Here's what WISPA is prepared to submit to the commerce committee. Thought
you guys would like a peek at it first.
WISPA USF Reform Position Paper
WISPA is a the WISP industry's only industry owned and operated
trade association. We're a 501c6 corporation with a 7 person, membership
The goals for USF should be clarified. Are laptops for kids
part of the program goals? Was it the original intent that USF exclude
small local entrepreneurs and give preferential treatment to the incumbent?
As USF changes, do the changes have a clear goal? Is this just a mechanism
to try to put more funds into the program otherwise leave it as is? Or does
Congress want to see substantial changes in the program that do more to
foster rather than stifle innovation?
WISPA believes that market forces should mostly be left to their
own. Without government tweaking. USF should be canceled completely. If a
real need for outside funding in regions or small pockets turns out to be
needed, address those issues on a case by case basis. At the very least the
USF program needs major reform as its cost based fee structure encourages
An example of artificially high costs would be in Odessa,
Washington. In the early 2000 time frame the local telco replaced an 8 T-1
microwave link with a fiber optic line at a cost (or so we've been told) of
$600,000. Even at the time, the cost of a microwave replacement with more
capacity would have been half or less. This is for a town of 1000 that's
not on the way to anywhere. The telco is now in the process of adding more
fiber to complete a fiber loop to other areas. This next 30 mile stretch is
through many solid rock canyons and the costs are expected to be even
This same telco has installed $60,000 DSL systems in rural areas
that have fewer than 15 houses within 18,000 feet of the hut. Clearly these
are cost raising mechanisms.
We understand that USF is not likely to go away at this time.
The above telco gets 2/3rds of its income via subsidies and would not likely
survive without them. Leaving such business practices in place permanently
is not good public policy though.
WISPA proposes that a time limit on the USF program be
instituted. Expand the program to include all communications companies and
use USF to help them build an infrastructure. Once that system is built, it
needs to stand on its own two legs though. If it doesn't, then that's the
company's fault and they can live with the results of the network they
built. Somewhere between 10 and 20 years should allow plenty of time for
efficient network upgrades or construction. The program should not be
viewed as a permanent profit line item for companies but rather be a short
term capitalization/construction fund that will end and leave the company
standing (or not) on its own two feet at a set specific date.
We believe that opening up USF to all operators would likely cause multiple
networks to be built at the same time and the most efficient ones would
survive. If, after USF was discontinued some areas were left with no viable
options for service those specific cases could be addressed under some more
targeted program. Funds should be collected and distributed based on
customers serviced. This would help prevent speculation with the funds,
rather the funds would reward those that have already stepped up to the
plate. Tying fund distribution with the FCC form 477 would also likely help
lead to more accurate market data availability.
WISPA also believes that USF's goals should be readdressed. We don't
believe that using USF funds to provide laptop computers to 68,000 7th and
8th graders in Massachusetts is a proper use of the program.
We would also like to see some changes in the way that USF is distributed.
The E-Rate program excludes almost all entrepreneurial providers. In some
areas the local WISP offers greater service levels for less cost than the
local hospital or school is paying via the E-Rate programs. We're not
allowed to service those portions of the account that we could take care of
because we don't have CLEC status or can't offer all services.
It seems to us that a complicated mechanism to compute pay in and pay out
isn't needed or wanted at this time. We propose that the current
contributions simply be expanded to any broadband provider in any area that
the incumbent currently contributes. And in any area where USF funds are
distributed all providers be given equal shares based on customer base. And
one customer equals one share. No company should get more money for more
services. This would slow down the convergence of services into
increasingly efficient networks in rural markets.
This model should encourage both competition and a shift from high cost to
low cost network design.
Marlon K. Schafer
Founding Board Member
FCC Committee Chairman
(509) 988-0260 cell
(509) 982-2181 Equipment sales
(408) 907-6910 (Vonage) Consulting services
42846865 (icq) And I run my own wisp!
126.96.36.199 (net meeting)
WISPA Wireless List: email@example.com