Re: [WISPA] [WISPA Members] [IMPORTANCE LEVEL: HIGH] Network Neutrality Ex Parte Letter Template for Operators to file
At 12/15/2010 01:27 AM, Tom DeReggi wrote: Fred, Excellent Filing. Thanks. The big risk is abuse of power by those with dominent market power, thus possibly the need for some targeted regulation. But I'm not aware of any WISPs that has scaled large enough to have dominent market power to the extent to become a risk to consumers or other providers. I asked for Fixed Wireless to be exempt from NetNeutrality restrictions simply because there is no market need to regulate a small provider. This is a classic case of where American-style regulation goes awry. In most other countries, regulation addresses market power. Big companies are regulated more closely than small ones if the market is concentrated. In the EU, a 25% market share is presumptive of significant market power (SMP), the first step towards regulation. But in the US, we draw false analogies based on what people do, rather than on what power they have, and we pretend it's fair to the powerful megacorporations to make the same rules apply to everyone, however small. This goes beyond telecom. In the current food safety debate, there's a major press to rid the country of The Scourge of the Bake Sale, wherein people cook food in, gag, *home kitchens*, not certified, and sell them. We all[1] know how many millions of people die every year from home cooking, of course, so safe food must come from regulated, managed industrial-scale factories! [1] We all in this case refers to certain op-ed columnists who only eat in restaurants, but who portray themselves as centrists by taking positions nobody else has, and to a handful of politicians who live to please them. So the same sort of thing applies to telecom and Internet. Most people get it from a Big Company that has SMP, and they've been scared into assuming that the big company will abuse it. This is perfectly understandable; I think that certain large companies (no names, but they tend to have the rights to the collective trademark Bell) would love to put the squeeze on. So they want to put rules on ISPs. If asked, I doubt most people who support neutrality on principle would want to squeeze a little WISP -- they're thinking big telco and MSO -- but the big telcos are using this as a way to put the squeeze on the little guys. I even noticed a Verizon-funded front group putting in ex parte comments yesterday for real neutrality. CLECs are subject to similar silliness, btw, being regulated entities. Not neutrality -- as common carriers, CLECs are neutral. Federal law says that states cannot price-regulate them, and they have no market power. But states still require them to file tariffs, with pretend rates, as if they were ILECs. States and the FCC require detailed filings of reports. It's all set up to be fair to the Bells by making small competitors do the work that big ones do. That's why the regulatory debate has to be refocused. I'm impressed by the great turnout of WISP ex-parte letters. The FreePrers did submit long lists of names of supporters, but even some of them, if asked, would recognize that WISPs shouldn't be held to the same standards as the big guys. But they generally neither know nor care about our existence. They are already suffering from Broadband Stockholm Syndrome, and would rather argue about the food in the prison canteen than think about real freedom. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] [WISPA Members] [IMPORTANCE LEVEL: HIGH] Network Neutrality Ex Parte Letter Template for Operators to file
At 12/14/2010 08:37 AM, RickH wrote: I appreciate you guys putting this all together so quickly. I filed mine but it would be a good idea if this call went out again with step by step instructions. TOPIC: Treatment of Fixed Wireless Broadband in Open Internet Decision to be made at the FCC Commission Meeting on Dec. 21st, 2010. DEADLINE: Tuesday, December 14, 2010, 5:30 PM EST IMPORTANCE LEVEL: HIGH Oh, foolish me. I thought you said 5:00 PM. I had 32 minutes to spare after filing! ;-) I guess I'm not an early bird. Since I'm not a WISP per se but do like to file in FCC proceedings, I threw this together. It basically says that ISPs per se, including all WISPs, should not be regulated, but that dominant wireline providers, like ILECs, should make wholesale facilities available, and that's the only neutrality required, or probably even likely to withstand judicial scrutiny. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 FCC-09-191-ExParte.doc Description: MS-Word document WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] [WISPA Members] [IMPORTANCE LEVEL: HIGH] Network Neutrality Ex Parte Letter Template for Operators to file
Fred, Excellent Filing. The big risk is abuse of power by those with dominent market power, thus possibly the need for some targeted regulation. But I'm not aware of any WISPs that has scaled large enough to have dominent market power to the extent to become a risk to consumers or other providers. I asked for Fixed Wireless to be exempt from NetNeutrality restrictions simply because there is no market need to regulate a small provider. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: Fred Goldstein To: WISPA General List Sent: Tuesday, December 14, 2010 5:02 PM Subject: Re: [WISPA] [WISPA Members] [IMPORTANCE LEVEL: HIGH] Network Neutrality Ex Parte Letter Template for Operators to file At 12/14/2010 08:37 AM, RickH wrote: I appreciate you guys putting this all together so quickly. I filed mine but it would be a good idea if this call went out again with step by step instructions. TOPIC: Treatment of Fixed Wireless Broadband in Open Internet Decision to be made at the FCC Commission Meeting on Dec. 21st, 2010. DEADLINE: Tuesday, December 14, 2010, 5:30 PM EST IMPORTANCE LEVEL: HIGH Oh, foolish me. I thought you said 5:00 PM. I had 32 minutes to spare after filing! ;-) I guess I'm not an early bird. Since I'm not a WISP per se but do like to file in FCC proceedings, I threw this together. It basically says that ISPs per se, including all WISPs, should not be regulated, but that dominant wireline providers, like ILECs, should make wholesale facilities available, and that's the only neutrality required, or probably even likely to withstand judicial scrutiny. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consultinghttp://www.ionary.com/ +1 617 795 2701 -- WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
