The current FCC rules per November's CAF order allow ILECs to be 
subsidized to provide "broadband" unless there is an "unsubsidized 
competitor" who provides both voice and data service.  Jack Unger has 
written an excellent petition to the FCC to change that to allow it 
to be "unsubsidized competition", wherein the data provider needn't 
be the voice provider.  But there's no guarantee that the FCC 
(currently down to three seated Commissioners) will take such action.

A WISP can provide the needed voice service via VoIP.  It need not be 
a certificated CLEC.  However, to get the VoIP service and local 
numbers, it still needs a CLEC with a connection to (at minimum) the 
tandem switch serving its area.  In some rural areas, this might not 
be available.  So the WISP might need to create a CLEC, or at least 
get one to serve its area.

While the traditional approach to starting a CLEC requires a 
"switch", that rather costly item, which a lot of ISPs don't want to 
have to manage, can be finessed by using a remote gateway.  At least 
one CLEC I'm working with offers a remote "rent a call agent" 
service, where there Class 4/5 call agent, which is equipped with 
Signaling System 7 (a big expense), can serve gateways anywhere, 
passing signaling (H.248) across the Internet or, ideally, a VPN.  So 
the rural CLEC just has a media gateway and SBC, and orders trunks 
into the local central office.  The VoIP side of the gateway then 
feeds the subscribers.

I'm trying to assess whether it's worth anyone's pursuing to set this 
up as an offering for WISPs. Does anyone see a market for this type 
of service?  Would it help anyone meet the "unsubsidized competitor" 
requirement?  Thanks...

  --
  Fred Goldstein    k1io   fgoldstein "at" ionary.com
  ionary Consulting              http://www.ionary.com/
  +1 617 795 2701 



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