Agreed on the bond issue.

If we fail to see movement on the Letter of Credit we could approach the
SBA about offering a solution.  They already have an export Letter of
Credit program.  Could something be modified or created for broadband

A coalition of WISPs who'd like to participate in this funding program is
essential.  Can WISPA send out a survey so we can get accurate numbers on
how many WISPs would participate in this funding program?  It might be
powerful to say "We have 500 members interested in participating in FCC
funding programs, however, only 20 were able to participate in CAF II due
to X, Y, and Z."

It is worth at least making it known in our filings that requiring audited
financials makes these programs inaccessible to many of our members.
What's their rationale in requiring audited financials instead of tax
returns and transcripts.  Tax returns are good enough for lending from
other agencies, such as the SBA. How does the FCC determine what
constitutes a financially sound company anyways?  Are there guidelines or
is it arbitrary?

How about an exemption to the audited financials for companies who've
recently gone through the underwriting process to obtain financing via
another government agency like the USDA or SBA.  Surely these are
creditworthy companies in the eyes of the Federal government.


Keefe John
Direct: 262.345.5200
Ethoplex Business Internet
Signal Residential Internet

On Fri, Jul 12, 2019 at 9:45 AM L. Elizabeth Bowles <>

> From my perspective, taking another run at eliminating the letter of
> credit requirement should be a priority. It is a huge barrier to smaller
> companies seeking this funding, and the policy the FCC is trying to
> accomplish can be met with a bond.
> I agree we need a coalition of small WISPs to advocate for this, but we
> also should leverage the experience of the WISPs who have already received
> CAF funding - that first-hand perspective will be helpful in showing that
> the LOC is burdensome in reality, not just hypothetically.
> As for the audited financials, I don’t think any energy should be spent on
> trying to eliminate that requirement because we are likely to fail. USDA
> also requires audited financials for many of its grants and loans, and
> worse, they require the last two years. It is hella expensive, but I don’t
> think we will win this argument, and any energy spent would be better spent
> elsewhere.
> Best,
> Elizabeth
> Sent from my iPhone
> On Jul 12, 2019, at 9:23 AM, Claude Aiken <> wrote:
> 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:* <> on behalf
> of Keefe John via Wireless <>
> *Sent:* Friday, July 12, 2019 9:03:18 AM
> *To:* Mark Radabaugh; WISPA General List;
> *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
> Ethoplex
> Direct: 262.345.5200
> --------------------
> Ethoplex Business Internet
> Signal Residential Internet
> On Fri, Jul 12, 2019 at 7:52 AM Mark Radabaugh via Wireless <
>> 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
>> Mark Radabaugh
>> WISPA Policy Committee Chair
>> 419-261-5996
>> 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: *"''" <>
>> *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:
>> Stephen E. Coran
>> Lerman Senter PLLC <> *|*2001 L Street, NW,
>> Suite 400 *|* Washington, DC 20036
>> 202-416-6744 (o) *|* 202-669-3288 (m) *| *  
>> *|*@stevecoran
>> – twitter
>> _______________________________________________
>> Wireless mailing list
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