Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
At 11/22/2011 11:53 AM, Sam Tetherow wrote: >Is there any provision in the document for reducing funding in the >future as areas get overbuilt? Or are we really looking at a 6-8month >land grab? Good question. I see two land grabs, actually, Phase 1 and 2, both in 2012, but potentially a few months apart. Otherwise, Phase 3 rules aren't firm yet. Once Phase 2 is awarded, it's there for five years. Phase 3 is likely to have another unsubsidized-competitor test around 2017. Probably to discuss in the FNPRM, which has a lot of questions I haven't all read yet. -- Fred Goldsteink1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
otential subs. I can >tell you from community connect grant research, looking at census data, it >was tough finding areas that gained maximum points of under 500 households. The Phase 1 and 2 subsidies will be based on Census Blocks. That's the smallest geographic area that the federal government knows about or has maps of. So if you can cover all of a block, you put it on the map, and subscribers there cannot be counted towards CAF subsidies. Now when auction time comes, AFAIK the size of each area to be auctioned has yet to be determined.. And for Rate of Return carriers, the rules will differ, and don't seem firm yet, so census blocks might not be the protected level. You might need a much bigger footprint. >Did it say anything in the rules, to define what an eligible size "area" is? >Both for identifying served and unserved, not just USF qualification? > >Wondering if NTIA/USDA is going to help identify preferred qualifying area >on the broadband map? I dont think it will be as simple as looking for >blank spots. >IS there currently a map of ILEC coverage area of Voice, that can be >overlaid to the broadband map? A few states do have it, but in general, ILEC coverage maps are not publicly available in GIS format. They are however always included in baseline tariffs. To be sure, the tariff maps you can find are usually n-th generation photocopies of hand-tool-drawn maps from the 1940s or so, and illegible, but they're official. And there are (expensive) commercial GIS layers showing each ILEC wire center's coverage boundary. But this also ties in to Carrier of Last Resort obligations. ILECs have state COLR obligations in most states, which is covered by their open-ended (monopoly/USF) finance model. An open question now is what happens to COLR if they lose their USF. Does CAF come with COLR? >A question likely to develop for WISPs is What are the safest places to >invest in expanding coverage, meaning less likely to get overbuilt with >subsidized competition? >The very Suburban/Urban and very Rural are becomming most likely for >subsidee and harsh competition. Some where in the middle, such as barely >rural, may be safer? > I'm not done with the rules yet, but offhand my guess is the safest place is one served by a Price Cap Carrier (not a small rural telco) that is far from their major focus (cities). But then the question is not really relevant for a lot of WISPs and local ISPs and CLECs. We serve the areas we serve because that's our business. It's finance capital that looks for cream areas to skim. Locals need to be able to operate anywhere. And that's a problem with some of the FCC rules, which assume that the operator is really mobile finance capital that will operate where it's most profitable, and to hell with potential customers in harder-to-serve areas. These new rules are less evil in that regard than some others from the past decade, though -- they at least made some effort to balance it a little. >- Original Message - >From: "Fred Goldstein" >To: "WISPA General List" >Sent: Monday, November 21, 2011 9:08 PM >Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > > > > At 11/21/2011 08:04 PM, you wrote: > >>Yes agreed, its not nearly as bad as it could have been. But I still say > >>ARRGGG! > >> > >> > Price Cap Carriers will be offered $775 per > >> > line to add 4/1 broadband serivce to "unserved" areas > >> > >>Thats much better for WISPs than if they agreed to pay our competitors > >>greater than $10,000 per sub for FIOS like Fiber. > >>WISPs atleast have a chance to compete against 4/1 services, and ILEC > >>reimbursement now inline with what it would cost a WISP to deploy, and not > >>to much more.. > > > > Note that this is "incremental" $775, a subsidy to add to their > > capital budget, not the total investment. Of course big ILECs tend > > to be wasteful spenders. > > > >> > So this might be a good time to make sure the mappers > >> > are aware of your service areas, or to think about short-term service > >> > expansion. > >> > >>yeah, you gotta love help that says "WISPs Go hurry up and build a > >>network at your cost quickly, we wont pay you, but if you dont build > >>quick, > >>we'll pay your competitor instead." > >>(Sarcasm) > >> > >> > The date by which you must be on the map isn't set yet, > >> > but it's presumably in 1H2012. > >> > >>Well, that is good, that they are looking at mapping for disqualification. >
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
ll be to see if, the RBOC fund recipients > really do what they are obligated to do afterwords. > > I think it is an ambitious plan to try to get the remaining American's some > form of broadband, which outcome would likely be good, I just cant say I > agree with the method. > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > - Original Message - > From: "Fred R. Goldstein" > To: "WISPA General List" > Sent: Monday, November 21, 2011 6:02 PM > Subject: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > > >> On Friday, the FCC finally released the Order in their Intercarrier >> Compensation and Universal Service Fund docket. The executive >> summary had come out with the Adoption at last month's FCC Public >> Meeting, but the 759-page (!) Order took a while to finish. >> >> The results, from a WISP perspective, are not nearly as bad as could >> have been. The FCC has taken safeguards to make it easier for an >> unsubsidized WISP to prevent subsidized competition from an incumbent LEC. >> >> The high-cost portions of the Universal Service Fund are being >> restructured into the Connect America Fund. This will come into >> being in three phases, each with different rules for Price Cap >> Carriers and Rate of Return Carriers. About 95% of phone lines are >> in the former category; the latter are basically small rural carriers >> who depend upon USF. >> >> Phase I is just 2012. Price Cap Carriers will be offered $775 per >> line to add 4/1 broadband serivce to "unserved" areas that they >> weren't otherwise going to serve. They can choose how many lines >> this applies to. If the location is "served" on the National >> Broadband Map, or if the ILEC *knows* it's served by an unsubsidized >> competitor, it's off limits. I think this must be at least 768k >> fixed service. So this might be a good time to make sure the mappers >> are aware of your service areas, or to think about short-term service >> expansion. The date by which you must be on the map isn't set yet, >> but it's presumably in 1H2012. >> >> Phase II starts in 2013. For this, Price Cap Carriers will be >> offered support based on a cost model that the FCC will create in >> 2012. Once the model is complete, the ILEC will decide if it wants >> to take that support for its territory on a state-by-state (all of a >> state or nothing) basis. Again, only unserved areas will get >> support, though an ILEC can use support to build common plant in an >> area that is more than 50% unserved. So a new DSLAM that covers 40% >> unserved would not be covered, but ont that covers 60% unserved would >> be. So again it's important for WISPs to make their presence >> known. If the ILEC turns down the state, USF support goes to the low >> bidder. >> >> Phase III starts in 2018, and will be entirely bid-based, but the >> details will be worked out in the future. >> >> A separate Extremely High Cost fund will allocate up to $100M/year >> for locations too costly (by the model) to serve via the standard >> subsidy. This will be separately bid, and it's assumed that fixed >> wireless and satellite will be the mostly likely technologies. So >> this could allow some subsidies to rustic-but-Bell-area WISPs. >> >> The FCC notes that while this gives ILECs first dibs on funding, it >> also takes away Price Cap Carrier USF from areas served by >> unsubsidized competitors, so WISPs could theoretically come out >> better under the new rules. >> >> Now here's a catch: "Unsubsidized competitor" is defined as a >> provider of both voice and broadband service. It's not entirely >> obvious (you try parsing 759 pages of FCC-speak this quickly... ;-) ) >> if that applies to the Price Cap Carrier model, or just the rural >> Rate of Return case, since the PCCs already offer unsubsidized voice >> across most of their territories, and the map isn't about voice. In >> the rural Rate of Return Carrier case, voice will be more >> important. This does not mean that the WISP must be a CLEC per se; >> it might be high-quality (QoS) VoIP offered in conjunction with a >> CLEC who has local numbers, for instance. But for some ISPs, this >> might be a good time to start thinking about adding voice >> service. (My talk at FISPA last month was about the case for whether >> an ISP should start up a CLEC.) >> >> In areas served by rate-of-return carriers, th
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
> The FCC just had to have a date, and was nice enough to not close it > too early. This also gives WISPs time to do some more construction > and have it included. > Thats one way to look at it. (And probably the more productive way, recognizing the timeline to protect opportunity.) > The whole-state rule applies to the big ILECs. If they say no, the > rules for the auction aren't written yet, and may work on a smaller > basis. I think that's one of the things to discuss in the FNPRM > Comments, which are due 24 January. But why would big ILEC's say, "no" ? Isn't this process pressuring the ILECs to say "yes". Giving the ILECs a second chance to get another free ride, now for broadband? If ILEC took subsidee for Voice in past, why would they not do the same for Data? Small ILECs might say no, because they might not have the funding or resources to take on a super large project even with subsidee. But Big Telco surely has the finances. We can use ATT as an example, who is advertising to cover all of America in 5 years, anyway. Do you think there is any chance that the big telco might say "no" in some states, I dont want USF? It has happened in the past, to some extent. I can give the example of Verizon pulling out of a low profit analog market, and letting a smaller LEC take over such as either Century tel or Frontier (forget which LEC, and which Eastern state).. Back then it made sense with Verizon focusing on FIOS preferring to bypass regulation, that FIOS allowed them. But would that same justification still be there, when USF subsidees are there to compensate? > If the location is "served" on the National > Broadband Map, or if the ILEC *knows* it's served by an unsubsidized > competitor, it's off limits .. > Again, only unserved areas will get > support, though an ILEC can use support to build common plant in an > area that is more than 50% unserved. Also, regarding those to comments in your original Email... I think the risk here is the same that it was with ARRA. Whats the definition of "unserved", and but more importantly what is the definition of "area", and what is the protest proof process, and is WISP's coverage large enough to qualify an area as served? And will gerrymandering allow a recipient to get around it? Obviously, the National MAP, that documents all reported coverage from all carriers will help quite a bit. But I'm still concerned that many WISP's coverage will be to small of a take rate or area, to be proportional enough to mark an area as "served". I can tell you that in my rural markets, it would be near impossible to get over 50% coverage, even if I served everyhome that I had coverage to. Lets use a hypothetical example of the average member WISP having 1000 subs. There are not many areas that have less than 2000 potential subs. I can tell you from community connect grant research, looking at census data, it was tough finding areas that gained maximum points of under 500 households. Did it say anything in the rules, to define what an eligible size "area" is? Both for identifying served and unserved, not just USF qualification? Wondering if NTIA/USDA is going to help identify preferred qualifying area on the broadband map? I dont think it will be as simple as looking for blank spots. IS there currently a map of ILEC coverage area of Voice, that can be overlaid to the broadband map? A question likely to develop for WISPs is What are the safest places to invest in expanding coverage, meaning less likely to get overbuilt with subsidized competition? The very Suburban/Urban and very Rural are becomming most likely for subsidee and harsh competition. Some where in the middle, such as barely rural, may be safer? Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband ----- Original Message - From: "Fred Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 9:08 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > At 11/21/2011 08:04 PM, you wrote: >>Yes agreed, its not nearly as bad as it could have been. But I still say >>ARRGGG! >> >> > Price Cap Carriers will be offered $775 per >> > line to add 4/1 broadband serivce to "unserved" areas >> >>Thats much better for WISPs than if they agreed to pay our competitors >>greater than $10,000 per sub for FIOS like Fiber. >>WISPs atleast have a chance to compete against 4/1 services, and ILEC >>reimbursement now inline with what it would cost a WISP to deploy, and not >>to much more.. > > Note that this is "incremental" $775, a subsidy to add to their > capital budget, not the total investment. Of course big ILECs tend >
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
Scottie, I have the same issue here in Indiana with one exchange in particular. I have been in contact with the Indiana Utility Regulatory Committee. They are in process of helping us. They could not understand why we could port and have access to all other exchanges in the same rate center but not that one. Steve Barnes General Manager PCS-WIN / RC-WiFi -Original Message- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Scottie Arnett Sent: Tuesday, November 22, 2011 12:58 AM To: WISPA General List Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs We just happen to fall into one of those 3.65Ghz protected areas! But I have heard that the local telco has something going on there too! Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Fred Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 10:38 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > At 11/21/2011 11:18 PM, Scottie Arnett wrote: >>Re-reading your posts brings me to another question.has any VOIP >>carriers ever used cellular carriers numbers? Is it even possible? > > First, wrt the Livingston exchange, 931-397 and 931-403 belong to US > Cellular; the latter is pooled (they're using the 7's). Nextel has > -871, pooled (using 6 and 7). Oddly, US Cellular but not S-N says it > subtends a Gaineborough tandem, which is Twin Lakes, but most Twin > Lakes exchanges subtend Nashville. > > As to VoIP via cellular numbers, well, its sort of odd, but it might > be possible. The new rules may actually say something about this -- > there was a VoIP company affiliated with a wireless company that was, > uh, alleged to have been laundering its LD calls via the cellular > company in order to get the lower termination rates. They deny it of > course... but that may have been addressed in the intercarrier > rules. I haven't gotten through it all yet. (It's freakin' huge.) I > actually had a client that was a wireless company whose business > included lots and lots of modems, way back when, so it's not > unprecedented to have, uh, "incidental" non-wireless traffic go > through a wirless feed. And heck, put up one 3.65 GHz base station > (if it's allowed there) and declare it "CMRS", and you're a cellco too! > > There's one lawyer I know who sort of specializes in this sort of thing. > >>Scottie Arnett >>President >>Info-Ed, Inc. >>Electronics and More >>931-243-2101 >>sarn...@info-ed.com >>- Original Message - >>From: "Scottie Arnett" >>To: "WISPA General List" >>Sent: Monday, November 21, 2011 10:14 PM >>Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing >>ILECs >> >> >> > Please explain about the Livingston exchange!!! I have been trying to >> > break >> > this barrier for almost 12 years. >> > >> > Scottie Arnett >> > President >> > Info-Ed, Inc. >> > Electronics and More >> > 931-243-2101 >> > sarn...@info-ed.com >> > - Original Message - >> > From: "Fred Goldstein" >> > To: "WISPA General List" >> > Sent: Monday, November 21, 2011 9:08 PM >> > Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing >> > ILECs >> > >> > >> >> At 11/21/2011 09:29 PM, you wrote: >> >>>The only other "telcos/cellcos" here that have local numbers are US >> >>>Cellular >> >>>and Verizon. None of the big VOIP carriers do, such as >> >>>Vonage/Packet8/take >> >>>your pick. They have NO Clec's here either. >> >> >> >> I like to think of that as a challenge. ;-) The good news is that >> >> they use the Nashville tandem, not their own, so the traffic exchange >> >> can be indirect. >> >> >> >> But it's true that there are no CLECs with numbers in TLTC's >> >> area. Powertel, US Cellular, VZW and Sprint Nextel are the only >> >> other carriers there, all mobile. No Celina numbers, either, if it >> >> matters. But Livingston has pooled prefix codes available. >> >> >> >> >> >> -- >> >> Fred Goldsteink1io fgoldstein "at" ionary.com >> >> ionary Consulting http://www.ionary.com/ >> >> +1 617 795 2701 >> >> >> >> >> >> &
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
We just happen to fall into one of those 3.65Ghz protected areas! But I have heard that the local telco has something going on there too! Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Fred Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 10:38 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > At 11/21/2011 11:18 PM, Scottie Arnett wrote: >>Re-reading your posts brings me to another question.has any VOIP >>carriers ever used cellular carriers numbers? Is it even possible? > > First, wrt the Livingston exchange, 931-397 and 931-403 belong to US > Cellular; the latter is pooled (they're using the 7's). Nextel has > -871, pooled (using 6 and 7). Oddly, US Cellular but not S-N says it > subtends a Gaineborough tandem, which is Twin Lakes, but most Twin > Lakes exchanges subtend Nashville. > > As to VoIP via cellular numbers, well, its sort of odd, but it might > be possible. The new rules may actually say something about this -- > there was a VoIP company affiliated with a wireless company that was, > uh, alleged to have been laundering its LD calls via the cellular > company in order to get the lower termination rates. They deny it of > course... but that may have been addressed in the intercarrier > rules. I haven't gotten through it all yet. (It's freakin' huge.) I > actually had a client that was a wireless company whose business > included lots and lots of modems, way back when, so it's not > unprecedented to have, uh, "incidental" non-wireless traffic go > through a wirless feed. And heck, put up one 3.65 GHz base station > (if it's allowed there) and declare it "CMRS", and you're a cellco too! > > There's one lawyer I know who sort of specializes in this sort of thing. > >>Scottie Arnett >>President >>Info-Ed, Inc. >>Electronics and More >>931-243-2101 >>sarn...@info-ed.com >>- Original Message - >>From: "Scottie Arnett" >>To: "WISPA General List" >>Sent: Monday, November 21, 2011 10:14 PM >>Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing >>ILECs >> >> >> > Please explain about the Livingston exchange!!! I have been trying to >> > break >> > this barrier for almost 12 years. >> > >> > Scottie Arnett >> > President >> > Info-Ed, Inc. >> > Electronics and More >> > 931-243-2101 >> > sarn...@info-ed.com >> > - Original Message - >> > From: "Fred Goldstein" >> > To: "WISPA General List" >> > Sent: Monday, November 21, 2011 9:08 PM >> > Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing >> > ILECs >> > >> > >> >> At 11/21/2011 09:29 PM, you wrote: >> >>>The only other "telcos/cellcos" here that have local numbers are US >> >>>Cellular >> >>>and Verizon. None of the big VOIP carriers do, such as >> >>>Vonage/Packet8/take >> >>>your pick. They have NO Clec's here either. >> >> >> >> I like to think of that as a challenge. ;-) The good news is that >> >> they use the Nashville tandem, not their own, so the traffic exchange >> >> can be indirect. >> >> >> >> But it's true that there are no CLECs with numbers in TLTC's >> >> area. Powertel, US Cellular, VZW and Sprint Nextel are the only >> >> other carriers there, all mobile. No Celina numbers, either, if it >> >> matters. But Livingston has pooled prefix codes available. >> >> >> >> >> >> -- >> >> Fred Goldsteink1io fgoldstein "at" ionary.com >> >> ionary Consulting http://www.ionary.com/ >> >> +1 617 795 2701 >> >> >> >> >> >> >> >> >> >> >> WISPA Wants You! Join today! >> >> http://signup.wispa.org/ >> >> >> >> >> >> >> WISPA Wireless List: wireless@wispa.org >> >> >> >> Subscribe/Unsubscribe: >> >> http://lists.wispa.org/mailman/listinfo/wireless >> >> >> >> Archives: http://lists.wispa.org/pipermail/wireless/ >> > >>
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
At 11/21/2011 11:18 PM, Scottie Arnett wrote: >Re-reading your posts brings me to another question.has any VOIP >carriers ever used cellular carriers numbers? Is it even possible? First, wrt the Livingston exchange, 931-397 and 931-403 belong to US Cellular; the latter is pooled (they're using the 7's). Nextel has -871, pooled (using 6 and 7). Oddly, US Cellular but not S-N says it subtends a Gaineborough tandem, which is Twin Lakes, but most Twin Lakes exchanges subtend Nashville. As to VoIP via cellular numbers, well, its sort of odd, but it might be possible. The new rules may actually say something about this -- there was a VoIP company affiliated with a wireless company that was, uh, alleged to have been laundering its LD calls via the cellular company in order to get the lower termination rates. They deny it of course... but that may have been addressed in the intercarrier rules. I haven't gotten through it all yet. (It's freakin' huge.) I actually had a client that was a wireless company whose business included lots and lots of modems, way back when, so it's not unprecedented to have, uh, "incidental" non-wireless traffic go through a wirless feed. And heck, put up one 3.65 GHz base station (if it's allowed there) and declare it "CMRS", and you're a cellco too! There's one lawyer I know who sort of specializes in this sort of thing. >Scottie Arnett >President >Info-Ed, Inc. >Electronics and More >931-243-2101 >sarn...@info-ed.com >- Original Message - >From: "Scottie Arnett" >To: "WISPA General List" >Sent: Monday, November 21, 2011 10:14 PM >Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > > > > Please explain about the Livingston exchange!!! I have been trying to > > break > > this barrier for almost 12 years. > > > > Scottie Arnett > > President > > Info-Ed, Inc. > > Electronics and More > > 931-243-2101 > > sarn...@info-ed.com > > - Original Message - > > From: "Fred Goldstein" > > To: "WISPA General List" > > Sent: Monday, November 21, 2011 9:08 PM > > Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing > > ILECs > > > > > >> At 11/21/2011 09:29 PM, you wrote: > >>>The only other "telcos/cellcos" here that have local numbers are US > >>>Cellular > >>>and Verizon. None of the big VOIP carriers do, such as > >>>Vonage/Packet8/take > >>>your pick. They have NO Clec's here either. > >> > >> I like to think of that as a challenge. ;-) The good news is that > >> they use the Nashville tandem, not their own, so the traffic exchange > >> can be indirect. > >> > >> But it's true that there are no CLECs with numbers in TLTC's > >> area. Powertel, US Cellular, VZW and Sprint Nextel are the only > >> other carriers there, all mobile. No Celina numbers, either, if it > >> matters. But Livingston has pooled prefix codes available. > >> > >> > >> -- > >> Fred Goldsteink1io fgoldstein "at" ionary.com > >> ionary Consulting http://www.ionary.com/ > >> +1 617 795 2701 > >> > >> > >> > >> > > >> WISPA Wants You! Join today! > >> http://signup.wispa.org/ > >> > > >> > >> WISPA Wireless List: wireless@wispa.org > >> > >> Subscribe/Unsubscribe: > >> http://lists.wispa.org/mailman/listinfo/wireless > >> > >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > > > > > > > WISPA Wants You! Join today! > > http://signup.wispa.org/ > > > > > > > WISPA Wireless List: wireless@wispa.org > > > > Subscribe/Unsubscribe: > > http://lists.wispa.org/mailman/listinfo/wireless > > > > Archives: http://lists.wispa.org/pipermail/wireless/ > > > > >WISPA Wants You! Join today! >http://signup.wispa.org/ > > >WISPA Wireless List: wireless@wispa.org > >Subscribe/Unsubscribe: >http://lists.wispa.org/mailman/listinfo/wireless > >Archives: http://lists.wispa.org/pipermail/wireless/ -- Fred Goldsteink1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
Re-reading your posts brings me to another question.has any VOIP carriers ever used cellular carriers numbers? Is it even possible? Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Scottie Arnett" To: "WISPA General List" Sent: Monday, November 21, 2011 10:14 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > Please explain about the Livingston exchange!!! I have been trying to > break > this barrier for almost 12 years. > > Scottie Arnett > President > Info-Ed, Inc. > Electronics and More > 931-243-2101 > sarn...@info-ed.com > - Original Message - > From: "Fred Goldstein" > To: "WISPA General List" > Sent: Monday, November 21, 2011 9:08 PM > Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing > ILECs > > >> At 11/21/2011 09:29 PM, you wrote: >>>The only other "telcos/cellcos" here that have local numbers are US >>>Cellular >>>and Verizon. None of the big VOIP carriers do, such as >>>Vonage/Packet8/take >>>your pick. They have NO Clec's here either. >> >> I like to think of that as a challenge. ;-) The good news is that >> they use the Nashville tandem, not their own, so the traffic exchange >> can be indirect. >> >> But it's true that there are no CLECs with numbers in TLTC's >> area. Powertel, US Cellular, VZW and Sprint Nextel are the only >> other carriers there, all mobile. No Celina numbers, either, if it >> matters. But Livingston has pooled prefix codes available. >> >> >> -- >> Fred Goldsteink1io fgoldstein "at" ionary.com >> ionary Consulting http://www.ionary.com/ >> +1 617 795 2701 >> >> >> >> >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
Please explain about the Livingston exchange!!! I have been trying to break this barrier for almost 12 years. Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Fred Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 9:08 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > At 11/21/2011 09:29 PM, you wrote: >>The only other "telcos/cellcos" here that have local numbers are US >>Cellular >>and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take >>your pick. They have NO Clec's here either. > > I like to think of that as a challenge. ;-) The good news is that > they use the Nashville tandem, not their own, so the traffic exchange > can be indirect. > > But it's true that there are no CLECs with numbers in TLTC's > area. Powertel, US Cellular, VZW and Sprint Nextel are the only > other carriers there, all mobile. No Celina numbers, either, if it > matters. But Livingston has pooled prefix codes available. > > > -- > Fred Goldsteink1io fgoldstein "at" ionary.com > ionary Consulting http://www.ionary.com/ > +1 617 795 2701 > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
TN is FULLL of cooperatives. From what I have found, the state of TN likes to protect them too. Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Mike Hammett" To: "WISPA General List" Sent: Monday, November 21, 2011 8:42 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > http://www.localcallingguide.com/lca_switch.php?tandem=NSVNTNGN00T > > Looks like all RLECs, but maybe you'd have luck with one of them. > > - > Mike Hammett > Intelligent Computing Solutions > http://www.ics-il.com > > > > On 11/21/2011 8:29 PM, Scottie Arnett wrote: >> The only other "telcos/cellcos" here that have local numbers are US >> Cellular >> and Verizon. None of the big VOIP carriers do, such as >> Vonage/Packet8/take >> your pick. They have NO Clec's here either. >> >> Scottie Arnett >> President >> Info-Ed, Inc. >> Electronics and More >> 931-243-2101 >> sarn...@info-ed.com >> - Original Message - >> From: "Fred Goldstein" >> To: "WISPA General List" >> Sent: Monday, November 21, 2011 8:01 PM >> Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing >> ILECs >> >> >>> At 11/21/2011 07:50 PM, Scottie Arnett wrote: >>>> How can you offer voice if you can not get local phone number's because >>>> of >>>> a >>>> rural telephone cooperative? >>> I don't believe a rural cooperative can prevent you from pulling >>> numbers from the NANPA. They are even required to interconnect with >>> you for the exchange of traffic which, under the new rules, will >>> *eventually* (like 9 years out) be at bilk-and-keep. You might >>> however have to interconnect indirectly, via a third-party tandem, >>> and there's some issue of recourse if they block calls to you. They >>> are not required to lease you any network elements. And they don't >>> like to be, well, too cooperative... but I'd first want to check >>> with the lawyers to know exactly how much privilege an RTC still has. >>> >>> >>> >>> -- >>> Fred Goldsteink1io fgoldstein "at" ionary.com >>> ionary Consulting http://www.ionary.com/ >>> +1 617 795 2701 >>> >>> >>> >>> >>> WISPA Wants You! Join today! >>> http://signup.wispa.org/ >>> >>> >>> WISPA Wireless List: wireless@wispa.org >>> >>> Subscribe/Unsubscribe: >>> http://lists.wispa.org/mailman/listinfo/wireless >>> >>> Archives: http://lists.wispa.org/pipermail/wireless/ >> >> >> >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
At 11/21/2011 09:29 PM, you wrote: >The only other "telcos/cellcos" here that have local numbers are US Cellular >and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take >your pick. They have NO Clec's here either. I like to think of that as a challenge. ;-) The good news is that they use the Nashville tandem, not their own, so the traffic exchange can be indirect. But it's true that there are no CLECs with numbers in TLTC's area. Powertel, US Cellular, VZW and Sprint Nextel are the only other carriers there, all mobile. No Celina numbers, either, if it matters. But Livingston has pooled prefix codes available. -- Fred Goldsteink1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
http://www.localcallingguide.com/lca_switch.php?tandem=NSVNTNGN00T Looks like all RLECs, but maybe you'd have luck with one of them. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com On 11/21/2011 8:29 PM, Scottie Arnett wrote: > The only other "telcos/cellcos" here that have local numbers are US Cellular > and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take > your pick. They have NO Clec's here either. > > Scottie Arnett > President > Info-Ed, Inc. > Electronics and More > 931-243-2101 > sarn...@info-ed.com > - Original Message - > From: "Fred Goldstein" > To: "WISPA General List" > Sent: Monday, November 21, 2011 8:01 PM > Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > > >> At 11/21/2011 07:50 PM, Scottie Arnett wrote: >>> How can you offer voice if you can not get local phone number's because of >>> a >>> rural telephone cooperative? >> I don't believe a rural cooperative can prevent you from pulling >> numbers from the NANPA. They are even required to interconnect with >> you for the exchange of traffic which, under the new rules, will >> *eventually* (like 9 years out) be at bilk-and-keep. You might >> however have to interconnect indirectly, via a third-party tandem, >> and there's some issue of recourse if they block calls to you. They >> are not required to lease you any network elements. And they don't >> like to be, well, too cooperative... but I'd first want to check >> with the lawyers to know exactly how much privilege an RTC still has. >> >> >> >> -- >> Fred Goldsteink1io fgoldstein "at" ionary.com >> ionary Consulting http://www.ionary.com/ >> +1 617 795 2701 >> >> >> >> >> WISPA Wants You! Join today! >> http://signup.wispa.org/ >> >> >> WISPA Wireless List: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
The only other "telcos/cellcos" here that have local numbers are US Cellular and Verizon. None of the big VOIP carriers do, such as Vonage/Packet8/take your pick. They have NO Clec's here either. Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Fred Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 8:01 PM Subject: Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > At 11/21/2011 07:50 PM, Scottie Arnett wrote: >>How can you offer voice if you can not get local phone number's because of >>a >>rural telephone cooperative? > > I don't believe a rural cooperative can prevent you from pulling > numbers from the NANPA. They are even required to interconnect with > you for the exchange of traffic which, under the new rules, will > *eventually* (like 9 years out) be at bilk-and-keep. You might > however have to interconnect indirectly, via a third-party tandem, > and there's some issue of recourse if they block calls to you. They > are not required to lease you any network elements. And they don't > like to be, well, too cooperative... but I'd first want to check > with the lawyers to know exactly how much privilege an RTC still has. > > > > -- > Fred Goldsteink1io fgoldstein "at" ionary.com > ionary Consulting http://www.ionary.com/ > +1 617 795 2701 > > > > > WISPA Wants You! Join today! > http://signup.wispa.org/ > > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
At 11/21/2011 08:04 PM, you wrote: >Yes agreed, its not nearly as bad as it could have been. But I still say >ARRGGG! > > > Price Cap Carriers will be offered $775 per > > line to add 4/1 broadband serivce to "unserved" areas > >Thats much better for WISPs than if they agreed to pay our competitors >greater than $10,000 per sub for FIOS like Fiber. >WISPs atleast have a chance to compete against 4/1 services, and ILEC >reimbursement now inline with what it would cost a WISP to deploy, and not >to much more.. Note that this is "incremental" $775, a subsidy to add to their capital budget, not the total investment. Of course big ILECs tend to be wasteful spenders. > > So this might be a good time to make sure the mappers > > are aware of your service areas, or to think about short-term service > > expansion. > >yeah, you gotta love help that says "WISPs Go hurry up and build a >network at your cost quickly, we wont pay you, but if you dont build quick, >we'll pay your competitor instead." >(Sarcasm) > > > The date by which you must be on the map isn't set yet, > > but it's presumably in 1H2012. > >Well, that is good, that they are looking at mapping for disqualification. >Also good that not all WISPs reported their coverage in the past. >The rules are good incentive for rural WISPs to report now. Those rules may >not have ever made it into the FCC rules, without the insight that it would >be incentive to get reamining WISPs to report. If WISPs had already >reported, why would the FCC have needed to include consideration and >incentive in the new rules? The FCC just had to have a date, and was nice enough to not close it too early. This also gives WISPs time to do some more construction and have it included. > > Phase II starts in 2013. For this, Price Cap Carriers will be > > offered support based on a cost model that the FCC will create in > > 2012. Once the model is complete, the ILEC will decide if it wants > > to take that support for its territory on a state-by-state (all of a > > state or nothing) basis. > >Thats the bad part Only a select few monopoly like companies can afford >to do complete State wide deployment, even when subsidized. >So basically, the FCC is saying Time to force the Monopolies to serve >ALL Americans, and leave no unserved areas left for the competitive >property. The whole-state rule applies to the big ILECs. If they say no, the rules for the auction aren't written yet, and may work on a smaller basis. I think that's one of the things to discuss in the FNPRM Comments, which are due 24 January. >... > > A separate Extremely High Cost fund will allocate up to $100M/year > > for locations too costly (by the model) to serve via the standard > > subsidy. This will be separately bid, and it's assumed that fixed > > wireless and satellite will be the mostly likely technologies. So > > this could allow some subsidies to rustic-but-Bell-area WISPs. > >Yes, that may be good for WISPs. >Or, better positioned ILECs to become WISPs. Good question. But due to caps on USF, ILECs might not want to play in that space. Also, the Big Dog Theory might come into play -- big dogs want big bones. A rural ILEC might play though, or a small CMRS. > > So on balance, the FCC has done a lot less harm to the rural WISP > > community than it could have, while still encouraging ILECs to deploy > > more broadband via subsidies. > >I fully agree with your conclusion. >Realistically, that could be considered a victory, for Rural WISPs. > >With that said, I would have preferred the FCC to have the balls to name the >new program what it really was... >They could have called it the "CAIF" - Connect America to ILECs fund. or >"KCC-CAF" - Kill Competiton and Choice, but Connect America Fund.". > >The interesting part will be to see how many RURAL ILECs will choose to >accept $768 per sub, to build out to all remaining Americans in their state. >What else will be interesting will be to see if, the RBOC fund recipients >really do what they are obligated to do afterwords. That number doesn't necessarily apply to Phase II -- if the bids are on a more granular area basis, they could go considerably higher. And they'll be for five years of funding, though frankly I'd prefer just CapEx, since WISPs need capital and big ILECs just need to pay off their investors. >I think it is an ambitious plan to try to get the remaining American's some >form of broadband, which outcome would likely be good, I just cant say I >agree with the method. I'm with you there. It's far from ideal, but it could have been w
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
At 11/21/2011 07:50 PM, Scottie Arnett wrote: >How can you offer voice if you can not get local phone number's because of a >rural telephone cooperative? I don't believe a rural cooperative can prevent you from pulling numbers from the NANPA. They are even required to interconnect with you for the exchange of traffic which, under the new rules, will *eventually* (like 9 years out) be at bilk-and-keep. You might however have to interconnect indirectly, via a third-party tandem, and there's some issue of recourse if they block calls to you. They are not required to lease you any network elements. And they don't like to be, well, too cooperative... but I'd first want to check with the lawyers to know exactly how much privilege an RTC still has. -- Fred Goldsteink1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
Yes agreed, its not nearly as bad as it could have been. But I still say ARRGGG! > Price Cap Carriers will be offered $775 per > line to add 4/1 broadband serivce to "unserved" areas Thats much better for WISPs than if they agreed to pay our competitors greater than $10,000 per sub for FIOS like Fiber. WISPs atleast have a chance to compete against 4/1 services, and ILEC reimbursement now inline with what it would cost a WISP to deploy, and not to much more.. > So this might be a good time to make sure the mappers > are aware of your service areas, or to think about short-term service > expansion. yeah, you gotta love help that says "WISPs Go hurry up and build a network at your cost quickly, we wont pay you, but if you dont build quick, we'll pay your competitor instead." (Sarcasm) > The date by which you must be on the map isn't set yet, > but it's presumably in 1H2012. Well, that is good, that they are looking at mapping for disqualification. Also good that not all WISPs reported their coverage in the past. The rules are good incentive for rural WISPs to report now. Those rules may not have ever made it into the FCC rules, without the insight that it would be incentive to get reamining WISPs to report. If WISPs had already reported, why would the FCC have needed to include consideration and incentive in the new rules? > Phase II starts in 2013. For this, Price Cap Carriers will be > offered support based on a cost model that the FCC will create in > 2012. Once the model is complete, the ILEC will decide if it wants > to take that support for its territory on a state-by-state (all of a > state or nothing) basis. Thats the bad part Only a select few monopoly like companies can afford to do complete State wide deployment, even when subsidized. So basically, the FCC is saying Time to force the Monopolies to serve ALL Americans, and leave no unserved areas left for the competitive property. Rather than fix the problem, the FCC is trying to secure that the remaining 25% of America will have subsidized competitors to private investment. There is no longer a consideration for the best party to serve a specific area. Preferrence is given to the big boy. no different than Auctions, where only the most fortunate and dominant player can win. The biggest flaw in telecom policy is the concept of Serving everyone or no one. Its the founation for every monopoly cable franchise type agreement, and now being replicated into CAF. Forcing acceptance on a complete state-by-state basis in my opinion is a major loss for the industry. Because the mind set hasn't changed from old telecom. They are still thinking "state regulation" and "utility electricity", where there is only ONE primary provider per state. Although, I will admit, these funds are targeted to UNSERVED areas, so atleast they aren't giving the whole state away. Just the least desirable part of the state for wireline to serve. They are saying. "WISPs, if you can serve someone new this year, great, go for it, its your last chance, before we give the market to someone else." > A separate Extremely High Cost fund will allocate up to $100M/year > for locations too costly (by the model) to serve via the standard > subsidy. This will be separately bid, and it's assumed that fixed > wireless and satellite will be the mostly likely technologies. So > this could allow some subsidies to rustic-but-Bell-area WISPs. Yes, that may be good for WISPs. Or, better positioned ILECs to become WISPs. > So on balance, the FCC has done a lot less harm to the rural WISP > community than it could have, while still encouraging ILECs to deploy > more broadband via subsidies. I fully agree with your conclusion. Realistically, that could be considered a victory, for Rural WISPs. With that said, I would have preferred the FCC to have the balls to name the new program what it really was... They could have called it the "CAIF" - Connect America to ILECs fund. or "KCC-CAF" - Kill Competiton and Choice, but Connect America Fund.". The interesting part will be to see how many RURAL ILECs will choose to accept $768 per sub, to build out to all remaining Americans in their state. What else will be interesting will be to see if, the RBOC fund recipients really do what they are obligated to do afterwords. I think it is an ambitious plan to try to get the remaining American's some form of broadband, which outcome would likely be good, I just cant say I agree with the method. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband ----- Original Message - From: "Fred R. Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 6:02 PM Subject: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
At 11/21/2011 06:43 PM, Victoria Proffer wrote: >Great summary! Thanks! >I saw the VoIP part too and the flag went up. This would tell me, it is >better to put VoIP on your network, sooner than later. > >I am curious what you thought of the Remote Fund that specifically mentioned >Fixed Wireless build out and ongoing support for WISPs. > >I have attached the Public Knowledge and Benton Foundation document that is >referenced in regards to building Community Networks. I love this idea! They have a lot of good ideas in that paper. Not that they were taken terribly seriously at this time. They mentioned Computer III as a model. That is indeed a good one; Computer II, after all (which was watered down by Computer III), is what made the public Internet possible. Its revocation has caused all sorts of trouble. But the FCC went out of their way to avoid touching any of the Computer Inquiries, or to use simple solutions that would have fallen out of them. Much of the complexity in their logic is an attempt to abuse the law to avoid the clear and simple concepts of the Computer Inquiries. So while the new Order is much better than what we would have gotten out of the previous Commission, it doubles down on that fundamental error, which of course was a major shibboleth of the Bells, who hated it with a purple passion. The middle mile question was left open for the Further NPRM, so more Comments may be welcome. >Also I thought it interesting that the FCC was requesting additional comment >on ECT status for WISPs and considering vetting on the federal, rather than >state level. Federal designation of ETCs already exists; I expect it will become more common in the future. >-Original Message- >From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On >Behalf Of Fred R. Goldstein >Sent: Monday, November 21, 2011 5:03 PM >To: WISPA General List >Subject: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > >On Friday, the FCC finally released the Order in their Intercarrier >Compensation and Universal Service Fund docket. The executive >summary had come out with the Adoption at last month's FCC Public >Meeting, but the 759-page (!) Order took a while to finish. > >The results, from a WISP perspective, are not nearly as bad as could >have been. The FCC has taken safeguards to make it easier for an >unsubsidized WISP to prevent subsidized competition from an incumbent LEC. > >The high-cost portions of the Universal Service Fund are being >restructured into the Connect America Fund. This will come into >being in three phases, each with different rules for Price Cap >Carriers and Rate of Return Carriers. About 95% of phone lines are >in the former category; the latter are basically small rural carriers >who depend upon USF. > >Phase I is just 2012. Price Cap Carriers will be offered $775 per >line to add 4/1 broadband serivce to "unserved" areas that they >weren't otherwise going to serve. They can choose how many lines >this applies to. If the location is "served" on the National >Broadband Map, or if the ILEC *knows* it's served by an unsubsidized >competitor, it's off limits. I think this must be at least 768k >fixed service. So this might be a good time to make sure the mappers >are aware of your service areas, or to think about short-term service >expansion. The date by which you must be on the map isn't set yet, >but it's presumably in 1H2012. > >Phase II starts in 2013. For this, Price Cap Carriers will be >offered support based on a cost model that the FCC will create in >2012. Once the model is complete, the ILEC will decide if it wants >to take that support for its territory on a state-by-state (all of a >state or nothing) basis. Again, only unserved areas will get >support, though an ILEC can use support to build common plant in an >area that is more than 50% unserved. So a new DSLAM that covers 40% >unserved would not be covered, but ont that covers 60% unserved would >be. So again it's important for WISPs to make their presence >known. If the ILEC turns down the state, USF support goes to the low >bidder. > >Phase III starts in 2018, and will be entirely bid-based, but the >details will be worked out in the future. > >A separate Extremely High Cost fund will allocate up to $100M/year >for locations too costly (by the model) to serve via the standard >subsidy. This will be separately bid, and it's assumed that fixed >wireless and satellite will be the mostly likely technologies. So >this could allow some subsidies to rustic-but-Bell-area WISPs. > >The FCC notes that while this gives ILECs first dibs on funding, it >also takes away Price Cap Carrier USF from areas served
Re: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
How can you offer voice if you can not get local phone number's because of a rural telephone cooperative? Scottie Arnett President Info-Ed, Inc. Electronics and More 931-243-2101 sarn...@info-ed.com - Original Message - From: "Fred R. Goldstein" To: "WISPA General List" Sent: Monday, November 21, 2011 5:02 PM Subject: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > On Friday, the FCC finally released the Order in their Intercarrier > Compensation and Universal Service Fund docket. The executive > summary had come out with the Adoption at last month's FCC Public > Meeting, but the 759-page (!) Order took a while to finish. > > The results, from a WISP perspective, are not nearly as bad as could > have been. The FCC has taken safeguards to make it easier for an > unsubsidized WISP to prevent subsidized competition from an incumbent LEC. > > The high-cost portions of the Universal Service Fund are being > restructured into the Connect America Fund. This will come into > being in three phases, each with different rules for Price Cap > Carriers and Rate of Return Carriers. About 95% of phone lines are > in the former category; the latter are basically small rural carriers > who depend upon USF. > > Phase I is just 2012. Price Cap Carriers will be offered $775 per > line to add 4/1 broadband serivce to "unserved" areas that they > weren't otherwise going to serve. They can choose how many lines > this applies to. If the location is "served" on the National > Broadband Map, or if the ILEC *knows* it's served by an unsubsidized > competitor, it's off limits. I think this must be at least 768k > fixed service. So this might be a good time to make sure the mappers > are aware of your service areas, or to think about short-term service > expansion. The date by which you must be on the map isn't set yet, > but it's presumably in 1H2012. > > Phase II starts in 2013. For this, Price Cap Carriers will be > offered support based on a cost model that the FCC will create in > 2012. Once the model is complete, the ILEC will decide if it wants > to take that support for its territory on a state-by-state (all of a > state or nothing) basis. Again, only unserved areas will get > support, though an ILEC can use support to build common plant in an > area that is more than 50% unserved. So a new DSLAM that covers 40% > unserved would not be covered, but ont that covers 60% unserved would > be. So again it's important for WISPs to make their presence > known. If the ILEC turns down the state, USF support goes to the low > bidder. > > Phase III starts in 2018, and will be entirely bid-based, but the > details will be worked out in the future. > > A separate Extremely High Cost fund will allocate up to $100M/year > for locations too costly (by the model) to serve via the standard > subsidy. This will be separately bid, and it's assumed that fixed > wireless and satellite will be the mostly likely technologies. So > this could allow some subsidies to rustic-but-Bell-area WISPs. > > The FCC notes that while this gives ILECs first dibs on funding, it > also takes away Price Cap Carrier USF from areas served by > unsubsidized competitors, so WISPs could theoretically come out > better under the new rules. > > Now here's a catch: "Unsubsidized competitor" is defined as a > provider of both voice and broadband service. It's not entirely > obvious (you try parsing 759 pages of FCC-speak this quickly... ;-) ) > if that applies to the Price Cap Carrier model, or just the rural > Rate of Return case, since the PCCs already offer unsubsidized voice > across most of their territories, and the map isn't about voice. In > the rural Rate of Return Carrier case, voice will be more > important. This does not mean that the WISP must be a CLEC per se; > it might be high-quality (QoS) VoIP offered in conjunction with a > CLEC who has local numbers, for instance. But for some ISPs, this > might be a good time to start thinking about adding voice > service. (My talk at FISPA last month was about the case for whether > an ISP should start up a CLEC.) > > In areas served by rate-of-return carriers, the new rules phase out > (over 3 years) all USF support to an ILEC that is 100% overlapped > (voice and broadband) by an unsubsidized carrier, typically > cable. If there is less than 100% overlap, then support will be > reduced, but the actual methodology is left to be determined via the > Further NPRM. > > So on balance, the FCC has done a lot less harm to the rural WISP > community than it could have, while still encour
[WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
On Friday, the FCC finally released the Order in their Intercarrier Compensation and Universal Service Fund docket. The executive summary had come out with the Adoption at last month's FCC Public Meeting, but the 759-page (!) Order took a while to finish. The results, from a WISP perspective, are not nearly as bad as could have been. The FCC has taken safeguards to make it easier for an unsubsidized WISP to prevent subsidized competition from an incumbent LEC. The high-cost portions of the Universal Service Fund are being restructured into the Connect America Fund. This will come into being in three phases, each with different rules for Price Cap Carriers and Rate of Return Carriers. About 95% of phone lines are in the former category; the latter are basically small rural carriers who depend upon USF. Phase I is just 2012. Price Cap Carriers will be offered $775 per line to add 4/1 broadband serivce to "unserved" areas that they weren't otherwise going to serve. They can choose how many lines this applies to. If the location is "served" on the National Broadband Map, or if the ILEC *knows* it's served by an unsubsidized competitor, it's off limits. I think this must be at least 768k fixed service. So this might be a good time to make sure the mappers are aware of your service areas, or to think about short-term service expansion. The date by which you must be on the map isn't set yet, but it's presumably in 1H2012. Phase II starts in 2013. For this, Price Cap Carriers will be offered support based on a cost model that the FCC will create in 2012. Once the model is complete, the ILEC will decide if it wants to take that support for its territory on a state-by-state (all of a state or nothing) basis. Again, only unserved areas will get support, though an ILEC can use support to build common plant in an area that is more than 50% unserved. So a new DSLAM that covers 40% unserved would not be covered, but ont that covers 60% unserved would be. So again it's important for WISPs to make their presence known. If the ILEC turns down the state, USF support goes to the low bidder. Phase III starts in 2018, and will be entirely bid-based, but the details will be worked out in the future. A separate Extremely High Cost fund will allocate up to $100M/year for locations too costly (by the model) to serve via the standard subsidy. This will be separately bid, and it's assumed that fixed wireless and satellite will be the mostly likely technologies. So this could allow some subsidies to rustic-but-Bell-area WISPs. The FCC notes that while this gives ILECs first dibs on funding, it also takes away Price Cap Carrier USF from areas served by unsubsidized competitors, so WISPs could theoretically come out better under the new rules. Now here's a catch: "Unsubsidized competitor" is defined as a provider of both voice and broadband service. It's not entirely obvious (you try parsing 759 pages of FCC-speak this quickly... ;-) ) if that applies to the Price Cap Carrier model, or just the rural Rate of Return case, since the PCCs already offer unsubsidized voice across most of their territories, and the map isn't about voice. In the rural Rate of Return Carrier case, voice will be more important. This does not mean that the WISP must be a CLEC per se; it might be high-quality (QoS) VoIP offered in conjunction with a CLEC who has local numbers, for instance. But for some ISPs, this might be a good time to start thinking about adding voice service. (My talk at FISPA last month was about the case for whether an ISP should start up a CLEC.) In areas served by rate-of-return carriers, the new rules phase out (over 3 years) all USF support to an ILEC that is 100% overlapped (voice and broadband) by an unsubsidized carrier, typically cable. If there is less than 100% overlap, then support will be reduced, but the actual methodology is left to be determined via the Further NPRM. So on balance, the FCC has done a lot less harm to the rural WISP community than it could have, while still encouraging ILECs to deploy more broadband via subsidies. -- Fred Goldsteink1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
