Hi All, I finally got my USF comments filed in the right spots (I hope, things are different than the last time I filed directly :-).
Your comments will apply to multiple FCC documents. Here's the list: WC Docket No. 10-90 GN Docket No. 09-51 WC Docket No. 07-135 WC Docket No. 05-337 CC Docket No. 01-92 CC Docket No. 96-45 WC Docket No. 03-109 You'll go here to file them: http://fjallfoss.fcc.gov/ecfs/upload/display?z=7t6a4 Notice the proceeding box. You'll put one of the above numbers into that box then fill out the rest of the form. There is a spot you can click that will let you put more than one proceeding into your filing. That'll save you a lot of time. The easiest way to do this is to include the above numbers into a document that you write then attach the document at the bottom of the filing form. Here's mine: ********************************* Friday, March 18, 2011 Comments on USF. WC Docket No. 10-90 GN Docket No. 09-51 WC Docket No. 07-135 WC Docket No. 05-337 CC Docket No. 01-92 CC Docket No. 96-45 WC Docket No. 03-109 Dear Sirs, I have been reading the current NPRM on USF and have gone from excited to frustrated to outright petrified, all in the first 20 pages or so. At this point I think my life as an ISP is pretty well over. It's just a matter of time before I join the ranks of the buggy whip industry. You site example upon example of creative rule interpretations, shady practices and out right misappropriations. Yet there is not one word dedicated to enforcement. Nothing about removal of companies from the program when they clearly abuse the current programs. What good is an overhaul of the USF system and all of it's side bar programs into a new CAF or any other program if the same ol' companies are still going to have access to it? They cheated the system before, they'll do it again! I'd always wondered how it happened that PTI bought out the US West system here in Odessa. Then PTI was bought out by Century Tel. Then Century Tel bought out Embarq. Next they bought Quest, not an area Quest covered, but Quest. Quest, the renamed US West! Where in the world does a small rural telco get the money to buy out a huge company like US West/Quest? Now I know. They game a system that no one cares is being scammed. I had a "temp" cable run to my house for 3 years. On a short drive last week I spotted 2 more "temp" runs, one of which I know has been there for more than a year. Just cable strung across the ground along side the ditch. There is one main trunk, just outside of town, that's been ground laid for 7 years now! They can afford to buy out Quest but they can't afford to maintain the network that they already have? So, take USF funds for a "high cost" area, don't fix things in the "high cost" area and instead buy out your competition. Nice gig. Why is there ANY talk of expanding subsidies to companies that act this way? Why do I even have to worry about what I'm going to do to try to compete with a company that gets it's money from what amounts to a tax on communications? What needs to happen here is to just stop the funding. It's clearly not needed in MOST cases these days. The "high cost" areas are high cost due in too large a part to fraud, waste and abuse, not to the costs associated with improving the networks. These guys had their chance, they blew it by playing the part of the stereotypical corporate greedmonger. It's time to turn off the spigot. Those that can really run a business will be fine, those that can't can, should and will fail and be replaced by better companies with better practices and probably better equipment. If you insist upon trying to "fix" the problem by creating a new and expanded program please, in God's name, make it a simple program! Heck, even the question you asked required nearly 300 single spaced type written pages. Don't create something that will require a staff of people to understand and or comply with. Don't make a program that's so convoluted that it's easily abused due to people's inability to fully understand it. Please do not, again, create a program that's only understood by those with a vested financial interest in the program. Make sure it's understandable by anyone that is interested in using it OR keeping the participants honest. There is quite a bit of talk in the industry about consumer vouchers, pay the customer and let all of us fight over the customer. I don't think that's a good option for the entrepreneur. It will take money to build the networks that the consumer will be expected to draw service from. That means that the network must first be built and it'll be paid for only after it's in place, if we get the customer. My biggest fear here is that companies will basically give services away just so that the customer will use them because they are the cheapest one. Also, think of how many consumers you already likely know that are gaming Workers Comp. systems and other programs like them. Who's going to make sure that the consumer is really paying what they claim they are or even have any service? It'll take a lot more inspectors to monitor the consumer than the providers. In my case we can maintain the network just fine. We can't quickly cash flow the construction of it. We can, and do, sell at a competitive rate. Our speeds are very competitive with DSL and cable. I just did a couple of installations on two farms roughly 15 miles from town and the customers got speeds around 12 mbps both download and upload. Not to my main router, but to http://www.speakeasy.net/speedtest, the Seattle site. Monthly rate for these customers? $40.00 Once the infrastructure is paid for keeping it running and upgraded is relatively easy and affordable. How should this be done? Set a 10 year sunset on ALL subsidies. Expand the current programs into broadband. Require all companies to pay in or draw out based upon what is being done today. If the telco in an area pays into USF then all broadband companies in the area will also pay in. If the local telco draws out then all broadband providers will also draw out. There needs to be competition and alternative technologies in all areas. We should have competitors, not just government chosen winners that happen to be good at the paperwork game. Don't add new competitors though, encouraging companies to start up just because they see "free government money" would be bad for everyone. Help the companies that are ALREADY working to fulfill the public demand. Keep all of the dollar amounts where they are today, don't play favorites, involve all current operators. Base all payments, either in or out, on what the current telco does, just expand the system to include all broadband providers. This will allow entrepreneurs to put their time, effort and man hours into network improvements and expansion rather than government paperwork. By doing this you'll create several layers of competition in nearly all rural areas of the country. Often with different hardware and business models. Then, in 10 years cut off the funds. In a couple of additional years those that build out good networks that are self sustainable will still be in business, the wasteful or inefficient ones will weed themselves from the market. The customer will have choices and competition to drive costs down and services up. As importantly the government will be out of the telecom corporate welfare business and can devote it's time and resources to the real hardship cases that remain. If this is also not an option, then whatever programs you do create need to be non exclusive in nature. Don't make the paperwork overhead so high that the average mom and pop shop can't participate. Don't pick favorites, programs need to benefit all operators or none of them. Don't create complicated programs that only a lawyer can understand. I know I've said this before but it bares repeating many times. The market will adjust to the needs of the consumer if there is a fair and level playing field. DSL systems were first created in the sixties. Yet we didn't see their wide spread use until the '96 telecom act forced competition into the telecom industry. Don't screw up the broadband industry by removing real, effective, innovative competition with a new government funded welfare program for the good ol' boys telecom club. Also, I think there needs to be some talk about expectations. What do people need certain speeds and capacities for and who should pay for those activities? The capacity needs for email are one thing, eBay is another. Watching a few Youtube videos is easy enough to do. But when we start talking about watching TV or movies via the internet an entirely new level of technology and capacity are needed. And for what? Primarily entertainment. Is it right to take money from one person and give it to another just so that the consumer can watch the latest Batman movie over the internet instead of waiting a couple of days for a movie to show up in the mail? Is it also fair to expect the transport operators to pay for all of this entertainment's requirements on the system. Should companies like Netflix with network loads not pay anything to those that actually deliver their services? Nearly 6 months ago they were already 20% of the peak demand on the internet. http://www.readwriteweb.com/archives/netflix_streaming_accounts_for_20_of_peak_internet.php This means that every single internet provider out there had what amounts to a 20% increase in their upstream costs with NO increase in revenue to support it. Who will pay for this once things like Netflix and Hulu really get popular? The consumer is really the one that should pay those costs. Yet the national broadband plan, most press and certainly most consumers think that internet costs should come down even further! Can you just imagine everyone in the country switching to a nice shiny new Suburban and then expecting Texaco to pay for the extra gas they need? Why is the internet industry thought of any differently? Perhaps Netflix will make some real strides in compression technology or display capabilities. http://imgur.com/gallery/NvGso It would sure be nice if the whole discussion of how much capacity Netflix needs became more of a non issue. Thank you for your time, Marlon K. Schafer Owner Odessa Office Equipment (509) 982-2181 **************************************** If you worry about your competition getting funded and you not getting funded then you need to weigh in on this filing. This is, in my opinion, the biggest thing that the FCC has done since I've been a WISP. This will make my business or kill it. Nothing in between. Take care, marlon -------------------------------------------------------------------------------- WISPA Wants You! 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