With competition the ILEC's would have to actually take care of their customers 
instead of treating them like they don't have a choice. I remember the day I 
cut the cord from bell. It was a memorable moment. 

Sent from my iPhone4

On Feb 12, 2011, at 4:28 PM, Mike Hammett <wispawirel...@ics-il.net> wrote:

> It's too bad they're axing competition instead of embracing it.
> 
> 
> -----
> Mike Hammett
> Intelligent Computing Solutions
> http://www.ics-il.com
> 
> 
> 
> On 2/12/2011 12:48 PM, Fred Goldstein wrote:
>> First off, this last thread's title was offensive, so I changed
>> it.  The current Administration is not doing much that previous ones
>> didn't do, and that's the problem.  The FCC sees the spectrum as a
>> source of revenue (auctions), and Congress sees the FCC as a source
>> of subsidy money to rural states.
>> 
>> USF exists because the Telecom Act requires it.  USF replaced an even
>> uglier system wherein rural telcos charged really really high
>> switched access per minute rates to LD carriers at either end of the
>> call.  VoIP would have killed that anyway... so now there are
>> explicit cash subsidies.
>> 
>> Let's set aside the smaller parts of USF (Schools&  Libraries, Rural
>> Health Care, and Low Income) and focus on the one on the table now,
>> High Cost Support.  This is the one that gets the bulk of the tax
>> money anyway.  The statutory requirement is that rural telephone
>> rates be comparable (not identical) to urban ones.  So if it really
>> costs $100/month to provide telephone service in East Overshoe, then
>> the East Overshoe Telephone Cooperative is entitled to USF to let
>> them hold down the rate.
>> 
>> But it's a lot more complicated than that.  Cost is averaged across a
>> "study area", which is in general the operating territory of one
>> (historic, pre-merger) telephone company in one state.  So South
>> Central Bell- Mississippi is one study area, and South Central Bell-
>> Tennessee is another.  Verizon has at least two study areas in
>> California, though, one ex-Contel and one ex-GTE.  CenturyTel has a
>> heap of them all over the place, as does TDS.
>> 
>> The point of averaging across a study area is that low-cost urban
>> areas cross-subsidize high-cost rural ones.  So Qwest in Omaha is
>> supposed to subsidize Qwest in the rural parts of Nebraska.  Thus the
>> big recipients are the small telephone companies who do not have
>> urban areas.  That would be bad enough, but a small telephone company
>> typically has a separate corporate structure, including IT, CS, etc.,
>> which supports very few subscribers.  So the OpEx per subscriber can
>> be really high too, because small telcos are inefficient.  If TDS or
>> CenturyTel buys them, they often keep the study areas separate...
>> cost goes down but the money still flows!  (The pending NPRM does
>> however at least open the issue of merging study areas.)  And the
>> Bells, especially Qwest/USWest, have sold off a lot of rural
>> areas.  So they have lowered their average cost. This doesn't lower
>> their rate, though, because they don't get USF anyway, and they are
>> on price caps, not rate of return, so they keep their rates and raise
>> their margins.  The rural chains that buy the rural turf eventually
>> (this takes a couple of years, though again the pending NPRM may
>> reduce this interval, which the FCC cutely calls "The Parent Trap")
>> get new subsidy flows for them.  So we're screwed both ways.
>> 
>> When TA96 passed, the FCC at the time was pro-competition (Hundt,
>> Kennard) and they wanted to make USF pro-competition too.  So they
>> created the "Equal Support Rule".  This is a tiny bit like Jeremie's
>> suggested voucher system.  A USF-eligible carrier is called an ETC
>> (eligible telecommunications carrier). A Competitive ETC (CETC) could
>> move into an area whose ILEC got USF.  The CETC would then get the
>> same amount *per line* as the ILEC-ETC.  So if East Overshoe
>> Telephone got $80/month/line, then Northern Wireless could get
>> $80/month/line for selling a fixed-wireless telephone line (using
>> their cellular network and a POTS-phone adapter).  Northern Wireless
>> (I made that name up but it alludes to a once-huge CETC) would not
>> need to show its own costs, as competitors don't fit the ILEC accounting 
>> model.
>> 
>> Now you'd think that this was a great idea, like a voucher, but it
>> had a big problem.  The ILEC-ETC is usually under Rate of Return
>> regulation.  So their profit margin is fixed.  Most of their costs
>> are fixed too.  So if the CETC takes lines away, the ILEC-ETC is
>> still entitled to keep the subsidy level needed to maintain their
>> rate of return and the same low prices.  So they keep their subsidy,
>> and USF ends up paying twice!  This is the FCC's justification for
>> wanting to do away with competitive ETCs entirely -- they could have
>> simply removed Equal Support, but they're killing CETC in toto,
>> regardless of what the law actually says.  A few years ago, they
>> capped CETC support.  If a new CETC comes into an area, their subsidy
>> comes out of other CETCs, no longer equal support.  The total is
>> supposed to phase down to 0 over five years.
>> 
>> BTW the biggest CETCs were cellular carriers, including Sprint, AT&T
>> Mobility and its predecessors, and some Verizon Wireless
>> acquisitions.  VZ and I think Sprint agreed to phase out their CETC
>> support as merger conditions.  CLECs got a rather small share of the
>> pie.  WISPS need not apply, since they're not carriers, and the
>> support was technically for voice.
>> 
>> Oh, voice?  Well, the real scandal of USF is that the ILEC-ETC is
>> allowed to do practically anything so long as it's useful for
>> voice.  They can build Fiber to the Ranch, for $20,000+/home (CapEx)
>> or more, or $1000/month per sub (though they propose making it harder
>> to get>$250/line/mo), if it also delivers voice, *even if* they
>> already have copper to the ranch *and* an unlicensed WISP.  Check out
>> Border to Border in Texas.  So USF does fund broadband; it just does
>> it indirectly, by letting them build a broadband-ready network with
>> subsidy money.  The ISP they run across it is then "incidental", not
>> *directly* subsidized, but if the wire or fiber is already there, how
>> much does more it cost to drop on broadband Internet?  Thanks to this
>> policy, many rural ILECs have better broadband coverage than
>> unsubsidized Bells.
>> 
>> We pay for this.  USF is funded by a tax on "interstate
>> telecommunications". That includes long distance calls, circuits, and
>> interconnected VoIP (assumed 64.9% interstate, IIRC, but I'm typing
>> this off-line on my laptop in a rural location -- I haven't paid VZW
>> for tethering and for some reason it no longer works on my cell phone
>> ;-] ).  This is technically a "fee" rather than "tax" because it
>> doesn't go to the Treasury's General Fund, but it is enforced like a
>> tax (big fines if you don't pay).  It goes to USAC, who runs
>> USF.  It's a self-adjusting tax.  Every quarter, they compute a new
>> rate, and it takes effect automatically.  It started out around 3%
>> and is now around 15.5%.
>> 
>> The FCC's new set of proposals has a couple of major impacts.  It
>> continues the phase-out of CETC support.  It also creates a new fund,
>> "Connect America", which explicitly covers "broadband", as if that
>> were a noun.  (Broadband what? It's an adjective.)  This will be
>> distibuted by reverse auction; the ETC who asks the least to serve a
>> given area gets the exclusive support.  If may be the ILEC.  Whether
>> or not it's the ILEC, the ILEC-ETC *continues* to get their current
>> support.  Connect America is incremental.  So the ILECs can get even more.
>> 
>> BTW there's a separate pending proposal to create a new USF to fund
>> mobile wireless -- licensed CMRS, not WISP.  This may be related to
>> the recently announced 98% goal, though it seem to me that Verizon
>> had planned that for its LTE network anyway!  BTW the Frontline
>> Wireless plan that almost happened in 2007 was required to have 99.3%
>> population coverage, though (speaking as one of their network
>> designers) that was sort of optimistic, and a sane proposal (that
>> might have happened) would have needed a lower number.
>> 
>>   --
>>   Fred Goldstein    k1io   fgoldstein "at" ionary.com
>>   ionary Consulting              http://www.ionary.com/
>>   +1 617 795 2701
>> 
>> 
>> 
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