Rick, I thought that we did this task, but please tell me how I can
confirm. - Cliff





On 11/28/12 4:45 PM, "Rick Harnish" <rharn...@wispa.org> wrote:

>Fred,
>
>I assure you the WISPA FCC Committee is indeed on this.  You make great
>points and we appreciate your review. You are definitely correct, that
>WISPs
>NEED to get on the National Broadband Map NOW!  Those that don't will be
>suffering from subsidized competition.  Anyone who does not know who to
>contact, drop me a line.  I have contacts now for all states.  Maybe, I
>can
>get that list up on the WISPA website under WISP Resources.  There is one
>now, but it is not complete.  I now have 4-5 names per state I believe.
>
>The guys at towercoverage.com are making it easy and inexpensive to make
>your maps and get them uploaded to the National/State Maps as well.
>
>Where there is a Wisp, there is a way!
>
>Respectfully,
>
>Rick Harnish
>Executive Director
>WISPA
>260-307-4000 cell
>866-317-2851 Option 2 WISPA Office
>Skype: rick.harnish.
>rharn...@wispa.org
>adm...@wispa.org (Trina and Rick)
>
>
>
>
>
>> -----Original Message-----
>> From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
>> Behalf Of Fred Goldstein
>> Sent: Wednesday, November 28, 2012 5:17 PM
>> To: wireless@wispa.org
>> Subject: [WISPA] FCC Connect America Fund -- It's Baaaackkkk!
>> 
>> 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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