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


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

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

No Taxes, No Regulatory Fees, No Hassles

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


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


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

Jeromie

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

> Hi All,
>
> Here's what WISPA is prepared to submit to the commerce committee.  
> Thought you guys would like a peek at it first.
>
>
>
> WISPA USF Reform Position Paper
>
>
>
>            WISPA is a the WISP industry's only industry owned and 
> operated trade association.  We're a 501c6 corporation with a 7 
> person, membership elected board.
>
>
>
>            The goals for USF should be clarified.  Are laptops for 
> kids part of the program goals?  Was it the original intent that USF 
> exclude small local entrepreneurs and give preferential treatment to 
> the incumbent? As USF changes, do the changes have a clear goal?  Is 
> this just a mechanism to try to put more funds into the program 
> otherwise leave it as is?  Or does Congress want to see substantial 
> changes in the program that do more to foster rather than stifle 
> innovation?
>
>
>
>            WISPA believes that market forces should mostly be left to 
> their own.  Without government tweaking.  USF should be canceled 
> completely.  If a real need for outside funding in regions or small 
> pockets turns out to be needed, address those issues on a case by case 
> basis.  At the very least the USF program needs major reform as its 
> cost based fee structure encourages abuse.
>
>
>
>            An example of artificially high costs would be in Odessa, 
> Washington.  In the early 2000 time frame the local telco replaced an 
> 8 T-1 microwave link with a fiber optic line at a cost (or so we've 
> been told) of $600,000.  Even at the time, the cost of a microwave 
> replacement with more capacity would have been half or less.  This is 
> for a town of 1000 that's not on the way to anywhere.  The telco is 
> now in the process of adding more fiber to complete a fiber loop to 
> other areas.  This next 30 mile stretch is through many solid rock 
> canyons and the costs are expected to be even higher.
>
>
>
>            This same telco has installed $60,000 DSL systems in rural 
> areas that have fewer than 15 houses within 18,000 feet of the hut.  
> Clearly these are cost raising mechanisms.
>
>
>
>            We understand that USF is not likely to go away at this 
> time. The above telco gets 2/3rds of its income via subsidies and 
> would not likely survive without them.  Leaving such business 
> practices in place permanently is not good public policy though.
>
>
>
>            WISPA proposes that a time limit on the USF program be 
> instituted.  Expand the program to include all communications 
> companies and use USF to help them build an infrastructure.  Once that 
> system is built, it needs to stand on its own two legs though.  If it 
> doesn't, then that's the company's fault and they can live with the 
> results of the network they built.  Somewhere between 10 and 20 years 
> should allow plenty of time for efficient network upgrades or 
> construction.  The program should not be viewed as a permanent profit 
> line item for companies but rather be a short term 
> capitalization/construction fund that will end and leave the company 
> standing (or not) on its own  two feet at a set specific date.
>
>
>
> We believe that opening up USF to all operators would likely cause 
> multiple networks to be built at the same time and the most efficient 
> ones would survive.  If, after USF was discontinued some areas were 
> left with no viable options for service those specific cases could be 
> addressed under some more targeted program.  Funds should be collected 
> and distributed based on customers serviced.  This would help prevent 
> 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.
>
>
>
> Sincerely,
>
> Marlon K. Schafer
>
> Founding Board Member
>
> FCC Committee Chairman
>
> WISPA
>
> (509) 982-2181
>
> (509) 988-0260 cell
>
>
> laters,
> Marlon
> (509) 982-2181                                   Equipment sales
> (408) 907-6910 (Vonage)                    Consulting services
> 42846865 (icq)                                    And I run my own wisp!
> 64.146.146.12 (net meeting)
> www.odessaoffice.com/wireless
> www.odessaoffice.com/marlon/cam
>
>
>



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