Net Neutrality...

Scott Helms khelms at
Wed Jul 16 12:20:23 UTC 2014

Here is the actual document for defining what the federal government
considers to be an ETC.  Keep in mind that state level boards actually make
the designation based on these, and potentially state level regulations, so
there is some variation based on the state(s) you operate in.  Having said,
that the requirements have not seemed overly onerous to us where we have
considered them, which certainly isn't all 50 states.

"20. As described above, ETC applicants must meet statutorily prescribed
requirements before
we can approve their designation as an ETC.46 Based on the record before
us, we find that an ETC
applicant must demonstrate: (1) a commitment and ability to provide
services, including providing
service to all customers within its proposed service area; (2) how it will
remain functional in emergency
situations; (3) that it will satisfy consumer protection and service
quality standards; (4) that it offers
local usage comparable to that offered by the incumbent LEC; and (5) an
understanding that it may be
required to provide equal access if all other ETCs in the designated
service area relinquish their
designations pursuant to section 214(e)(4) of the Act.47 As noted above,
these requirements are
mandatory for all ETCs designated by the Commission. ETCs designated by the
Commission prior to
this Report and Order will be required to make such showings when they
submit their annual
certification filing on October 1, 2006. We also encourage state
commissions to apply these
requirements to all ETC applicants over which they exercise jurisdiction.
We do not believe that
different ETCs should be subject to different obligations, going forward,
because of when they
happened to first obtain ETC designation from the Commission or the state.
These are responsibilities
associated with receiving universal service support that apply to all ETCs,
regardless of the date of
initial designation."

Its also worth noting that you do _not_ have to offer voice or life line
services according the federal guidelines.

"3947 U.S.C. § 214(e)(1)(A). The services that are supported by the federal
universal service support mechanisms
are: (1) voice grade access to the public switched network; (2) local
usage; (3) Dual Tone Multifrequency (DTMF)
signaling or its functional equivalent; (4) single-party service or its
functional equivalent; (5) access to emergency
services, including 911 and enhanced 911; (6) access to operator services;
(7) access to interexchange services; (8)
access to directory assistance; and (9) toll limitation for qualifying
low-income customers. See 47 C.F.R. § 54.101.
 While section 214(e)(1) requires an ETC to “offer” the services supported
by the federal universal service support
mechanisms, the Commission has determined that this does not require a
competitive carrier to actually provide the
supported services throughout the designated service area before
designation as an ETC. Federal-State Joint Board
on Universal Service; Western Wireless Corporation Petition for Preemption
of an Order of the South Dakota
Public Utilities Commission, Declaratory Ruling, CC Docket No. 96-45, 15
FCC Rcd 15168, 15172-75, paras. 10-
18 (2000), recon. pending (Section 214(e) Declaratory Ruling)."

That was once a requirement that kept most WISPs from being able to
participate, but is no longer.  I don't personally see a large hurdle for
WISPs in the federal language and I work with 4 I know of that have ETC
status in 3 different states.

Scott Helms
Vice President of Technology
(678) 507-5000

On Tue, Jul 15, 2014 at 9:53 PM, Bob Evans <bob at>

> I think your point needs to be explained. Because anything gnment is
> riddled will large carrier benefiting. Look at the school discounts for
> internet services...pretty much just for LECs.
> Thank You
> Bob Evans
> > I have stayed out of much of this, but can't help myself.   Along with
> > everything else, you are seriously misinformed about the process of
> > becoming an ETC.   It is not onerous.   Please stop.   You are giving
> > rural
> > ISPs a bad reputation.
> >
> >
> > On Tue, Jul 15, 2014 at 7:57 PM, Brett Glass <nanog at>
> wrote:
> >
> >> 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
> >>
> >>
> >>
> >> 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
> >>
> >>
> >>
> >>
> >
> >
> > --
> > Fletcher Kittredge
> > GWI
> > 8 Pomerleau Street
> > Biddeford, ME 04005-9457
> > 207-602-1134
> >

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