Is there any provision in the document for reducing funding in the future as areas get overbuilt? Or are we really looking at a 6-8month land grab?
On 11/21/11 7:04 PM, Tom DeReggi wrote: > Yes agreed, its not nearly as bad as it could have been. But I still say > ARRGGG! > >> Price Cap Carriers will be offered $775 per >> line to add 4/1 broadband serivce to "unserved" areas > Thats much better for WISPs than if they agreed to pay our competitors > greater than $10,000 per sub for FIOS like Fiber. > WISPs atleast have a chance to compete against 4/1 services, and ILEC > reimbursement now inline with what it would cost a WISP to deploy, and not > to much more.. > >> So this might be a good time to make sure the mappers >> are aware of your service areas, or to think about short-term service >> expansion. > yeah, you gotta love help that says.... "WISPs Go hurry up and build a > network at your cost quickly, we wont pay you, but if you dont build quick, > we'll pay your competitor instead." > (Sarcasm) > >> The date by which you must be on the map isn't set yet, >> but it's presumably in 1H2012. > Well, that is good, that they are looking at mapping for disqualification. > Also good that not all WISPs reported their coverage in the past. > The rules are good incentive for rural WISPs to report now. Those rules may > not have ever made it into the FCC rules, without the insight that it would > be incentive to get reamining WISPs to report. If WISPs had already > reported, why would the FCC have needed to include consideration and > incentive in the new rules? > >> Phase II starts in 2013. For this, Price Cap Carriers will be >> offered support based on a cost model that the FCC will create in >> 2012. Once the model is complete, the ILEC will decide if it wants >> to take that support for its territory on a state-by-state (all of a >> state or nothing) basis. > Thats the bad part.... Only a select few monopoly like companies can afford > to do complete State wide deployment, even when subsidized. > So basically, the FCC is saying.... Time to force the Monopolies to serve > ALL Americans, and leave no unserved areas left for the competitive > property. > Rather than fix the problem, the FCC is trying to secure that the remaining > 25% of America will have subsidized competitors to private investment. > There is no longer a consideration for the best party to serve a specific > area. Preferrence is given to the big boy. > no different than Auctions, where only the most fortunate and dominant > player can win. > The biggest flaw in telecom policy is the concept of Serving everyone or no > one. Its the founation for every monopoly cable franchise type agreement, > and now being replicated into CAF. Forcing acceptance on a complete > state-by-state basis in my opinion is a major loss for the industry. Because > the mind set hasn't changed from old telecom. They are still thinking "state > regulation" and "utility electricity", where there is only ONE primary > provider per state. > > Although, I will admit, these funds are targeted to UNSERVED areas, so > atleast they aren't giving the whole state away. Just the least desirable > part of the state for wireline to serve. > > They are saying..... "WISPs, if you can serve someone new this year, great, > go for it, its your last chance, before we give the market to someone else." > >> A separate Extremely High Cost fund will allocate up to $100M/year >> for locations too costly (by the model) to serve via the standard >> subsidy. This will be separately bid, and it's assumed that fixed >> wireless and satellite will be the mostly likely technologies. So >> this could allow some subsidies to rustic-but-Bell-area WISPs. > Yes, that may be good for WISPs. > Or, better positioned ILECs to become WISPs. > >> So on balance, the FCC has done a lot less harm to the rural WISP >> community than it could have, while still encouraging ILECs to deploy >> more broadband via subsidies. > I fully agree with your conclusion. > Realistically, that could be considered a victory, for Rural WISPs. > > With that said, I would have preferred the FCC to have the balls to name the > new program what it really was... > They could have called it the "CAIF" - Connect America to ILECs fund. or > "KCC-CAF" - Kill Competiton and Choice, but Connect America Fund.". > > The interesting part will be to see how many RURAL ILECs will choose to > accept $768 per sub, to build out to all remaining Americans in their state. > What else will be interesting will be to see if, the RBOC fund recipients > really do what they are obligated to do afterwords. > > I think it is an ambitious plan to try to get the remaining American's some > form of broadband, which outcome would likely be good, I just cant say I > agree with the method. > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > ----- Original Message ----- > From: "Fred R. Goldstein" <fgoldst...@ionary.com> > To: "WISPA General List" <wireless@wispa.org> > Sent: Monday, November 21, 2011 6:02 PM > Subject: [WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs > > >> On Friday, the FCC finally released the Order in their Intercarrier >> Compensation and Universal Service Fund docket. The executive >> summary had come out with the Adoption at last month's FCC Public >> Meeting, but the 759-page (!) Order took a while to finish. >> >> The results, from a WISP perspective, are not nearly as bad as could >> have been. The FCC has taken safeguards to make it easier for an >> unsubsidized WISP to prevent subsidized competition from an incumbent LEC. >> >> The high-cost portions of the Universal Service Fund are being >> restructured into the Connect America Fund. This will come into >> being in three phases, each with different rules for Price Cap >> Carriers and Rate of Return Carriers. About 95% of phone lines are >> in the former category; the latter are basically small rural carriers >> who depend upon USF. >> >> Phase I is just 2012. Price Cap Carriers will be offered $775 per >> line to add 4/1 broadband serivce to "unserved" areas that they >> weren't otherwise going to serve. They can choose how many lines >> this applies to. If the location is "served" on the National >> Broadband Map, or if the ILEC *knows* it's served by an unsubsidized >> competitor, it's off limits. I think this must be at least 768k >> fixed service. So this might be a good time to make sure the mappers >> are aware of your service areas, or to think about short-term service >> expansion. The date by which you must be on the map isn't set yet, >> but it's presumably in 1H2012. >> >> Phase II starts in 2013. For this, Price Cap Carriers will be >> offered support based on a cost model that the FCC will create in >> 2012. Once the model is complete, the ILEC will decide if it wants >> to take that support for its territory on a state-by-state (all of a >> state or nothing) basis. Again, only unserved areas will get >> support, though an ILEC can use support to build common plant in an >> area that is more than 50% unserved. So a new DSLAM that covers 40% >> unserved would not be covered, but ont that covers 60% unserved would >> be. So again it's important for WISPs to make their presence >> known. If the ILEC turns down the state, USF support goes to the low >> bidder. >> >> Phase III starts in 2018, and will be entirely bid-based, but the >> details will be worked out in the future. >> >> A separate Extremely High Cost fund will allocate up to $100M/year >> for locations too costly (by the model) to serve via the standard >> subsidy. This will be separately bid, and it's assumed that fixed >> wireless and satellite will be the mostly likely technologies. So >> this could allow some subsidies to rustic-but-Bell-area WISPs. >> >> The FCC notes that while this gives ILECs first dibs on funding, it >> also takes away Price Cap Carrier USF from areas served by >> unsubsidized competitors, so WISPs could theoretically come out >> better under the new rules. >> >> Now here's a catch: "Unsubsidized competitor" is defined as a >> provider of both voice and broadband service. It's not entirely >> obvious (you try parsing 759 pages of FCC-speak this quickly... ;-) ) >> if that applies to the Price Cap Carrier model, or just the rural >> Rate of Return case, since the PCCs already offer unsubsidized voice >> across most of their territories, and the map isn't about voice. In >> the rural Rate of Return Carrier case, voice will be more >> important. This does not mean that the WISP must be a CLEC per se; >> it might be high-quality (QoS) VoIP offered in conjunction with a >> CLEC who has local numbers, for instance. But for some ISPs, this >> might be a good time to start thinking about adding voice >> service. (My talk at FISPA last month was about the case for whether >> an ISP should start up a CLEC.) >> >> In areas served by rate-of-return carriers, the new rules phase out >> (over 3 years) all USF support to an ILEC that is 100% overlapped >> (voice and broadband) by an unsubsidized carrier, typically >> cable. If there is less than 100% overlap, then support will be >> reduced, but the actual methodology is left to be determined via the >> Further NPRM. >> >> So on balance, the FCC has done a lot less harm to the rural WISP >> community than it could have, while still encouraging ILECs to deploy >> more broadband via subsidies. >> >> -- >> Fred Goldstein k1io fgoldstein "at" ionary.com >> ionary Consulting http://www.ionary.com/ >> +1 617 795 2701 >> >> >> >> -------------------------------------------------------------------------------- >> WISPA Wants You! 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