----- Original Message ----- From: "Brett Glass" <[EMAIL PROTECTED]>
To: <isp-wireless@isp-wireless.com>
Cc: <wireless@wispa.org>
Sent: Tuesday, March 28, 2006 1:00 PM
Subject: Re: [isp-wireless] USF fund reform

Some comments:

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.

A 501(c)(6) nonprofit corporation cannot be "owned" by anyone. WISPA's board does act as if it "owns" the group, though, so this fact may be lost on them. Also, several of the members of that board claimed that they would step down after the organization was founded and then did not.

Sigh. The MEMBERSHIP owns the corp. We can modify or change it anytime that the membership votes to do so.

The goals for USF should be clarified. Are laptops for kids part of the program goals?

Even to ask this question shows a fundamential misunderstanding of the concept of universal service.

Agreed. That's why I was shocked to find out that USF had funded 68,000 laptops for school kids. That number came up in Senate testimony about USF reform.

Was it the original intent that USF exclude small local entrepreneurs and give preferential treatment to the incumbent?

But of course! Remember, it was designed to replace cross-subsidies within the Bell System -- the original incumbents. Even most wireless carriers do not get USF funding.

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?

Congress wants campaign contributions and votes. Anything else is incidental.

WISPA believes that market forces should mostly be left to their own.

Incorrect grammar (embarrassing).

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.

Poor writing style and no citations of sources. The same is true for the rest of the document. I'd be embarrassed to be a member of a group that submitted any such document.

Feel free to provide better wording at any time. The intent of releasing that doccument before submission was to get constructive input.


--Brett Glass

** ISPCON Spring 2006 - May 16 - 18 - Baltimore, MD  www.ispcon.com **
** THE EVENT for ISPs, WISPS, CLECs and WebHosts **
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