We pushed for reducing these burdens (audited financials and LoC) last time. 
Before WISPA's advocacy, LoC must have been procured from a Top 100 bank, and 
audited financials had to be submitted before bidding began. We were able to 
get both of those changed to allow more financial entities to provide thr LoC 
(FCC said no on the performance bond), and get audited financials submitted 
only by winners.

We will try again this time, and will likely get a coalition of smaller 
providers associations together to try to push this.

For my edification, are you suggesting we de-prioritize spectrum advocacy in 
favor of this?

Claude Aiken
President & CEO

From: wireless-boun...@wispa.org <wireless-boun...@wispa.org> on behalf of 
Keefe John via Wireless <wireless@wispa.org>
Sent: Friday, July 12, 2019 9:03:18 AM
To: Mark Radabaugh; WISPA General List; policycommit...@wispa.org
Cc: Ken Hohhof via Members
Subject: Re: [WISPA] Draft Items for August 1 FCC Meeting

More funding is always welcome!

What can be done to ensure access to this funding by all WISPs?  The CAF II 
rules were so onerous that only a tiny percentage of WISPA members were able to 
participate.  This needs to change.  WISPA's #1 priority should be crafting 
rules that allow ALL WISPs to have a chance to participate.

The two biggest barriers to entry are:

Letter of Credit - These are very difficult to obtain, especially for the 
majority of our members.  Can we propose a bond as an alternative?

Audited Financial Statements - Audited financial statements cost $10,000 - 
$50,000 per year or more.  This is a huge hurdle for the majority of WISPs.  
Can we propose CPA-prepared financial statements and/or IRS tax return 
transcripts for small entities?

Keefe John
Direct: 262.345.5200
Ethoplex Business Internet
Signal Residential Internet


On Fri, Jul 12, 2019 at 7:52 AM Mark Radabaugh via Wireless 
<wireless@wispa.org<mailto:wireless@wispa.org>> wrote:
There are two upcoming items on the FCC’s August 1st meeting on items that will 
effect all WISP’s.    Please review the documents below.

Short summary:

477 Order - will revamp the 477 data collection process and information.   
Personally this is a good thing.

RDOF - This is the next $20,400,000,000 (20.4 Billion Dollars) that will be 
spend to overbuild your network if you are not currently providing 25/3 service 
& phone.

WISPA has time to meet with the commissioners and discuss up to the 25th.   A 
lot of effort has already gone into making sure that both of these are fair and 
open to all providers, not just the Telco’s.   There is no way to stop the feds 
from spending this money - it’s coming regardless of what we do.   Both 
political parties, the administration, and the FCC all want to spend money on 
rural broadband.

YOU HAVE TO DO YOUR PART to either position yourself to receive this funding, 
or prevent your competitors from getting it and overbuilding you.


Mark Radabaugh
WISPA Policy Committee Chair

Begin forwarded message:

From: "Coran, Steve via PolicyCommittee" 
Subject: [PolicyCommittee] Draft Items for August 1 FCC Meeting
Date: July 11, 2019 at 5:48:29 PM EDT
To: "'policycommit...@wispa.org<mailto:policycommit...@wispa.org>'" 
Reply-To: "Coran, Steve" 

Just released, below are links to draft items of interest for the FCC’s August 
1 open meeting.  We have the opportunity to meet with the Commissioners until 
the afternoon of July 25.  Would appreciate the Committee’s input on these 
soon.  Just released, and I have not had a chance to review these yet.

DRAFT Form 477 Order + FNPRM: 
DRAFT RDOF NPRM: https://docs.fcc.gov/public/attachments/DOC-358432A1.pdf

Stephen E. Coran
Lerman Senter PLLC<http://www.lermansenter.com/> |2001 L Street, NW, Suite 400 
| Washington, DC 20036
202-416-6744 (o) | 202-669-3288 (m) | 
sco...@lermansenter.com<mailto:sco...@lermansenter.com>  |@stevecoran – twitter

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