https://ecfsapi.fcc.gov/file/10616167661646/satchell.answers2questions.NPRM....
Warning: this is 63 pages long, and dull as dishwater. It does have a few color pictures, though. And one comic strip. Summary: fix the statutes (thank you Sen. Stevens, for the junk!) and apply Title II only to monopoly Internet access service providers. I had sent this notice to a listserve (of which I'm a subscriber) of telecomm policy people, and I'm getting a whole lot of pushback. So I thought, why should NANOG lose out on the fun? So, instead of you hearing about this in the sweet bye and bye, I'll get the firestorm over with now, rather than stretching this out for three months. (I'm on this listserve, too.) And if you think my ideas are bad, perhaps you will propose a better suggestion to the FCC about the subject.
On Sat, Jun 17, 2017 at 9:54 AM, Stephen Satchell <list@satchell.net> wrote:
It does have a few color pictures, though. And one comic strip.
Upvote for use of 'caisson'. There is at least one thing that Sen. Ted Stevens got right; in the fiber era, the Internet really *is* a series of tubes. I appreciate that a target of 35,000 per county or "county equivalent" (parish, borough?) is just a number — but I believe I would prefer a metric keyed to actual geographic population density rather than to political or municipal boundaries qua boundaries. At least it seems to me that you are wanting to encourage rural development, given that the current broadband 'divide' is largely a rural vs. urban one, according to the 2016 Broadband Progress Report. Natural monopolies worked for electrification. Do you anticipate Title I providers as being sufficient to the task of narrowing this divide, with or without a federal incentives program? Historically, federal incentives have largely gone to Title II providers or their affiliated ISPs, if I understand the math correctly. https://www.brookings.edu/blog/the-avenue/2017/02/13/in-infrastructure-plan-... Jeremy Austin
On 06/17/2017 02:10 PM, Jeremy Austin wrote:
I appreciate that a target of 35,000 per county or "county equivalent" (parish, borough?) is just a number — but I believe I would prefer a metric keyed to actual geographic population density rather than to political or municipal boundaries qua boundaries. At least it seems to me that you are wanting to encourage rural development, given that the current broadband 'divide' is largely a rural vs. urban one, according to the 2016 Broadband Progress Report.
If you have a better idea regarding how to differentiate rural monopoly broadband providers to urban monopoly providers, please submit a comment to the FCC about your ideas of the right way to differentiate them.
Natural monopolies worked for electrification. Do you anticipate Title I providers as being sufficient to the task of narrowing this divide, with or without a federal incentives program? Historically, federal incentives have largely gone to Title II providers or their affiliated ISPs, if I understand the math correctly.
Title I providers did an excellent job back in the early days of the Internet providing service in virtually every area, including rural locations. Let me explain. I was on the Telecommunications Industry Associations' Transmitter Group 30 (TR30) by invitation of members, because I was publishing modem reviews in places like Byte and MacWorld magazines. The membership invited me to learn how to do it "right" to better serve the readership. (By the way, TIA TR30 used to be known as the "Modem Working Group". See the references to 47 CFR 68.) What was interesting is that the model "loops" (telephone circuits) included wire simulation for calls between rural locations to town upramps to the 'Net. When I incorporated the recommended loop models in my testing, I was able to show what modems would be good for the outliers to use. In that sense, that was the industry's way of trying to serve everyone, not just the "townies". The only Title II involvement was over the PSTN circuits themselves. Now, I can't talk to federal incentives. I can understand why, though -- the large providers have enough lawyers to put in bids "in the proper language" to win awards. The small ISPs can't afford a law firm with sixty names on the masthead. You may want to check the FCC site to see if there is a NPRM on subsidies on rural broadband, and comment on the questions contained in such a document. Or file a request for consideration -- there is a way to do that on EFCS.
participants (2)
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Jeremy Austin -
Stephen Satchell