well as "last mile" distribution.  But there's no clear 
obligation to make this available at wholesale, which would be nice. 
They also ask about how to handle builds that have to go through 
served areas in order to reach unserved ones.  So even if you're on 
the map, you could get overbuilt by the ILEC.

Note that a Phase I awardee must apply to serve specific unserved 
areas and applies to serve a certain number of unserved subscribers, 
*but* they do not actually have to use it where they said they 
would.  The applications are merely suggestions of where they might 
find their unserved customers.   They can actually spend it 
elsewhere, so long as they get at least one customer added per $775.

An open question is that several awardees said that their proposed 
service areas are confidential. The FCC has not decided if this is 
acceptable, so it's an open question now.  I'd think that a WISP 
should be allowed to know if the ILEC plans to build subsidized 
service to an area they're thinking of building to, so this should be 
public information, not confidential.  So tell the FCC!

I am hoping the FCC Committee and others interested will take note of 
this.  It probably won't reach the Federal Register for a while, and 
then the 30 day Comment period begins.

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

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