Holy Massive Bureaucratic Report IP Man!

David Byrd : Byrd's Eye View
David Byrd
Chief Marketing Officer for ANPI

Holy Massive Bureaucratic Report IP Man!

Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking adopted February 8, 2011 and released February 9, 2011 is one gigantic tome. Even the rules regarding commenting require a moment or two of thought, check out the following:

Comment Date on Section XV: [30 days after date of publication in the Federal Register]

Reply Comment Date on Section XV: [45 days after date of publication in the Federal Register]

Comment Date on the Remaining Sections: [45 days after date of publication in the Federal Register]; Comment Date of State Members of the Federal-State Joint Board on Universal Service: [59 days after date of publication in the Federal Register]; Reply Comment Date on Remaining Sections: [80 days after date of publication in the Federal Register]

Got it! The idea that I could read this and do my regular job was an incredible faux pas on my part. The Introduction and Executive Summary are a mind boring 18 pages leaving out much of the necessary detail for me to properly summarize the Notice’s impact. However, with over 700 relevant paragraphs, sections, and FCC member comments, it became very clear why companies pay others to read and digest these documents. Therefore, I have discovered I am not up to the task.

Obviously, the Notice identifies certain changes the FCC would like to make to the process of funding the Universal Service Fund (USF) and the role of the Federal Government and the States. To that end the key element is to eliminate both the USF and InterCarrier Compensation (ICC) and create a new fund, the Connect America Fund (CAF). No wonder these guys were unanimous for the first time in ages, they now have a chance to create a whole new mess. Okay, that wasn’t fair. Some of the suggested rules look promising. It would be good to end incentives for Traffic Pumping or Access Stimulation. One rule change would be to replace the current per minute charge with an actual cost to provide service fee.

The Notice’s focus is on expanding broadband to rural and underserved areas. As I have stated in previous blogs, I believe that priority is wrong. We should first ascertain and ensure that the country has competitive broadband services established for the 80% of the population that is most easily served. The US ranks sixth among the G7 and is at risk of falling to seventh when Access, Speed and Price (ASP) are compared. This includes the broadband that is available in our cities and metropolitan areas.

The section on VoIP that will most affect Broadvox, our partners and competitors, I have not read yet. Perhaps, I am afraid of reading the bad, or at least, what I consider may be bad. I will do my best to cover it on Friday. Help me IP Man!

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