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Wednesday, September 12, 2007


I was just looking at the PowerPoint slides from an ex parte discussion that Embarq made at the FCC. It's all about the E-Rate, so of course I have opinions I'd like to share. Here are the main topics I teased out of it.

Embarq makes the case that in order to get funding from the E-Rate, VoIP vendors should have to follow telecom regulations. Well, yeah, except that VoIP is currently under Internet Access. I'm all for making VoIP a "basic" Telecom Service (and said so in my ESL comments this year), but until that happens....

Embarq wants to tighten up the certifications required of service providers. I'm OK with all their suggestions except the last one: they suggest that all service providers be required to file a Form 473 (the SPAC, which service providers file annually) before taking part in bidding. That might be reasonable if bidding took place close to the start of service, but since bidding has to start at least 6 months before service can start, it seems odd to force service providers to file an annual certification half a year before the annum.

This one I like. Basically the idea is to have more information displayed about service provicers on the USAC Web site.

I don't work for service providers, so I don't know what effect these suggestions would have.

Competitive Bidding Impropriety:
Embarq made a good suggestion and a bad suggestion. The good suggestion: consultants should have to certify that they are not affiliated with any service providers. The bad suggestion: No school district employee or board member should be allowed to serve on the board of any service provider in that state. Just look at the WiscNet travesty, where a bunch of school districts had people on the board of a cooperative that provided Internet access, and got COMADed.

Internet Access Usage:
I'm on Embarq's side here. The slide doesn't say so, but I suspect that they are aiming at applicants who set up a WAN, then hook that WAN to the Internet, and call it all Internet Access. It's not, even under current rules, but the rules need to be clearer on that.

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