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Beyond “The Order” – The New Regulatory Horizon for Rural Carriers. Bob Schoonmaker, President GVNW Consulting, Inc. August 7, 2012. Overview. Long-term FCC objectives Items implemented Items not implemented Longer-term impact of items implemented. Long-term FCC Objectives.
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Beyond “The Order” – The New Regulatory Horizon for Rural Carriers Bob Schoonmaker, President GVNW Consulting, Inc. August 7, 2012
Overview • Long-term FCC objectives • Items implemented • Items not implemented • Longer-term impact of items implemented
Long-term FCC Objectives • Bill and keep for access “compensation” • Increase broadband availability in rural areas (including price cap rural areas) • Increase broadband capability (speed) • Continue to encourage replacement of wireline service with wireless • Budget control on USF – no increase • Transform TDM network to IP • Efficiency
Steps toward bill and keep • Implemented first step for terminating rates – end game • Price cap companies by 2018 • ROR companies by 2020 • Originating rates – FNPRM – unknown • IntraMTA CMRS – Effective July 1, 2012 • Recovery Mechanism – PC – 6 years, ROR 10+ years
Increased Broadband Availability • Price Cap Carriers • Frozen support • 3 year phase in - 2013 – 2016 to 100% use for broadband in unserved areas • CAF I - $300 million incremental to unserved broadband locations - $775/location • CAF II – Start 1/1/2013 or later – Initially model based – Reverse auctions in five years
Increased Broadband Availability • Rate of return • CAF for broadband delayed until FNPRM • ROR carriers have responsibility to provide 4 Mbps/1 Mbps upon reasonable request
Increased Broadband Speed • Initial requirement - 4mbps/1mbps “actual” • ETC reporting requirement starting by July 1, 2013 (actual measurements) • CAF II – indicates a future requirement potential of 6 mbps/1.5 mbps
Broadband Provisioning • FCC Projection – US Avg • 4 Mbps in 2015 • Akami - 4th Qtr. – 2011 report - US Avg. - 5.8 Mbps
More wireless • “White spaces” availability • Moves to provide more spectrum (500 MHz, 300 MHz in 5 years) • Mobility I fund • Reverse auction – late 2012 • 3G or greater to areas unserved by 3G • Service over 75% of road miles in area • $300 million one-time support • Broadcast spectrum voluntary auction
Budget Control • FCC implemented budget controls for $4.5 billion – Specified amounts by fund type • Core Wireless reserve to help fund overruns • If less than quarterly amount, hold the remainder in reserve • USAC reports to FCC within 75 days of how to correct overrun
Transform TDM network to IP • Transition ICC to bill and keep • Facilitate IP to IP interconnection • FNPRM – Should CAF recipients be required to offer IP to IP interconnection? • Some have proposed specific “shut-off” dates for TDM
Efficiency • Corp. Oper. Exp. Cap for HCL and ICLS • Regression analysis for HCL and ICLS • $250/month/line cap on ROR USF • Only one recipient per area – phase out of CLEC and CETC support • Reverse auctions for some funds • Price cap existing funds to broadband construction in unserved areas
Items Implemented • ETC Reporting Requirements • Urban rate floor at $10 • Corporate Operations Cap–HCL and ICLS • Intrastate Access Reductions – Step 1 • $250/month/line USF limit • Regression analysis for HCL • Recovery Mechanism and ARC rates • CLEC USF Phase-out
Items Implemented (cont.) • LSS shift into Recovery Mechanism • Safety Net Additive-elimination begun
Items Yet to be Implemented • Regression analysis for ICLS • Change in rate-of-return • Broadband CAF for ROR companies • Transition of originating and transport access to bill and keep • Phase out of Recovery Mechanism • IP to IP interconnection • Broadband speed testing
Items Yet to be Implemented • Loss of USF where unsubsidized competitor serves substantial portion of area (but less than 100%)
Short term Focus–ETC Reports • ETC Requirements – July 1, 2013 • Five-year plan including: • Maps showing planned upgrades (by wire center or census block) • Describe with specificity planned improvements and areas • Estimate the area and population that will be served by upgrades • Service to Anchor Institutions • May want to include appropriate caveats related to funding
Short term Focus–ETC Reports • ETC Requirements – July 1, 2013 – (most by voice and broadband separately) • Outage Reporting • Complaints • Network Performance Reports (not defined) • Unfulfilled requests for service • Price offerings • Audited financial Reports • Lines under Urban Benchmark-$14-6/1/2013
Longer Term Focus • Financial Planning • Operating expense control • Capital expense control – efficiency • Broadband expansion • Area and customers covered • Capability • Area covered by an unsubsidized competitor (75% of households possibly)
Impacts – Corp. Ops. Cap • Impacts vary by company size • Current difference between actual & max • Examples: • Assume 3.0% growth in corp. op. expense • Assume -5.0% loss in access lines
Regression Analysis • April 25, 2012 – Impacts only 100 companies instead of 400+ - (2 in AR, 1 in MO) only two parameters – Op. Exp. and Cap. Exp. • Continued industry concern re: unpredictability and variability, some coefficients don’t comport with reason • Need to verify inputs, particularly sq. miles, exchange boundaries, & road miles
Op. Expense – Possibilities • Consortiums and/or consolidations • Shared management • Shared technicians • Past due or early retirements • Depreciation expense (cap. in regression) • Employee benefits • Energy use
Op Expense – Term Access for LD • July 3, 2012 – Missouri (est.) • AT&T - $0.015 reduction – 49% • Windstream - $0.016 reduction – 22% • CenturyLink - $0.03 reduction – 42% • RLECs - $0.02 to $0.06 – 20% to 40% • July, 2013 – Similar $ amounts – larger % reductions from 2012 rates
New Revenue Sources • Increase Broadband penetration • Broadband speed and “volume” increases • Expand technology offerings • Backhaul for wireless (incl. mini-cell sites) • “White Spaces” offerings • “Smart meter/energy control” • “Smart home” offerings
Unknown Impacts • Regression analysis – longer term • Rate of return reduction • Originating and Transport Access • ROR CAF for Broadband • Loss of USF in competitive areas • Competition from cable, wireless & satellite • Changes in technology
10th Circuit Court of Appeals • Several issues under appeal • Smith vs. Illinois Bell • Bill and Keep • Regression analysis • Preemption of states • Court denied FCC request to delay until FCC answered all questions • Briefing schedule for most of the remainder of 2012
Future Regulatory Horizon • Uncertainty – unanswered questions • Financial challenges from current revenue sources • Need to move toward a broadband service model • What will it the future horizon be like?
THANK YOU!! HAVE A GREAT DAY!! • Bob Schoonmaker • 719-594-5809 • bschoonmaker@gvnw.com