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Re: EFF Call for sign-ons: ISPs, networking companies and engineers opposed to FCC privacy repeal


From: Fletcher Kittredge <fkittred () gwi net>
Date: Wed, 29 Mar 2017 16:43:22 -0400

The vast majority of obligations you describe continue to exist and don't
have anything to do with this bill.

On Wed, Mar 29, 2017 at 4:02 PM, Mark Radabaugh <mark () amplex net> wrote:


On Mar 29, 2017, at 9:59 AM, Joe Loiacono <jloiacon () csc com> wrote:

Lowering barriers to entry is where the next political focus should be.

Joe Loiacono


And there you have much of the problem with this privacy bill.

Read the actual Report and Order:  https://apps.fcc.gov/edocs_
public/attachmatch/FCC-16-148A1.pdf <https://apps.fcc.gov/edocs_
public/attachmatch/FCC-16-148A1.pdf>

219 pages

You want to start a competitive ISP these days?   Make sure you:

Incorporate your business
Obtain Liability, Workers Comp, Unemployment, Auto Insurance
Comply with the FCC Privacy Act (short reading, requires considerable
investment in tracking opt in, opt out, privacy policies)
File the mandatory FCC 477 filings twice a year with detailed information
on the geolocation of all of your customers and service area.
If offering VoIP service file your 499-A and Quarterly 499-Q’s with the FCC
Draft your “Open Internet Disclosure Statement”, pay a FCC lawyer a couple
grand to renew it, make sure it’s prominent on your website
Build your website
Obtain bandwidth and IP, fill out your ARIN information.
Make up your “Consumer Label” for Broadband:
https://www.fcc.gov/consumers/guides/consumer-labels-broadband-services <
https://www.fcc.gov/consumers/guides/consumer-labels-broadband-services>
(probably need a lawyer for this too..)
Pay the lawyer to write your “Terms of Service” so that you have at least
some chance of surviving the lawsuits
Implement your CALEA plan and file that paperwork with the FBI so they can
find you
Register with the Copyright office so that you can deal with DMCA notices.
Establish your copyright policy and procedures.  Have your lawyer review
it.
Make sure you comply with 18 USC 2258A regarding reporting and
registration for kiddie porn, train your employees
Make sure you have a CPNI policy, training, and report to the FCC yearly
Implement and file your Section 255 “Disability Rights” policy and make
sure you file yearly with the FCC your information

Slap up a Ubiquiti access point and you can now make millions of dollars
in short order.

I’m sure I forgot a few things like “build your network”, but that’s
simple.

Mark




-- 
Fletcher Kittredge
GWI
207-602-1134
www.gwi.net


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