For a one time payment of $775 per home, I can connect ALL the unconnected homes in my county...

But that is not how it works, is it?

I'll be buried in red tape and paper for the rest of my life, right?  And, of course, since I took their money, they can now tell me how to run my network and so on...

I'd be happy if I can just block everyone else in my county from getting it.

--


On 11/28/2012 5:16 PM, Fred Goldstein wrote:
The FCC's home page ( transition.fcc.gov ) has an item about Connect 
America Fund, posted with no description.  This turns out to be a 
further NPRM about Phase I funding.

As you may recall, CAF Phase I was the short-term (2012) step that 
offered $775 per line to price-cap ILECs (the Bells and other big 
ones) to bring "broadband" to "unserved" areas that they otherwise 
wouldn't. It was budgeted for $300M but only about $115M was claimed, 
mostly by Frontier.  The Bells didn't take much.  CenturyLink however 
whined that the definition of "served" should be changed to 
specifically exclude areas WISPs, so they could get subsidy money to 
overbuild existing WISPs.  The FCC turned that one down, though 
CenturyLink did take money for some other areas.

The new Further Notice of Proposed Rulemaking:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-138A1.pdf 
asks what to do about the remaining Phase I money.  While they could 
of course just not spend it, lowering the USF tax (now around 17%!), 
that's not one of the two options they are proposing to select 
from.  One option is to simply add this funding to Phase II, which 
begins in 2013.  Phase II allows for competition in the awarding of 
funds; there will be a reverse auction, and the bidder who asks for 
the least subsidy money gets it.

Most of the FNPRM, however, is devoted to the other option, 
essentially a second round of Phase I.  They propose changing Phase I 
rules to encourage the ILECs to take more money.  There are a lot of 
questions about details, but the basic ideas are along these lines:

1)  Redefine "unserved" to be anywhere that doesn't have 4/1 service, 
vs. 768k/200k in the first round.  This would be based on the 
National Broadband Map, using 3M/768k as a surrogate for 4/1.  (The 
agencies apparently hadn't agreed on speed tiers.)  So an area served 
by a WISP at 2M/500k, or by Canopy 100s, would be deemed "unserved", 
since it's not 4/1.

2)  Allow challenges to the national map.  So if an ILEC thinks an 
area is unserved even if a WISP claims it's served, they can argue 
the matter to the FCC.  This works both ways, so I suppose an ISP 
could claim that the map omitted them by mistake.  But it points out 
that a WISP SHOULD MAKE SURE ITS COVERAGE AREAS ARE ON THE 
MAP!  (Just a little shouting in case anyone didn't hear it.)

They are supposed to come out with a list of unserved areas (census 
blocks0 next month.

There are some other interesting details.  Phase I awards are $775 
per new customer.  That number may be adjusted in this second 
round.  Also, in areas served by (rural, subsidized) Rate of Return 
Carriers, the subsidy number comes from the FCC's High Cost Proxy 
Model.  In Phase 2, these areas get subsidized according to a more 
elaborate cost model now being debated.

There is also the possibility that the Phase I recipient may have to 
build a certain amount of "second mile" (basically, exchange feeder 
fiber) as well as "last mile" distribution.  But there's no clear 
obligation to make this available at wholesale, which would be nice. 
They also ask about how to handle builds that have to go through 
served areas in order to reach unserved ones.  So even if you're on 
the map, you could get overbuilt by the ILEC.

Note that a Phase I awardee must apply to serve specific unserved 
areas and applies to serve a certain number of unserved subscribers, 
*but* they do not actually have to use it where they said they 
would.  The applications are merely suggestions of where they might 
find their unserved customers.   They can actually spend it 
elsewhere, so long as they get at least one customer added per $775.

An open question is that several awardees said that their proposed 
service areas are confidential. The FCC has not decided if this is 
acceptable, so it's an open question now.  I'd think that a WISP 
should be allowed to know if the ILEC plans to build subsidized 
service to an area they're thinking of building to, so this should be 
public information, not confidential.  So tell the FCC!

I am hoping the FCC Committee and others interested will take note of 
this.  It probably won't reach the Federal Register for a while, and 
then the 30 day Comment period begins.

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

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