Re: Net Neutrality...

[Brett Glass <nanog () brettglass com>]

At 05:06 PM 7/15/2014, Rubens Kuhl wrote:

> Do you see Connect America Fund, the successor to Universal Service Fund,
> as a threat to US rural WISPs or as the possible solution for them ?

It's a major threat to rural WISPs and all competitive ISPs. Here's 
why. The FCC is demanding that ISPs become "Eligible 
Telecommunications Carriers," or ETCs, before they can receive 
money from it. An ETC is a telephone company which is regulated 
under the mountain of regulations, requirements, and red tape of 
Title II of the Telecomm Act. It has to report to both state 
regulatory agencies AND the FCC. It's a classification that doesn't 
fit ISPs at all, but they would have to subject themselves to this 
heavy-handed regulation before they could get a dime from the fund.

The FCC just announced a "rural broadband experiment" in which it 
will fund ETCs, but not pure-play ISPs, to build out rural broadband; see

http://www.fcc.gov/document/rural-broadband-experiments-order

As part of this experiment, the FCC will pay telephone companies to 
overbuild us, even though the residents of the areas in question 
already have service. This is because, as far as the regulators are 
concerned, if they do not have their regulatory hooks in us, we 
don't exist and any service we provide does not count. The 
"experiment" also requires participants to tie up large amounts of 
money in escrow accounts so that they can obtain "letters of 
credit" guaranteeing performance.

All of this is, alas, the regulators' way of attempting to destroy 
those whom they cannot regulate.

IMHO, the USF is outmoded and should be disbanded.

--Brett Glass