When your filing is done correctly you'll be directed to a page with info
similar to this:
ECFS Filing Receipt - Confirmation number: 2011422924356 Proceedings
Name Subject
10-90 In the Matter of Connect America Fund A National Brooadband Plan
for Our Future High-Cost Universal Service Support. .
09-51 In the matter of a National Broadband Plan for Our Future.
07-135 In the Matter of Establishing Just and Reasonable Rates for
Local Exchange Carriers. .
05-337 In the Matter of Federal -State Joint Board on Universal
Service High-Cost Universal Service Support. .. .
01-92 Developing a Unified Intercarrier Compensation Regime.
96-45 FEDERAL-STATE JOINT BOARD ON UNIVERSAL SERVICE
03-109 In the Matter of Lifeline and Link-Up
Contact Info
Name of Filer: Marlon K. Schafer
Email Address: [email protected] Address
Address Line 1: box 489
City: Odessa
State: WASHINGTON
Zip: 99159 Details
Type of Filing: COMMENT
Document(s)File Name Custom Description Size
USF reform platform.doc Resending wtih proceeding's indluded on the
doccument. 155 KB
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status of your filing:
http://fjallfoss.fcc.gov/ecfs/comment/confirm?confirmation=2011422924356
For any problems please contact the Help Desk at 202-418-0193.
----- Original Message -----
From: "Marlon K. Schafer (509-982-2181)" <[email protected]>
To: <[email protected]>
Cc: "WISPA General List" <[email protected]>
Sent: Friday, April 22, 2011 10:07 AM
Subject: [WISPA] USF comment deadline is near
> 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
>
>
>
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