I think you are missing the point here. We're talking about a mechanism to bring broadband to the entire country! Not just a small expansion for you.

Also, most rural telco's will die if they loose these funds. Sure they're milking the system but they'll still fail without it. Like it or not, they are important especially for the next several years. You need backhaul right??? grin Even they need time to change business models, products, infrastructure etc.

That help?
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



----- Original Message ----- From: "KyWiFi LLC" <[EMAIL PROTECTED]>
To: "WISPA General List" <[email protected]>
Sent: Tuesday, March 28, 2006 1:11 PM
Subject: Re: [WISPA] USF fund reform


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" <[email protected]>
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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