At 7/29/2010 11:51 AM, Brian Webster wrote: >Fred, > Does the bill state that the voice and data service have to be >provided by the SAME carrier or just that the consumer has access to them?
It says that they purchase it "from" the unsupported non-incumbent provider. So that implies at least a resale relationship. Bear in mind that many cable companies who provide voice service do not have their own voice networks; Sprint, for instance, is the wholesale CLEC supplier to much of Suddenlink and TW Cable. The bill does not specify that the seller be a CLEC per se. It does require a stand-alone voice service (bundles only don't count), toll restriction option, E911, etc. And there can be "just and reasonable" charges for extending the line outside of the normal service range, again resembling telco practice for houses set back too far, etc. >Would cellular service qualify in that case? No; it's written for wireline, and "standard" POTS parameters. The bill allows up to two CMRS carriers to get USF too. If there are at least three CMRS carriers in an area, they "bid" for the right to receive USF. If there aren't three, but one already gets USF, it keeps it, without bidding, at current levels. This latter clause might end up giving VZ and ATT a lot of extra money vs. current FCC plans to reduce USF support to them, which shows you how the bill is not really one to reduce USF so much as to direct it certain ways! >Thought is that is there is >cell or CLEC service and a WISP also covers the same area with only >broadband, it could be considered served. The issue of QOS and all the other >call reliability standards would be addressed by others and not the WISP. No, because mobile standards are counted differently, towards the separate mobile USF entitlement. WISPs are left out. (Time to crack out the lobbyists!) > I get and understand every point you made on the bill and the >players. It all makes sense and pretty much what one would expect. Changes >to allow WISP's or wireless to be considered part of the 75% coverage would >really hurt the rurals that are trying to save their revenue stream and will >meet with a massive fight. USF reform was expected to have spurred a big >fight from those who stand to lose. There have been a lot of votes and >campaign contributions bought with that money over the years. Yes, I expect that this bill will receive a fair amount of opposition from the subsidy-suckers too. >Brian > > >-----Original Message----- >From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On >Behalf Of Fred Goldstein >Sent: Thursday, July 29, 2010 11:20 AM >To: WISPA General List >Subject: Re: [WISPA] USF Reform Bill Introduced - The most compelling reason >to document and map your network coverage ever > >At 7/29/2010 10:34 AM, Brian Webster wrote: > >Yes but if the cable companies could also ally with wireless carriers to >get > >other areas excluded from USF subsidies, the field would be a more level >one > >should the cable companies try to compete in other markets. We might also > >get Clearwire and the cellular carriers to support the position although > >most of their deployments will probably be in areas that would never have > >qualified for USF to begin with. If the terms wireline are kept in the bill > >it would appear that wireless services might also be excluded from >receiving > >any USF funds which basically keeps USF funds in the exclusive hands of the > >Telco's as it has been. > > > >Personally I think that if we don't out and out oppose the bill for USF > >reform, but rather do something like this as a minor change, the WISP > >industry can make out better. USF reform will happen and USF funds will be > >spent on deploying broadband to unserved areas no matter what. What we need > >to do is make sure the law does not fund builds in areas already served by > >WISP's and other technologies. If the battle could also be fought and won >to > >allow WISP's access to the funds for broadband deployments then great. When > >going up against the cable and Telco lobbies, one has to be wise about > >picking their battles as the funding to fight this will be limited. > >And on a related note, Patrick Leary wrote, > > >You'd think there would be an excellent legal argument to fight that. > >Seems it'd be difficult to enact a law that in effect discriminates > >against certain classes of providers, especially since WISPs are the > >only "pure play" broadband providers out there. Theorectically the > >re-configured USF is meant to propel broadband...so how could the feds > >exclude the only entity that provides broadband first, other services > >second. All other providers have "broadband" as a secondary play. > >Patrick's first... We're talking about a new law, so the legal >argument boils down to whatever the law says is legal, is legal, >unless it's a flagrant constitutional violation. Which I don't see, >since the main issue here is simply who gets government handouts, and >handing out money (and taxing) is sort of the normal role of >government. The problem is that the system is so corrupt by now that >the handouts appear to be irrational. In practice they're not; they >just aren't done for the public good. > >Back to Brian's point... You first have to think about whose bill >this is. Boucher doesn't make this stuff up himself. Nor does his >staff, though they know more about it than most congressional >staffers. Boucher's job in Washington is, and has always been, to >carry Verizon's water. When he puts a bill in the hopper, it comes >from them. Tom Tauke's staff probably drafted most of the bill. > >So what is Verizon asking for? You again have to look at what USF is >all about. It was created as part of intercarrier compensation >reform. Before USF, toll settlements to rural carriers were high >enough to pay the subsidies. Make a 30 cent call and the rural >carrier gets 50 cents for terminating it. This worked because Long >Distance was a huge luxury and thus could be milked. As the cost of >delivering LD went down, the amount that could be diverted to >supporting the ILECs went up. But the system broke down under >competition, especially from VoIP, but also from something called >"reality" -- you can't perpetuate a rotten system like that >forever. It was hugely inefficient. So intercarrier payments from >IXCs to LECs no longer pay the whole freight, and explicit USF makes >up the difference. The IXCs, however, are the main payers of >USF. They count the cards differently but the kitty still goes the same >way. > >In the 1980s, Verizon (then called Bell Atlantic) was a LEC and on >the receiving end of IXC switched access charges. But now the Bells >get much lower switched access rates, so it's not a big revenue >source for them. Instead, you have Verizon owning the former MCI and >Worldcom assets and Southwestern Bell owning the former AT&T Corp. >assets, so the two mega-Bells are probably net payers, not >recipients, of subsidies to the rurals, both via USF and access >charges. Sprint, of course, no longer has any affiliated LECs, so >it's a big net loser too. Those three companies thus want to lower >the bill. The rural carriers, from the few remaining mom-and-pops to >the coops up to big CenturyTel and Citizens/Frontier, want even >more. So they are using "broadband" as an excuse. Give them more >USF money and they'll extend DSL out further, even FTTH. Hey, it's >not *their* money! They don't build gold-plated networks. It's >solid 14k gold. (Not 24k. They're too modest for that, and besides >14k is harder.) > >So what the Boucher bill does is push the FCC along the path it was >considering anyway, with some tweaks. The 75% clause is there to cut >off support to ILECs that have been almost fully overbuilt by cable, >not because cable cares (they don't get USF), but because it may >lower the total cost of the USF, and let's face it, PacketCable is >just as good as most POTS. It's not Skype! It's not even on the >Internet. Verizon HATES the cable industry, especially Comcast, but >if the presence of cable can be used against USF subsidy-suckers, >then it's counted. > >USF still only goes to "ETCs", as before, and getting to be an ETC >may not be easy. The FCC has largely frozen out new competitors, and >their plan is to limit USF high-cost support to ILECs only. The >Boucher bill opens it up by creating a subsidized wireless franchise >too, so Verizon and its best buddy ATT can split up the country that >way. (Sprint and other can bid too, though they're less likely to >win.) The odds of a WISP getting USF out of this bill are roughly >those of getting a unicorn to ride on to visit customer sites. > >Now let's get back to the technical issue. The bill not only >specifies "wireline", but it requires standard-quality >telephony. That means, basically, full-QoS POTS with local phone >numbers. Can a WISP deliver that? Yes, but it's not trivial. It >requires QoS-engineered networks. It requires high reliability, >battery backup, etc. It may be hard for any "routed" network can meet >the grade, but that can be fixed in software. > >It also requires that you use, or be, a local CLEC for the voice >service. This is pretty scary for most ISPs, but if there were a >good reason for it, then it could be handled. There are a few >ways. If there is a local CLEC already, the WISP can partner with >it. Or a CLEC can sell wholesale dial tone (SIP, MGCP or H.248, for >instance) to the WISP, though that requires the WISP to be a CLEC >too. Or the WISP/CLEC can outsource the whole thing to a company who >operates a centralized call agent, and who places down a media >gateway at the local tandem and does all the work. There are a >number of variations possible here and I see some of them in my CLEC >work, though the "rent-a-switch" and "rent-a-call-agent" business >hasn't developed as far as I'd like it to. > >But since the WISP still doesn't get USF, there's not much reason to >try, unless the WISP wants the voice revenue. Which isn't a bad >thing, actually... you can deliver it for a much lower *cost* than >the rural ILEC. But you can't undercut the ILEC's *price*, since USF >is paying most of the freight. That's the trouble with the whole >system. And Boucher and Terry, who represent largely rural >constituencies, are not interested in fixing that! In theory, if the >law didn't specify wireline and the WISP-CLEC could pass the 75% >test, then the ILEC would take a big hit and have to raise its >prices, which would be politically unpopular. That's the only >upside, and it's a long shot at best. > > >Brian > > -- Fred Goldstein k1io 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/
