Re: [WISPA] Quick Question: Title II, for or against?

[Fred Goldstein]

On 11/22/2014 5:02 AM, Blair Davis wrote:
I'm gonna respectfully say that, from the inside, being told 'That not 
one of our clients, don't worry about how long the repair lasts.'  and 
'Why should we bother to put a DSLAM out there?  It's only gonna get 
used up by them anyway.' and 'That pair of T1's is more than enough to 
feed that subdivision...  They aren't our users anyway.' and lots more 
similar comments in the trenches tend to make me somewhat skeptical of 
that.


I won't say that it may not have been a part of it.  I will say, that 
as the workers saw it,  when forced to give away their bread n butter, 
they rightly felt that it wasn't their problem anymore. When I refer 
to workers, I mean anyone who would have been CWA or equivalent.  I'll 
even include lower management.




To be blunt, the workers were lied to by management.  During that era, 
CWA and IBEW were basically house unions, helping tout the management 
line so long as their salaries were decent.  And under rate-of-return 
regulation, salaries were "allowable expense", passed through 100% to 
ratepayers so they could pay well.


But in reality those lines were just lines, not the truth.  Bell culture 
simply did not recognize the value of wholesale, "the channel".  It was 
direct retail sales or nothing.  The automobile industry was the 
opposite -- the dealer network did the heavy lifting of dealing with the 
actual users.  Go to any retail store and you'll see the channel at 
work, the retailer buying wholesale. It works really well for Levi 
Strauss, Ralph Lauren, etc.


Before the FCC relieved the Bells of their Title II reporting 
obligations, but before they relieved them of their wholesale 
obligations, they reported profit separately for their various 
subsidiaries.  The raw DSL (wholesale) and other wholesale businesses 
were profitable (Special Access tends towards a 100%+ rate of return!), 
but the Internet retail subsidiaries, the ones that competed directly 
with real ISPs, were unprofitable.  AFAIK they've never made money on 
Internet.  They only want to drive of the other providers so they can 
kill it, but now it's too important to kill, hence the NN kerfuffle.  
Had the Bells been real businesses, managed for long-term profit (vs. 
management control and ego-tripping), they would have embraced the 
wholesale channel, not lied about it.


Prior to Judge Greene, there was an /'esprit de corps'/ among the 
people of the Bell System.  It persisted under Ameritec... for a 
while.  By the time SBC was trying to become AT&T all over again, it 
was gone.  And when SBC became at&t, the employees, as far as I could 
see, didn't give a damn any more.  It became more 'Good enough to get 
paid.  By the time that becomes a problem, I'll be somewhere else...' 
.  Prior to that, people expected to be working on and using the plant 
forever.  When they fixed something, the fix was intended to last 
longer that the original.


Mary left after 28 years because the culture was gone.  She no longer 
liked working there.




It should come as no surprise that the unions are no longer on 
management's side; they're tired of being dicked around.  It wasn't 
Judge Greene who ended that esprit, either.  It was a change in American 
business culture to one where short-term profit was all that mattered, 
where CEOs were a privileged class of super-high-paid suckups who got 
bonuses for both succes and failure, and union-busting was raised to a 
high art.  AFOR was more damaging to labor relations than later 
demonopolization, as it made salaries and benefits an actual drain on 
shareholder returns, rather than an allowable expense.  (Recall that 
after Standard Oil was broken up in 1912, it only took a few years 
before the sum of the parts was worth three times as much as the 
previous whole.  Shareholders, including Rockefeller, cried all the way 
to the bank.)  Now they're in the final stages of abandoning the 
undermaintained plant, using excuses like "IP transition".  It mostly 
means dumping on their last union employees by pushing more business 
onto non-union wireless subsidiaries.



//
On 11/22/2014 12:13 AM, Fred Goldstein wrote:

On 11/21/2014 7:39 PM, Blair Davis wrote:

Just and reasonable...  Give me a break.

There is a reason the carriers let the POTS network decay... My 
wife, before she died, spent 28 years with Michigan Bell...  From 
before Judge Greene, thru Ameritec and then SBC.  She saw this from 
the inside.


Because they were forced to allow others to use their wired plant at 
prices below the cost of maintenance, let alone upgrades.




That was the Bell party line, for public consumption, but it wasn't true.

Section 251 (sections of the Communications Act, 47 USC, beginning 
with 2 are in Title II) has the rules for demonopolization of PSTN 
carriers.  They had a de jure monopoly; they still have a natural 
monopoly on mass-market services.  So they have facilities that are a 
necessary inpu to competitive pr

Re: [WISPA] Quick Question: Title II, for or against?

[Blair Davis]

I'm gonna respectfully say that, from the inside, being told 'That not 
one of our clients, don't worry about how long the repair lasts.'  and 
'Why should we bother to put a DSLAM out there?  It's only gonna get 
used up by them anyway.' and 'That pair of T1's is more than enough to 
feed that subdivision...  They aren't our users anyway.' and lots more 
similar comments in the trenches tend to make me somewhat skeptical of that.


I won't say that it may not have been a part of it.  I will say, that as 
the workers saw it,  when forced to give away their bread n butter, they 
rightly felt that it wasn't their problem anymore. When I refer to 
workers, I mean anyone who would have been CWA or equivalent.  I'll even 
include lower management.


Prior to Judge Greene, there was an /'esprit de corps'/ among the people 
of the Bell System.  It persisted under Ameritec... for a while.  By the 
time SBC was trying to become AT&T all over again, it was gone.  And 
when SBC became at&t, the employees, as far as I could see, didn't give 
a damn any more.  It became more 'Good enough to get paid.  By the time 
that becomes a problem, I'll be somewhere else...' .  Prior to that, 
people expected to be working on and using the plant forever.  When they 
fixed something, the fix was intended to last longer that the original.


Mary left after 28 years because the culture was gone.  She no longer 
liked working there.


--




//
On 11/22/2014 12:13 AM, Fred Goldstein wrote:

On 11/21/2014 7:39 PM, Blair Davis wrote:

Just and reasonable...  Give me a break.

There is a reason the carriers let the POTS network decay...  My 
wife, before she died, spent 28 years with Michigan Bell... From 
before Judge Greene, thru Ameritec and then SBC.  She saw this from 
the inside.


Because they were forced to allow others to use their wired plant at 
prices below the cost of maintenance, let alone upgrades.




That was the Bell party line, for public consumption, but it wasn't true.

Section 251 (sections of the Communications Act, 47 USC, beginning 
with 2 are in Title II) has the rules for demonopolization of PSTN 
carriers.  They had a de jure monopoly; they still have a natural 
monopoly on mass-market services.  So they have facilities that are a 
necessary inpu to competitive providers. They built their networks 
using rate of return regulation and de jure monopoly status 
(essentially a guarantee of profit) and that put them at the 24 mile 
line in the competitive marathon.


Section 251 says that ILECs specifically and uniquely have to provide 
unbundled network elements at forward-looking cost.  Just what "cost" 
is is not a simple answer.  Cost is not price.  Cost can be embedded 
direct cost, fully distributed (various methods), long-run 
incremental, total service long-run incremental, total element 
long-run incremental, etc.  Lots of room to argue cost, and that was a 
lot of fun back in the rate case days, to do cost studies and argue 
over details.


Non-ILECs have fewer obligations than ILECs.  There is a separate 
fundamental right of common carriage if a company is deemed a common 
carrier, but the "just and reasonable" standard is generally enforced 
only to what I call a "shocks the conscience" level.  No formulas, 
just don't horribly offend the Commission. It is very rarely invoked.


The Bells stopped maintaining their plant because in 1992-1993, they 
transitioned from rate of return regulation to price cap ("alternate 
form of") regulation.  Under rate of return, their total profit was a 
percentage (11.25% return was the last number, still in use) of their 
rate base (undepreciated capital plant). So the investment was to 
invest heavily; investing in rural areas paid really well because the 
high cost would be recoverable from urban monopoly ratepayers.  Under 
AFOR, though, some basic service prices are capped but not profits, so 
they could increase profits by reducing costs.  And they sure did!  
AFOR was met by massive layoffs and a general decline in maintenance.  
Accountants running companies devalue the future, so disinvestment 
look good to short term profits, and CEOs live for quarterly bonuses, 
which are not based on how they position the company for 10 years 
out.  Well, 20 years of AFOR and the chickens have come home to 
roost.  The plant is very heavily depreciated, not maintained, and the 
parent companies have put their capital into wireless, which has been 
more profitable lately.  Such is deregulation, helping turn the USA 
into a third world country while rentiers take the money and run.


Do you want to be forced to allow other to use your wireless 
network?  And have your costs and reimbursements determined by 
bureaucrats?




This would not apply to WISPs even in the unlikely event that WISPs 
were covered by Title II (which I've strongly opposed). They were 
never common carriers, and WISP plant is generally not suited for it.  
(There are wireless common carriers, and you cou

Re: [WISPA] Quick Question: Title II, for or against?

[Fred Goldstein]

On 11/21/2014 7:39 PM, Blair Davis wrote:

Just and reasonable...  Give me a break.

There is a reason the carriers let the POTS network decay...  My wife, 
before she died, spent 28 years with Michigan Bell...  From before 
Judge Greene, thru Ameritec and then SBC.  She saw this from the inside.


Because they were forced to allow others to use their wired plant at 
prices below the cost of maintenance, let alone upgrades.




That was the Bell party line, for public consumption, but it wasn't true.

Section 251 (sections of the Communications Act, 47 USC, beginning with 
2 are in Title II) has the rules for demonopolization of PSTN carriers.  
They had a de jure monopoly; they still have a natural monopoly on 
mass-market services.  So they have facilities that are a necessary inpu 
to competitive providers. They built their networks using rate of return 
regulation and de jure monopoly status (essentially a guarantee of 
profit) and that put them at the 24 mile line in the competitive marathon.


Section 251 says that ILECs specifically and uniquely have to provide 
unbundled network elements at forward-looking cost.  Just what "cost" is 
is not a simple answer.  Cost is not price.  Cost can be embedded direct 
cost, fully distributed (various methods), long-run incremental, total 
service long-run incremental, total element long-run incremental, etc.  
Lots of room to argue cost, and that was a lot of fun back in the rate 
case days, to do cost studies and argue over details.


Non-ILECs have fewer obligations than ILECs.  There is a separate 
fundamental right of common carriage if a company is deemed a common 
carrier, but the "just and reasonable" standard is generally enforced 
only to what I call a "shocks the conscience" level.  No formulas, just 
don't horribly offend the Commission.  It is very rarely invoked.


The Bells stopped maintaining their plant because in 1992-1993, they 
transitioned from rate of return regulation to price cap ("alternate 
form of") regulation.  Under rate of return, their total profit was a 
percentage (11.25% return was the last number, still in use) of their 
rate base (undepreciated capital plant).  So the investment was to 
invest heavily; investing in rural areas paid really well because the 
high cost would be recoverable from urban monopoly ratepayers.  Under 
AFOR, though, some basic service prices are capped but not profits, so 
they could increase profits by reducing costs.  And they sure did!  AFOR 
was met by massive layoffs and a general decline in maintenance.  
Accountants running companies devalue the future, so disinvestment look 
good to short term profits, and CEOs live for quarterly bonuses, which 
are not based on how they position the company for 10 years out.  Well, 
20 years of AFOR and the chickens have come home to roost.  The plant is 
very heavily depreciated, not maintained, and the parent companies have 
put their capital into wireless, which has been more profitable lately.  
Such is deregulation, helping turn the USA into a third world country 
while rentiers take the money and run.


Do you want to be forced to allow other to use your wireless network?  
And have your costs and reimbursements determined by bureaucrats?




This would not apply to WISPs even in the unlikely event that WISPs were 
covered by Title II (which I've strongly opposed).  They were never 
common carriers, and WISP plant is generally not suited for it.  (There 
are wireless common carriers, and you could create one if you wanted, 
but it would be a choice.)  And non-ILEC prices are never set by 
regulators.  The Just & Reasonable standard is only raised when a price 
is truly out of line, like the $68 3-minute pay phone call, or prison 
phone calls (always collect, typically at dollars per minute, which the 
FCC is cracking down on now).  Not even ILEC retail rates are set by 
regulators any more, just wholesale rates, which are regulated as part 
of the must-carry nature of the PSTN.



Title II, if forced on the small wisps, will kill us.



Probably true, but it's not the facilities they're talking about now, 
it's the data itself, which Title II was never meant to regulate, so it 
wouldn't stand up in court.



--
On 11/21/2014 6:19 PM, Fred Goldstein wrote:

On 11/21/2014 5:47 PM, Drew Lentz wrote:
So here's what sparked the question. I was trying to get some 
point-counterpoint going on with a friend of mine and found some 
pretty good arguments on each. This article made me think about it 
all a little differently:


http://www.netcompetition.org/congress/the-multi-billion-dollar-impact-of-fcc-title-ii-broadband-for-google-entire-internet-ecosystem

To Fred's point, the article mentions:
"That's because of the way the law and the forbearance provision are 
written; they apparently do not allow for any immaculate ruling 
where the FCC somehow rules the service and carrier of Internet 
traffic are regulated, but not the Internet traffic itself that is 
pr

Re: [WISPA] Quick Question: Title II, for or against?

[Blair Davis]

Just and reasonable...  Give me a break.

There is a reason the carriers let the POTS network decay...  My wife, 
before she died, spent 28 years with Michigan Bell...  From before Judge 
Greene, thru Ameritec and then SBC.  She saw this from the inside.


Because they were forced to allow others to use their wired plant at 
prices below the cost of maintenance, let alone upgrades.


Do you want to be forced to allow other to use your wireless network?  
And have your costs and reimbursements determined by bureaucrats?


Title II, if forced on the small wisps, will kill us.

--
On 11/21/2014 6:19 PM, Fred Goldstein wrote:

On 11/21/2014 5:47 PM, Drew Lentz wrote:
So here's what sparked the question. I was trying to get some 
point-counterpoint going on with a friend of mine and found some 
pretty good arguments on each. This article made me think about it 
all a little differently:


http://www.netcompetition.org/congress/the-multi-billion-dollar-impact-of-fcc-title-ii-broadband-for-google-entire-internet-ecosystem

To Fred's point, the article mentions:
"That's because of the way the law and the forbearance provision are 
written; they apparently do not allow for any immaculate ruling where 
the FCC somehow rules the service and carrier of Internet traffic are 
regulated, but not the Internet traffic itself that is precisely what 
defines the service and carrier."




The article is pure garbage.  Read the January ruling of the DC 
Circuit.  It was quite clear that the Computer II framework was 
legal.  And the Telecom Act was meant to memorialize that, not 
overturn it.  The Computer II framework very explicitly held that the 
"basic" carrier function was regulated while the higher-layer 
"enhanced" traffic was not.  The reason the FCC keeps getting in 
trouble is that they don't want restore that working model, since it 
would hurt some carriers' fee-fees.


The idea that Title II requires metered pricing makes less sense than 
the average diarrhea that comes from Louis Gohmerts' tuchus. The .0007 
rate is for termination of local telephone calls; it has nothing to do 
with bits or data services.  Whoever wrote the article is either a) an 
utter ignoramus; b) an utterly contemptible liar, or c) both.


There are all sorts of reasons why Title II would break the Internet.  
But applied to the access layer, it would simply mean that ISPs could 
lease DSL for a certain price per line per month, and perhaps a 
certain number of cents per gigabit, but that price would have to be 
"just and reasonable" in light of its actual cost to provision.


Oh, and Scott Cleland is now a lobbyist for the Bells, a professional 
liar who used to pretend to be an industry "analyst" for the Wall 
Street crowd, but who always shilled for the Bells.


Anyhow, not trying to beat a dead horse, but this got me questioning 
things :) Have a great weekend y'all!


-drew

On Fri, Nov 21, 2014 at 4:45 PM, Drew Lentz > wrote:


So here's what sparked the question. I was trying to get some
point-counterpoint going on with a friend of mine and found some
pretty good arguments on each. This article made me think about
it all a little differently:




___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless



--
  Fred R. Goldstein  k1iofred "at" interisle.net
  Interisle Consulting Group
  +1 617 795 2701


___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless


--
West Michigan Wireless ISP
Allegan, Michigan  49010
269-686-8648

A Division of:
Camp Communication Services, INC

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Fred Goldstein]

On 11/21/2014 5:47 PM, Drew Lentz wrote:
So here's what sparked the question. I was trying to get some 
point-counterpoint going on with a friend of mine and found some 
pretty good arguments on each. This article made me think about it all 
a little differently:


http://www.netcompetition.org/congress/the-multi-billion-dollar-impact-of-fcc-title-ii-broadband-for-google-entire-internet-ecosystem

To Fred's point, the article mentions:
"That's because of the way the law and the forbearance provision are 
written; they apparently do not allow for any immaculate ruling where 
the FCC somehow rules the service and carrier of Internet traffic are 
regulated, but not the Internet traffic itself that is precisely what 
defines the service and carrier."




The article is pure garbage.  Read the January ruling of the DC 
Circuit.  It was quite clear that the Computer II framework was legal.  
And the Telecom Act was meant to memorialize that, not overturn it.  The 
Computer II framework very explicitly held that the "basic" carrier 
function was regulated while the higher-layer "enhanced" traffic was 
not.  The reason the FCC keeps getting in trouble is that they don't 
want restore that working model, since it would hurt some carriers' 
fee-fees.


The idea that Title II requires metered pricing makes less sense than 
the average diarrhea that comes from Louis Gohmerts' tuchus. The .0007 
rate is for termination of local telephone calls; it has nothing to do 
with bits or data services.  Whoever wrote the article is either a) an 
utter ignoramus; b) an utterly contemptible liar, or c) both.


There are all sorts of reasons why Title II would break the Internet.  
But applied to the access layer, it would simply mean that ISPs could 
lease DSL for a certain price per line per month, and perhaps a certain 
number of cents per gigabit, but that price would have to be "just and 
reasonable" in light of its actual cost to provision.


Oh, and Scott Cleland is now a lobbyist for the Bells, a professional 
liar who used to pretend to be an industry "analyst" for the Wall Street 
crowd, but who always shilled for the Bells.


Anyhow, not trying to beat a dead horse, but this got me questioning 
things :) Have a great weekend y'all!


-drew

On Fri, Nov 21, 2014 at 4:45 PM, Drew Lentz > wrote:


So here's what sparked the question. I was trying to get some
point-counterpoint going on with a friend of mine and found some
pretty good arguments on each. This article made me think about it
all a little differently:




___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless



--
 Fred R. Goldstein  k1iofred "at" interisle.net
 Interisle Consulting Group
 +1 617 795 2701

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Drew Lentz]

So here's what sparked the question. I was trying to get some
point-counterpoint going on with a friend of mine and found some pretty
good arguments on each. This article made me think about it all a little
differently:

http://www.netcompetition.org/congress/the-multi-billion-dollar-impact-of-fcc-title-ii-broadband-for-google-entire-internet-ecosystem

To Fred's point, the article mentions:
"That’s because of the way the law and the forbearance provision are
written; they apparently do not allow for any immaculate ruling where the
FCC somehow rules the service and carrier of Internet traffic are
regulated, but not the Internet traffic itself that is precisely what
defines the service and carrier."

Anyhow, not trying to beat a dead horse, but this got me questioning things
:) Have a great weekend y'all!

-drew

On Fri, Nov 21, 2014 at 4:45 PM, Drew Lentz  wrote:

> So here's what sparked the question. I was trying to get some
> point-counterpoint going on with a friend of mine and found some pretty
> good arguments on each. This article made me think about it all a little
> differently:
>
>
___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Drew Lentz]

So here's what sparked the question. I was trying to get some
point-counterpoint going on with a friend of mine and found some pretty
good arguments on each. This article made me think about it all a little
differently:
___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Fred Goldstein]

On 11/20/2014 12:07 AM, Robert wrote:
> Ah the days of Covad, Northpoint, etc..   Racing to get high speed
> internet to needy customers on VC dollars not knowing that behind their
> backs a quick regulation change would make all that easy pickings for
> the incumbents...   Those who do not learn from history are doomed to
> repeat it..  Fred, please gaze into your magic ball of the past and give
> us a clue to our future?  Are our collective necks starting to hover
> over the ax block?

Ah yes, the days of Covad and Northpoint.  It was fun to watch them 
fail.  This wasn't however the FCC's doing.  The crazy speculators of 
the day ("investor" is too kind a term for them) were dumping money  
where it was obviously impossible to make a profit, hoping a greater 
fool would bail them out.  When there were six CLECs selling SDSL (aimed 
at business, full loop) in a suburban CO that didn't have a lot of 
businesses in it, you knew they were failures.  I wrote about this in my 
book The Great Telecom Meltdown.  One thing I like about the WISP 
business is that the participants don't have other people's money to 
waste so they're run like actual businesses.

Of course the FCC came along and killed off most of the surviving real 
businesses a couple of years later.  Their rule changes were justified 
by predictions that, predictably to us, never came true. It was a farce; 
SBC (n/k/a AT&T) and Verizon had that FCC in their pocket and they 
weren't even trying to look fair.

As to the crystal ball gazing:  I think the WISPs will survive, and I 
credit WISPA and its legal and FCC teams for a lot of this.  The 
wireline ISP and CLEC businesses never had good organizations behind 
them -- there were CLEC groups made up of the big guys who mostly did 
resale/platform, but nobody lobbying for the smaller and more 
data-oriented CLECs.  WISPA literally gets a seat at the table (Steve 
Coran last week, for instance) so our needs are heard, and on record 
(which matters come appeal time -- no new facts allowed, but you can 
mine the record).

My actual forecast is that Wheeler, in a few months, will come out with 
a cockamamie plan that tries to regulate the Internet itself using 
Section 706 authority, though he might touch Title II.  It is likely to 
not directly impose common carrier regulation (Title II) on WISPs, but 
it might impact their upstream ISPs.  It might make things a little 
difficult for some WISPs but not be fatal.  In any case it will be 
appealed.  Then after the 2016 election, the Court will throw out the 
bulk of it, noting that Section 706 is not a grant of authority after 
all (this was a legal issue they overlooked in the last case, where 
Verizon failed to point that out) and that Title II was aimed at common 
carriers, not information service providers, and the FCC will have 
failed to demonstrate that ISPs are common carriers when engaging in 
peering.  Thus no Title II there. (Title II is absolutely legal to apply 
to the access wire of otherwise-regulated carriers, at the lower layers, 
and the DC Circuit said so in January.  Tom will not go there.  If he 
were to go there, he probably would not touch WISPs -- my Comment gave 
him a good way to draw that line without saying "WISP" out loud needing 
to define the term.)

In other words, the FCC will write convoluted rules *designed to be 
overturned*, so that the next FCC (each president gets his/her own 
chairman) will be handed the issue again, and have to figure out how to 
kick the can down the road another 4/8 years, hoping it all goes away.

> On 11/19/2014 08:32 PM, Faisal Imtiaz wrote:
>> Chuckle :)
>>
>> You all don't know who Fred is :)
>>
>> He has a weee bit of experience in these matters. :)
>>
>> I am reading this discussion about Title II and having a  dejavu !!!
>>
>> What you all see coming to our door steps in form of Title II via the FCC, 
>> is pretty similar to what the we saw about 5 to 10 years ago on the wireline 
>> side.. there it was 'de-regulation' or Forbearance from Title II 
>> regulations.It is rather interesting and comical (sarcasm)  to see the 
>> 'regulatory pendulum' swinging in the opposite direction...I wish there is a 
>> way to turn all the arguments presented and accepted by the FCC at that time 
>> to grant forbearance could be re-presented to them
>>
>> And yes, Fred is a subject matter expert on Wireline Regulation /FCC... 
>> (Think of him like a Steve Coran of the wireline world).
>>
>> :)
>>
>>
>> Faisal Imtiaz
>> Snappy Internet & Telecom
>> 7266 SW 48 Street
>> Miami, FL 33155
>> Tel: 305 663 5518 x 232
>>
>> Help-desk: (305)663-5518 Option 2 or Email: supp...@snappytelecom.net
>>
>> 

Re: [WISPA] Quick Question: Title II, for or against?

[Caleb Knauer]

This is very informative, thanks Fred.

I guess the part that I'm still confused about is the whole content
neutrality/fastlane conversation, the only part general consumers care
about as the political base pushing for these changes has made it into
the single marketing pitch.  I mean sure, at first glance it seems
like a good idea to prevent telco/cable companies from parsing up the
internet into psuedo-channels (worst case).  But of course it's not
that simple.  What part of the proposed NN rules dictates how content
is managed to make it "neutral"?

For delivery/reporting/transport regulations, seems to me that if the
feds want us to play by big boy rules then they need to give us big
boy tools (spectrum).  And real spectrum, not tiny neutered slices.
Licensed (real, not this 3.65 nonsense), high power, wide bands (for
mfg efficiency).

On Wed, Nov 19, 2014 at 11:26 AM, Fred Goldstein  wrote:
> On 11/19/2014 8:49 AM, Drew Lentz wrote:
>> I put up a quick poll, results will be shared and are anonymous.
>>
>> https://www.surveymonkey.com/s/3R6YTH9
>>
>> I'm curious to see what the percentages are between those that support
>> and those that don't support the Title II argument. I've been trying
>> to get a good feel for who would and wouldn't like it (mostly it seems
>> carriers love it, web services hate it.) I have a feeling WISPs might
>> be on the "hate it" side, but I'm interested to find out. Thanks for
>> your answer and have a fantastic day!
>>
>
> You asked the question very poorly, so there is no one correct answer.
>
> "Broadband" is an adjective. You don't regulate adjectives, you regulate
> nouns.  Broadband what? This is the fallacy of today's public discourse
> -- they are using this adjective as a noun without the noun, so
> different people use it to have different referents.
>
> I think I'm in pretty close harmony with the WISPA position here, given
> that Steve Coran chose me to help him give his NN talk in Vegas last
> month based on my detailed Comments on the topic to the FCC.  And I've
> been writing and Commenting on this for years. Several years ago I told
> the FCC that they were using this adjective as a noun, but that they
> could separate the two primary implied nouns by using a Spanish-language
> convention.  El Broadband would refer to the physical facility, the high
> speed transmission medium. La Broadband would refer to the content of
> the facility, including Internet service delivered over it.  (If you
> don't know Spanish, "el radio" is a device and "la radio" is a
> program.)  But in lawyer terms, El Broadband is the telecommunications
> component, and La Broadband is the information service riding atop it.
>
> The reason NN is a Thing is that the FCC, in 2005, threw away the law
> (TA96) and decided that telephone companies could stop being common
> carriers, stop providing ISPs with El Broadband (raw DSL), and simply
> sell La Broadband as a vertically-integrated service with exclusive
> access to their formerly common-carrier facilities.  So typical
> consumers in cities went from having many ISP choices (one cable company
> and many ISPs available via DSL) to two (one each cable and DSL).
>
> The public reaction to this was, understandably, rather negative. They
> recognized that they could be screwed by their cable and telco
> duopolists (monopolists in many areas, and more in the future as the
> ILECs abandon their copper plant without replacing it).  But not
> recognizing the difference between a "network" (what carries IP) and an
> "internetwork" (the Internet itself, content slung across many
> networks), they demanded "network neutrality" referring to the ISP
> function itself.  And the FCC obliged, being basically political, by
> proposing the regulation of Internet services, but not regulating the
> actual telecom provided by the monopolists.
>
> So I'm in favor of applying Title II to the actual telecommunications
> component of broadband services provided by incumbents, and those using
> rivalrous facilities (those that exclude others, including pole
> attachments, conduits, and exclusively-licensed frequencies).  But those
> who only compete with incumbent cable and telco, or who use
> non-rivalrous facilities and frequencies (that includes essentially all
> WISPs), would not fall under Title II whatsoever, and neither would the
> Internet backbone or anything done on the Internet itself (IP layer on
> up, but this does not refer to IP-based voice services provided by
> facility owners).
>
> So I'm in favor of Title II for some broadband stuff (where it opens
> monopoly wire to competitive ISPs) but not others (where it regulates
> the Internet or WISPs).  Got it?  That's why the question is wrong.
>
> --
>   Fred R. Goldstein  k1iofred "at" interisle.net
>   Interisle Consulting Group
>   +1 617 795 2701
>
> ___
> Wireless mailing list
> Wireless@wispa.org
> http://lists.wispa.org/mailman/listinfo/wire

Re: [WISPA] Quick Question: Title II, for or against?

[Caleb Knauer]

Man we went through all those guys as they rose and fell in the early
years.  We had a 2x2Mbps SDSL line in our apt in college and it turned
into homework central for all our friends that needed to push heavy
data back to campus computing systems but didn't want to hang out in
the labs all night.  I also remember what a total trainwreck it was
getting circuits provisioned/moved for our integration customers as
BellSouth would drag their feet so bad.  That mess is what pushed me
into wireless to start with.

On Thu, Nov 20, 2014 at 12:07 AM, Robert  wrote:
> Ah the days of Covad, Northpoint, etc..   Racing to get high speed
> internet to needy customers on VC dollars not knowing that behind their
> backs a quick regulation change would make all that easy pickings for
> the incumbents...   Those who do not learn from history are doomed to
> repeat it..  Fred, please gaze into your magic ball of the past and give
> us a clue to our future?  Are our collective necks starting to hover
> over the ax block?
>
> On 11/19/2014 08:32 PM, Faisal Imtiaz wrote:
>> Chuckle :)
>>
>> You all don't know who Fred is :)
>>
>> He has a weee bit of experience in these matters. :)
>>
>> I am reading this discussion about Title II and having a  dejavu !!!
>>
>> What you all see coming to our door steps in form of Title II via the FCC, 
>> is pretty similar to what the we saw about 5 to 10 years ago on the wireline 
>> side.. there it was 'de-regulation' or Forbearance from Title II 
>> regulations.It is rather interesting and comical (sarcasm)  to see the 
>> 'regulatory pendulum' swinging in the opposite direction...I wish there is a 
>> way to turn all the arguments presented and accepted by the FCC at that time 
>> to grant forbearance could be re-presented to them
>>
>> And yes, Fred is a subject matter expert on Wireline Regulation /FCC... 
>> (Think of him like a Steve Coran of the wireline world).
>>
>> :)
>>
>>
>> Faisal Imtiaz
>> Snappy Internet & Telecom
>> 7266 SW 48 Street
>> Miami, FL 33155
>> Tel: 305 663 5518 x 232
>>
>> Help-desk: (305)663-5518 Option 2 or Email: supp...@snappytelecom.net
>>
>> - Original Message -
>>> From: "Eric Tykwinski" 
>>> To: "WISPA General List" 
>>> Sent: Wednesday, November 19, 2014 7:10:11 PM
>>> Subject: Re: [WISPA] Quick Question: Title II, for or against?
>>>
>>> Fred,
>>>
>>> It’s a little late, but damn, that was a good description of the problem.
>>> I’m hoping and just hoping, that Wheeler understands exactly what the 
>>> problem
>>> really is.
>>> Everyone thinks Title II is a hammer both on the ILEC and the public 
>>> activist
>>> side,
>>> but in reality I hope that the FCC does have a bit more common sense and see
>>> that competition is what will lead to the public good in the long run.
>>>
>>> Now if the lawyers can actually come up with something that will legally
>>> stick, well that’s up in the air.
>>>
>>> Sincerely,
>>>
>>> Eric Tykwinski
>>> TrueNet, Inc.
>>> P: 610-429-8300
>>> F: 610-429-3222
>>>
>>>> On Nov 19, 2014, at 6:04 PM, Kevin Sullivan 
>>>> wrote:
>>>>
>>>> Wow, that was well thought out. I'd say that's a pretty good assessment!
>>>>
>>>> Kevin
>>>>
>>>> - Original Message -
>>>> From: "Fred Goldstein" 
>>>> To: 
>>>> Sent: Wednesday, November 19, 2014 8:26 AM
>>>> Subject: Re: [WISPA] Quick Question: Title II, for or against?
>>>>
>>>>
>>>>> On 11/19/2014 8:49 AM, Drew Lentz wrote:
>>>>>> I put up a quick poll, results will be shared and are anonymous.
>>>>>>
>>>>>> https://www.surveymonkey.com/s/3R6YTH9
>>>>>>
>>>>>> I'm curious to see what the percentages are between those that support
>>>>>> and those that don't support the Title II argument. I've been trying
>>>>>> to get a good feel for who would and wouldn't like it (mostly it seems
>>>>>> carriers love it, web services hate it.) I have a feeling WISPs might
>>>>>> be on the "hate it" side, but I'm interested to find out. Thanks for
>>>>>> your answer and have a fantastic day!
>>>>>>
>>>>>
>>>>> You asked

Re: [WISPA] Quick Question: Title II, for or against?

[Robert]

Ah the days of Covad, Northpoint, etc..   Racing to get high speed
internet to needy customers on VC dollars not knowing that behind their
backs a quick regulation change would make all that easy pickings for
the incumbents...   Those who do not learn from history are doomed to
repeat it..  Fred, please gaze into your magic ball of the past and give
us a clue to our future?  Are our collective necks starting to hover
over the ax block?

On 11/19/2014 08:32 PM, Faisal Imtiaz wrote:
> Chuckle :)
> 
> You all don't know who Fred is :)
> 
> He has a weee bit of experience in these matters. :)
> 
> I am reading this discussion about Title II and having a  dejavu !!!
> 
> What you all see coming to our door steps in form of Title II via the FCC, is 
> pretty similar to what the we saw about 5 to 10 years ago on the wireline 
> side.. there it was 'de-regulation' or Forbearance from Title II 
> regulations.It is rather interesting and comical (sarcasm)  to see the 
> 'regulatory pendulum' swinging in the opposite direction...I wish there is a 
> way to turn all the arguments presented and accepted by the FCC at that time 
> to grant forbearance could be re-presented to them
> 
> And yes, Fred is a subject matter expert on Wireline Regulation /FCC... 
> (Think of him like a Steve Coran of the wireline world).
> 
> :)
> 
> 
> Faisal Imtiaz
> Snappy Internet & Telecom
> 7266 SW 48 Street
> Miami, FL 33155
> Tel: 305 663 5518 x 232
> 
> Help-desk: (305)663-5518 Option 2 or Email: supp...@snappytelecom.net 
> 
> - Original Message -----
>> From: "Eric Tykwinski" 
>> To: "WISPA General List" 
>> Sent: Wednesday, November 19, 2014 7:10:11 PM
>> Subject: Re: [WISPA] Quick Question: Title II, for or against?
>>
>> Fred,
>>
>> It’s a little late, but damn, that was a good description of the problem.
>> I’m hoping and just hoping, that Wheeler understands exactly what the problem
>> really is.
>> Everyone thinks Title II is a hammer both on the ILEC and the public activist
>> side,
>> but in reality I hope that the FCC does have a bit more common sense and see
>> that competition is what will lead to the public good in the long run.
>>
>> Now if the lawyers can actually come up with something that will legally
>> stick, well that’s up in the air.
>>
>> Sincerely,
>>
>> Eric Tykwinski
>> TrueNet, Inc.
>> P: 610-429-8300
>> F: 610-429-3222
>>
>>> On Nov 19, 2014, at 6:04 PM, Kevin Sullivan 
>>> wrote:
>>>
>>> Wow, that was well thought out. I'd say that's a pretty good assessment!
>>>
>>> Kevin
>>>
>>> - Original Message -
>>> From: "Fred Goldstein" 
>>> To: 
>>> Sent: Wednesday, November 19, 2014 8:26 AM
>>> Subject: Re: [WISPA] Quick Question: Title II, for or against?
>>>
>>>
>>>> On 11/19/2014 8:49 AM, Drew Lentz wrote:
>>>>> I put up a quick poll, results will be shared and are anonymous.
>>>>>
>>>>> https://www.surveymonkey.com/s/3R6YTH9
>>>>>
>>>>> I'm curious to see what the percentages are between those that support
>>>>> and those that don't support the Title II argument. I've been trying
>>>>> to get a good feel for who would and wouldn't like it (mostly it seems
>>>>> carriers love it, web services hate it.) I have a feeling WISPs might
>>>>> be on the "hate it" side, but I'm interested to find out. Thanks for
>>>>> your answer and have a fantastic day!
>>>>>
>>>>
>>>> You asked the question very poorly, so there is no one correct answer.
>>>>
>>>> "Broadband" is an adjective. You don't regulate adjectives, you regulate
>>>> nouns.  Broadband what? This is the fallacy of today's public discourse
>>>> -- they are using this adjective as a noun without the noun, so
>>>> different people use it to have different referents.
>>>>
>>>> I think I'm in pretty close harmony with the WISPA position here, given
>>>> that Steve Coran chose me to help him give his NN talk in Vegas last
>>>> month based on my detailed Comments on the topic to the FCC.  And I've
>>>> been writing and Commenting on this for years. Several years ago I told
>>>> the FCC that they were using this adjective as a noun, but that they
>>>> could separate the two primary implied no

Re: [WISPA] Quick Question: Title II, for or against?

[Brett Woollum]

Agreed, thanks Fred! 

Sonic.net, a California CLEC offering DSL internet services, has a blog post 
about this topic that might be of interest to the group: 
https://corp.sonic.net/ceo/2014/11/12/neutrality-is-just-a-symptom/ 


Brett Woollum 
Senior Sales Engineer 
br...@tekify.com 

Tekify Broadband Internet Services 
Web: http://www.tekify.com 
Phone: 510-266-5800 , ext 6200 

- Original Message -

From: "Kevin Sullivan"  
To: "WISPA General List"  
Sent: Wednesday, November 19, 2014 3:04:17 PM 
Subject: Re: [WISPA] Quick Question: Title II, for or against? 

Wow, that was well thought out. I'd say that's a pretty good assessment! 

Kevin 

- Original Message - 
From: "Fred Goldstein"  
To:  
Sent: Wednesday, November 19, 2014 8:26 AM 
Subject: Re: [WISPA] Quick Question: Title II, for or against? 


> On 11/19/2014 8:49 AM, Drew Lentz wrote: 
>> I put up a quick poll, results will be shared and are anonymous. 
>> 
>> https://www.surveymonkey.com/s/3R6YTH9 
>> 
>> I'm curious to see what the percentages are between those that support 
>> and those that don't support the Title II argument. I've been trying 
>> to get a good feel for who would and wouldn't like it (mostly it seems 
>> carriers love it, web services hate it.) I have a feeling WISPs might 
>> be on the "hate it" side, but I'm interested to find out. Thanks for 
>> your answer and have a fantastic day! 
>> 
> 
> You asked the question very poorly, so there is no one correct answer. 
> 
> "Broadband" is an adjective. You don't regulate adjectives, you regulate 
> nouns. Broadband what? This is the fallacy of today's public discourse 
> -- they are using this adjective as a noun without the noun, so 
> different people use it to have different referents. 
> 
> I think I'm in pretty close harmony with the WISPA position here, given 
> that Steve Coran chose me to help him give his NN talk in Vegas last 
> month based on my detailed Comments on the topic to the FCC. And I've 
> been writing and Commenting on this for years. Several years ago I told 
> the FCC that they were using this adjective as a noun, but that they 
> could separate the two primary implied nouns by using a Spanish-language 
> convention. El Broadband would refer to the physical facility, the high 
> speed transmission medium. La Broadband would refer to the content of 
> the facility, including Internet service delivered over it. (If you 
> don't know Spanish, "el radio" is a device and "la radio" is a 
> program.) But in lawyer terms, El Broadband is the telecommunications 
> component, and La Broadband is the information service riding atop it. 
> 
> The reason NN is a Thing is that the FCC, in 2005, threw away the law 
> (TA96) and decided that telephone companies could stop being common 
> carriers, stop providing ISPs with El Broadband (raw DSL), and simply 
> sell La Broadband as a vertically-integrated service with exclusive 
> access to their formerly common-carrier facilities. So typical 
> consumers in cities went from having many ISP choices (one cable company 
> and many ISPs available via DSL) to two (one each cable and DSL). 
> 
> The public reaction to this was, understandably, rather negative. They 
> recognized that they could be screwed by their cable and telco 
> duopolists (monopolists in many areas, and more in the future as the 
> ILECs abandon their copper plant without replacing it). But not 
> recognizing the difference between a "network" (what carries IP) and an 
> "internetwork" (the Internet itself, content slung across many 
> networks), they demanded "network neutrality" referring to the ISP 
> function itself. And the FCC obliged, being basically political, by 
> proposing the regulation of Internet services, but not regulating the 
> actual telecom provided by the monopolists. 
> 
> So I'm in favor of applying Title II to the actual telecommunications 
> component of broadband services provided by incumbents, and those using 
> rivalrous facilities (those that exclude others, including pole 
> attachments, conduits, and exclusively-licensed frequencies). But those 
> who only compete with incumbent cable and telco, or who use 
> non-rivalrous facilities and frequencies (that includes essentially all 
> WISPs), would not fall under Title II whatsoever, and neither would the 
> Internet backbone or anything done on the Internet itself (IP layer on 
> up, but this does not refer to IP-based voice services provided by 
> facility owners). 
> 
> So I'm in favor of Title II for some broadband stuff (where it opens 
> m

Re: [WISPA] Quick Question: Title II, for or against?

[Faisal Imtiaz]

Chuckle :)

You all don't know who Fred is :)

He has a weee bit of experience in these matters. :)

I am reading this discussion about Title II and having a  dejavu !!!

What you all see coming to our door steps in form of Title II via the FCC, is 
pretty similar to what the we saw about 5 to 10 years ago on the wireline 
side.. there it was 'de-regulation' or Forbearance from Title II 
regulations.It is rather interesting and comical (sarcasm)  to see the 
'regulatory pendulum' swinging in the opposite direction...I wish there is a 
way to turn all the arguments presented and accepted by the FCC at that time to 
grant forbearance could be re-presented to them

And yes, Fred is a subject matter expert on Wireline Regulation /FCC... (Think 
of him like a Steve Coran of the wireline world).

:)


Faisal Imtiaz
Snappy Internet & Telecom
7266 SW 48 Street
Miami, FL 33155
Tel: 305 663 5518 x 232

Help-desk: (305)663-5518 Option 2 or Email: supp...@snappytelecom.net 

- Original Message -
> From: "Eric Tykwinski" 
> To: "WISPA General List" 
> Sent: Wednesday, November 19, 2014 7:10:11 PM
> Subject: Re: [WISPA] Quick Question: Title II, for or against?
> 
> Fred,
> 
> It’s a little late, but damn, that was a good description of the problem.
> I’m hoping and just hoping, that Wheeler understands exactly what the problem
> really is.
> Everyone thinks Title II is a hammer both on the ILEC and the public activist
> side,
> but in reality I hope that the FCC does have a bit more common sense and see
> that competition is what will lead to the public good in the long run.
> 
> Now if the lawyers can actually come up with something that will legally
> stick, well that’s up in the air.
> 
> Sincerely,
> 
> Eric Tykwinski
> TrueNet, Inc.
> P: 610-429-8300
> F: 610-429-3222
> 
> > On Nov 19, 2014, at 6:04 PM, Kevin Sullivan 
> > wrote:
> > 
> > Wow, that was well thought out. I'd say that's a pretty good assessment!
> > 
> > Kevin
> > 
> > - Original Message -
> > From: "Fred Goldstein" 
> > To: 
> > Sent: Wednesday, November 19, 2014 8:26 AM
> > Subject: Re: [WISPA] Quick Question: Title II, for or against?
> > 
> > 
> >> On 11/19/2014 8:49 AM, Drew Lentz wrote:
> >>> I put up a quick poll, results will be shared and are anonymous.
> >>> 
> >>> https://www.surveymonkey.com/s/3R6YTH9
> >>> 
> >>> I'm curious to see what the percentages are between those that support
> >>> and those that don't support the Title II argument. I've been trying
> >>> to get a good feel for who would and wouldn't like it (mostly it seems
> >>> carriers love it, web services hate it.) I have a feeling WISPs might
> >>> be on the "hate it" side, but I'm interested to find out. Thanks for
> >>> your answer and have a fantastic day!
> >>> 
> >> 
> >> You asked the question very poorly, so there is no one correct answer.
> >> 
> >> "Broadband" is an adjective. You don't regulate adjectives, you regulate
> >> nouns.  Broadband what? This is the fallacy of today's public discourse
> >> -- they are using this adjective as a noun without the noun, so
> >> different people use it to have different referents.
> >> 
> >> I think I'm in pretty close harmony with the WISPA position here, given
> >> that Steve Coran chose me to help him give his NN talk in Vegas last
> >> month based on my detailed Comments on the topic to the FCC.  And I've
> >> been writing and Commenting on this for years. Several years ago I told
> >> the FCC that they were using this adjective as a noun, but that they
> >> could separate the two primary implied nouns by using a Spanish-language
> >> convention.  El Broadband would refer to the physical facility, the high
> >> speed transmission medium. La Broadband would refer to the content of
> >> the facility, including Internet service delivered over it.  (If you
> >> don't know Spanish, "el radio" is a device and "la radio" is a
> >> program.)  But in lawyer terms, El Broadband is the telecommunications
> >> component, and La Broadband is the information service riding atop it.
> >> 
> >> The reason NN is a Thing is that the FCC, in 2005, threw away the law
> >> (TA96) and decided that telephone companies could stop being common
> >> carriers, stop providing ISPs with El Broadband (raw DSL), and simply
> >> sell La Broad

Re: [WISPA] Quick Question: Title II, for or against?

[Mike Hammett]

" Future FCCs would not be bound by this FCC’s decisions. " 

For good and bad. 




- 
Mike Hammett 
Intelligent Computing Solutions 
http://www.ics-il.com 



- Original Message -

From: "Jeff Broadwick"  
To: "WISPA General List"  
Sent: Wednesday, November 19, 2014 8:55:28 PM 
Subject: Re: [WISPA] Quick Question: Title II, for or against? 



Title ll has a ton of regulations…some which could reasonably apply, but most 
that have no bearing whatsoever or would be incredibly damaging to our 
industry. The question…and the problem, is that we don’t know what the FCC 
would enforce and what they would forebear from enforcing…and for how long. 
Future FCCs would not be bound by this FCC’s decisions. 


Regards, 

Jeff 


Jeff Broadwick 
Senior Account Manager, Convergence Technologies, Inc. 
jbroadw...@converge-tech.com 
312-205-2519 Office 
574-220-7826 Cell 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf 
Of Rubens Kuhl 
Sent: Wednesday, November 19, 2014 7:40 PM 
To: WISPA General List 
Subject: Re: [WISPA] Quick Question: Title II, for or against? 








The real problem is that consumers have only the CableCo and TelCo as options 
for purchasing internet. The government instead of regulating should encourage 
competition in the free market. WISPs are one such competitor. 







WISPs are prevented by laws of Electromagnetism and Communications to direct 
compete with CableCo and TelCo for most customers, so this argument actually 
justifies Title II treatment since CableCo and TelCo are the only ones most US 
citizens can choose from. 



Rubens 


___ 
Wireless mailing list 
Wireless@wispa.org 
http://lists.wispa.org/mailman/listinfo/wireless 

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Jeff Broadwick]

Title ll has a ton of regulations…some which could reasonably apply, but most 
that have no bearing whatsoever or would be incredibly damaging to our 
industry.  The question…and the problem, is that we don’t know what the FCC 
would enforce and what they would forebear from enforcing…and for how long.  
Future FCCs would not be bound by this FCC’s decisions.

 

 

Regards,

 

Jeff

 

 

Jeff Broadwick

Senior Account Manager, Convergence Technologies, Inc.

 <mailto:jbroadw...@converge-tech.com> jbroadw...@converge-tech.com

312-205-2519 Office

574-220-7826 Cell

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf 
Of Rubens Kuhl
Sent: Wednesday, November 19, 2014 7:40 PM
To: WISPA General List
Subject: Re: [WISPA] Quick Question: Title II, for or against?

 

The real problem is that consumers have only the CableCo and TelCo as options 
for purchasing internet.  The government instead of regulating should encourage 
competition in the free market.  WISPs are one such competitor.  

 

 

WISPs are prevented by laws of Electromagnetism and Communications to direct 
compete with CableCo and TelCo for most customers, so this argument actually 
justifies Title II treatment since CableCo and TelCo are the only ones most US 
citizens can choose from. 

 

Rubens

 

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Rubens Kuhl]

>
> The real problem is that consumers have only the CableCo and TelCo as
> options for purchasing internet.  The government instead of regulating
> should encourage competition in the free market.  WISPs are one such
> competitor.
>
>
WISPs are prevented by laws of Electromagnetism and Communications to
direct compete with CableCo and TelCo for most customers, so this argument
actually justifies Title II treatment since CableCo and TelCo are the only
ones most US citizens can choose from.

Rubens
___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Fred Goldstein]

On 11/19/2014 4:22 PM, Sean Heskett wrote:
> also title II regulations are why an OC3 at 150Mbps costs 100 times as 
> much as 150Mbps metro ethernet.  Ethernet is unregulated, OC3 is part 
> of the whole terrified crap left over from MaBell etc.  So even though 
> both services are delivered over the same medium (fiber) because of 
> the technology used OC3 is heavily regulated while ethernet is not.
>
> Title II will make internet access more expensive, not less.
>
>

No, not really.  The problem is that OC-3 is fully deregulated too -- 
the FCC only applies title II on circuits up to DS3/OC-1.  Thus the 
monopolists can charge whatever the want for it.  Ethernet is more 
competitive, so they charge less where there is competition.

The law isn't about technology, but the FCC is not always neutral. So a 
10 Mbps Ethernet is unregulated but the equivalent TDM is.  A CLEC can 
buy DS3, in many cases, for a very low price, where it' a UNE.  An ISP 
has to pay the FCC-authorized price, but in many areas (not all) the FCC 
has deregulated that too.

The Bells view SONET as a medium for carrying phone calls, and price it 
based on the assumption that it's lost toll revenue on each DS0. 
Insane.  Plus they are using 1990s gear (pre-Cerent) and pricing based 
on what the paid then, not what newer gear costs (maybe 10% of that).

-- 
  Fred R. Goldstein  k1iofred "at" interisle.net
  Interisle Consulting Group
  +1 617 795 2701

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Eric Tykwinski]

Fred,

It’s a little late, but damn, that was a good description of the problem.
I’m hoping and just hoping, that Wheeler understands exactly what the problem 
really is.
Everyone thinks Title II is a hammer both on the ILEC and the public activist 
side,
but in reality I hope that the FCC does have a bit more common sense and see
that competition is what will lead to the public good in the long run.

Now if the lawyers can actually come up with something that will legally stick, 
well that’s up in the air.

Sincerely,

Eric Tykwinski
TrueNet, Inc.
P: 610-429-8300
F: 610-429-3222

> On Nov 19, 2014, at 6:04 PM, Kevin Sullivan  
> wrote:
> 
> Wow, that was well thought out. I'd say that's a pretty good assessment!
> 
> Kevin
> 
> - Original Message - 
> From: "Fred Goldstein" 
> To: 
> Sent: Wednesday, November 19, 2014 8:26 AM
> Subject: Re: [WISPA] Quick Question: Title II, for or against?
> 
> 
>> On 11/19/2014 8:49 AM, Drew Lentz wrote:
>>> I put up a quick poll, results will be shared and are anonymous.
>>> 
>>> https://www.surveymonkey.com/s/3R6YTH9
>>> 
>>> I'm curious to see what the percentages are between those that support 
>>> and those that don't support the Title II argument. I've been trying 
>>> to get a good feel for who would and wouldn't like it (mostly it seems 
>>> carriers love it, web services hate it.) I have a feeling WISPs might 
>>> be on the "hate it" side, but I'm interested to find out. Thanks for 
>>> your answer and have a fantastic day!
>>> 
>> 
>> You asked the question very poorly, so there is no one correct answer.
>> 
>> "Broadband" is an adjective. You don't regulate adjectives, you regulate 
>> nouns.  Broadband what? This is the fallacy of today's public discourse 
>> -- they are using this adjective as a noun without the noun, so 
>> different people use it to have different referents.
>> 
>> I think I'm in pretty close harmony with the WISPA position here, given 
>> that Steve Coran chose me to help him give his NN talk in Vegas last 
>> month based on my detailed Comments on the topic to the FCC.  And I've 
>> been writing and Commenting on this for years. Several years ago I told 
>> the FCC that they were using this adjective as a noun, but that they 
>> could separate the two primary implied nouns by using a Spanish-language 
>> convention.  El Broadband would refer to the physical facility, the high 
>> speed transmission medium. La Broadband would refer to the content of 
>> the facility, including Internet service delivered over it.  (If you 
>> don't know Spanish, "el radio" is a device and "la radio" is a 
>> program.)  But in lawyer terms, El Broadband is the telecommunications 
>> component, and La Broadband is the information service riding atop it.
>> 
>> The reason NN is a Thing is that the FCC, in 2005, threw away the law 
>> (TA96) and decided that telephone companies could stop being common 
>> carriers, stop providing ISPs with El Broadband (raw DSL), and simply 
>> sell La Broadband as a vertically-integrated service with exclusive 
>> access to their formerly common-carrier facilities.  So typical 
>> consumers in cities went from having many ISP choices (one cable company 
>> and many ISPs available via DSL) to two (one each cable and DSL).
>> 
>> The public reaction to this was, understandably, rather negative. They 
>> recognized that they could be screwed by their cable and telco 
>> duopolists (monopolists in many areas, and more in the future as the 
>> ILECs abandon their copper plant without replacing it).  But not 
>> recognizing the difference between a "network" (what carries IP) and an 
>> "internetwork" (the Internet itself, content slung across many 
>> networks), they demanded "network neutrality" referring to the ISP 
>> function itself.  And the FCC obliged, being basically political, by 
>> proposing the regulation of Internet services, but not regulating the 
>> actual telecom provided by the monopolists.
>> 
>> So I'm in favor of applying Title II to the actual telecommunications 
>> component of broadband services provided by incumbents, and those using 
>> rivalrous facilities (those that exclude others, including pole 
>> attachments, conduits, and exclusively-licensed frequencies).  But those 
>> who only compete with incumbent cable and telco, or who use 
>> non-rivalrous facilities and frequencies (that includes essentially all 
>> WISPs

Re: [WISPA] Quick Question: Title II, for or against?

[Kevin Sullivan]

Wow, that was well thought out. I'd say that's a pretty good assessment!

Kevin

- Original Message - 
From: "Fred Goldstein" 
To: 
Sent: Wednesday, November 19, 2014 8:26 AM
Subject: Re: [WISPA] Quick Question: Title II, for or against?


> On 11/19/2014 8:49 AM, Drew Lentz wrote:
>> I put up a quick poll, results will be shared and are anonymous.
>>
>> https://www.surveymonkey.com/s/3R6YTH9
>>
>> I'm curious to see what the percentages are between those that support 
>> and those that don't support the Title II argument. I've been trying 
>> to get a good feel for who would and wouldn't like it (mostly it seems 
>> carriers love it, web services hate it.) I have a feeling WISPs might 
>> be on the "hate it" side, but I'm interested to find out. Thanks for 
>> your answer and have a fantastic day!
>>
> 
> You asked the question very poorly, so there is no one correct answer.
> 
> "Broadband" is an adjective. You don't regulate adjectives, you regulate 
> nouns.  Broadband what? This is the fallacy of today's public discourse 
> -- they are using this adjective as a noun without the noun, so 
> different people use it to have different referents.
> 
> I think I'm in pretty close harmony with the WISPA position here, given 
> that Steve Coran chose me to help him give his NN talk in Vegas last 
> month based on my detailed Comments on the topic to the FCC.  And I've 
> been writing and Commenting on this for years. Several years ago I told 
> the FCC that they were using this adjective as a noun, but that they 
> could separate the two primary implied nouns by using a Spanish-language 
> convention.  El Broadband would refer to the physical facility, the high 
> speed transmission medium. La Broadband would refer to the content of 
> the facility, including Internet service delivered over it.  (If you 
> don't know Spanish, "el radio" is a device and "la radio" is a 
> program.)  But in lawyer terms, El Broadband is the telecommunications 
> component, and La Broadband is the information service riding atop it.
> 
> The reason NN is a Thing is that the FCC, in 2005, threw away the law 
> (TA96) and decided that telephone companies could stop being common 
> carriers, stop providing ISPs with El Broadband (raw DSL), and simply 
> sell La Broadband as a vertically-integrated service with exclusive 
> access to their formerly common-carrier facilities.  So typical 
> consumers in cities went from having many ISP choices (one cable company 
> and many ISPs available via DSL) to two (one each cable and DSL).
> 
> The public reaction to this was, understandably, rather negative. They 
> recognized that they could be screwed by their cable and telco 
> duopolists (monopolists in many areas, and more in the future as the 
> ILECs abandon their copper plant without replacing it).  But not 
> recognizing the difference between a "network" (what carries IP) and an 
> "internetwork" (the Internet itself, content slung across many 
> networks), they demanded "network neutrality" referring to the ISP 
> function itself.  And the FCC obliged, being basically political, by 
> proposing the regulation of Internet services, but not regulating the 
> actual telecom provided by the monopolists.
> 
> So I'm in favor of applying Title II to the actual telecommunications 
> component of broadband services provided by incumbents, and those using 
> rivalrous facilities (those that exclude others, including pole 
> attachments, conduits, and exclusively-licensed frequencies).  But those 
> who only compete with incumbent cable and telco, or who use 
> non-rivalrous facilities and frequencies (that includes essentially all 
> WISPs), would not fall under Title II whatsoever, and neither would the 
> Internet backbone or anything done on the Internet itself (IP layer on 
> up, but this does not refer to IP-based voice services provided by 
> facility owners).
> 
> So I'm in favor of Title II for some broadband stuff (where it opens 
> monopoly wire to competitive ISPs) but not others (where it regulates 
> the Internet or WISPs).  Got it?  That's why the question is wrong.
> 
> -- 
>  Fred R. Goldstein  k1iofred "at" interisle.net
>  Interisle Consulting Group
>  +1 617 795 2701
> 
> ___
> Wireless mailing list
> Wireless@wispa.org
> http://lists.wispa.org/mailman/listinfo/wireless
___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Sean Heskett]

also title II regulations are why an OC3 at 150Mbps costs 100 times as much
as 150Mbps metro ethernet.  Ethernet is unregulated, OC3 is part of the
whole terrified crap left over from MaBell etc.  So even though both
services are delivered over the same medium (fiber) because of the
technology used OC3 is heavily regulated while ethernet is not.

Title II will make internet access more expensive, not less.



On Wed, Nov 19, 2014 at 6:49 AM, Drew Lentz  wrote:

> I put up a quick poll, results will be shared and are anonymous.
>
> https://www.surveymonkey.com/s/3R6YTH9
>
> I'm curious to see what the percentages are between those that support and
> those that don't support the Title II argument. I've been trying to get a
> good feel for who would and wouldn't like it (mostly it seems carriers love
> it, web services hate it.) I have a feeling WISPs might be on the "hate it"
> side, but I'm interested to find out. Thanks for your answer and have a
> fantastic day!
>
> -d
>
> ___
> Wireless mailing list
> Wireless@wispa.org
> http://lists.wispa.org/mailman/listinfo/wireless
>
>
___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Robert Andrews]

Net Neutrality is the magician waving his hands so we all look at that 
while the real magic is the mergers that make it all moot... 
Everybody, watch the hand...Don't watch the other one that is 
reaching into your back pocket...Mergers are good for 
politicians...   Bigger companies write way bigger checks to politicians...



On 11/19/2014 09:26 AM, Sean Heskett wrote:
Title II is designed to breakup monopolies (i.e. Railroads, MaBell, 
Electric, Gas etc.)  everyone acts like it is the "Holy Grail" of free 
market capitalism to have the government step in and regulate 
everything your company wants to do. 


I'm not a monopoly...I have done nothing to deserve heavy handed 
government regulation oversight of everything i do.


This "Net Neutrality" BS is just that BS...They are trying to "fix" a 
problem that doesn't exist yet.


The real problem is that consumers have only the CableCo and TelCo as 
options for purchasing internet.  The government instead of regulating 
should encourage competition in the free market.  WISPs are one such 
competitor.


The government should also stop turning a blind eye to mergers like 
the Comcast & Time Warner merger that only exacerbates the problem and 
will lead us to the MaBell situation where you can get internet from 
one source only.


2 Cents

-sean

On Wed, Nov 19, 2014 at 8:50 AM, Tim Way > wrote:


Here is my confusion on this issue. Everyone is acting like it is
the great harbinger for Internet companies. One of the biggest
problems I have is lack of clear information. I'm not saying I
have any of those answers for certainty but I will point a few
things I have picked up meanwhile donning my flame proof cap.

  * Requires us to be able to provide per service reporting of
traffic (I think of it as a port span or flow-analysis of a
particular service user, which is fairly easy to do and you
should already be able to do this)
  * Talks about potentially a 16% fee on service. This will not
make you shut your doors big or small because every provider
will have to do this and I can assure you in the long run no
one is eating that cost but the consumer. Also this is
fundamentally good for rural Americans. Rural areas have phone
service because of that fund when used properly. Now it would
include proper broadband access. This is the only risk I see
to the WISP model. There is nothing that says you can't play
both sides and become a participant in utilizing the USF to
build out infrastructure even if that means doing scary things
like diving into ground models like fiber.
  * The biggest one I have is fair treatment of traffic. To me
this is the default way to run an ISP. I don't want an ISP
that slows down certain traffic and I definitely don't want to
be the service provider that does that. I'd rather see more
guaranteed bandwidth numbers and a flatter pricing scheme even
if that means a higher cost to the consumer. What I mean by
that is if you deploy 100mbps of service to an area and you
start signing up users and all the sudden you are promising
everyone 20% over what you can provide them at the head-end
don't use the words "up to" in your service agreement. Either
adjust the service speeds to control the talking on a head-end
radio or make adjustments to your architecture to accommodate
the bursts in traffic. What that might mean is more smaller
cells to service an area and yes that costs money. Nothing is
free in this world so if it costs X dollars to provide Y
services to consumers that want Y then such is life. No on
complains when they need to upgrade their electrical service
at home because they want to run more equipment or devices. If
that means I as the consumer that wants to stream HD Netflix
in 4 rooms has to upgrade my service then so be it. The
provider (You/Me) can then build out our infrastructure to
accommodate that need at the cost you and your customer agree
on or he/she just decides that their bandwidth needs doesn't
match the price point to achieve what they are trying to do
and goes back to buying DVDs through Amazon. This also works
on the upstream, as a small WISP do you really want to be on
the receiving end of a big provider possibly your only option
for decent upstream connectivity to suddenly start slowing
down certain types of traffic? Then you are faced with trying
to provide a service that your customers might demand without
any ability other than potentially an extremely expensive one
to fill that need. I think it is always better to not shape
traffic for customers. Let them manage their connection to the

Re: [WISPA] Quick Question: Title II, for or against?

[Sean Heskett]

Title II is designed to breakup monopolies (i.e. Railroads, MaBell,
Electric, Gas etc.)  everyone acts like it is the "Holy Grail" of free
market capitalism to have the government step in and regulate everything
your company wants to do. 

I'm not a monopoly...I have done nothing to deserve heavy handed government
regulation oversight of everything i do.

This "Net Neutrality" BS is just that BS...They are trying to "fix" a
problem that doesn't exist yet.

The real problem is that consumers have only the CableCo and TelCo as
options for purchasing internet.  The government instead of regulating
should encourage competition in the free market.  WISPs are one such
competitor.

The government should also stop turning a blind eye to mergers like the
Comcast & Time Warner merger that only exacerbates the problem and will
lead us to the MaBell situation where you can get internet from one source
only.

2 Cents

-sean


On Wed, Nov 19, 2014 at 8:50 AM, Tim Way  wrote:

> Here is my confusion on this issue. Everyone is acting like it is the
> great harbinger for Internet companies. One of the biggest problems I have
> is lack of clear information. I'm not saying I have any of those answers
> for certainty but I will point a few things I have picked up meanwhile
> donning my flame proof cap.
>
>
>- Requires us to be able to provide per service reporting of traffic
>(I think of it as a port span or flow-analysis of a particular service
>user, which is fairly easy to do and you should already be able to do this)
>- Talks about potentially a 16% fee on service. This will not make you
>shut your doors big or small because every provider will have to do this
>and I can assure you in the long run no one is eating that cost but the
>consumer. Also this is fundamentally good for rural Americans. Rural areas
>have phone service because of that fund when used properly. Now it would
>include proper broadband access. This is the only risk I see to the WISP
>model. There is nothing that says you can't play both sides and become a
>participant in utilizing the USF to build out infrastructure even if that
>means doing scary things like diving into ground models like fiber.
>- The biggest one I have is fair treatment of traffic. To me this is
>the default way to run an ISP. I don't want an ISP that slows down certain
>traffic and I definitely don't want to be the service provider that does
>that. I'd rather see more guaranteed bandwidth numbers and a flatter
>pricing scheme even if that means a higher cost to the consumer. What I
>mean by that is if you deploy 100mbps of service to an area and you start
>signing up users and all the sudden you are promising everyone 20% over
>what you can provide them at the head-end don't use the words "up to" in
>your service agreement. Either adjust the service speeds to control the
>talking on a head-end radio or make adjustments to your architecture to
>accommodate the bursts in traffic. What that might mean is more smaller
>cells to service an area and yes that costs money. Nothing is free in this
>world so if it costs X dollars to provide Y services to consumers that want
>Y then such is life. No on complains when they need to upgrade their
>electrical service at home because they want to run more equipment or
>devices. If that means I as the consumer that wants to stream HD Netflix in
>4 rooms has to upgrade my service then so be it. The provider (You/Me) can
>then build out our infrastructure to accommodate that need at the cost you
>and your customer agree on or he/she just decides that their bandwidth
>needs doesn't match the price point to achieve what they are trying to do
>and goes back to buying DVDs through Amazon. This also works on the
>upstream, as a small WISP do you really want to be on the receiving end of
>a big provider possibly your only option for decent upstream connectivity
>to suddenly start slowing down certain types of traffic? Then you are faced
>with trying to provide a service that your customers might demand without
>any ability other than potentially an extremely expensive one to fill that
>need. I think it is always better to not shape traffic for customers. Let
>them manage their connection to the Internet. Instead for high throughput
>applications we should push for the option to deploy CDN like edge devices
>from these larger service providers if the actual throughput is not
>available or more costly.
>
> Alright I've got my flame retardant cap on let the replies flood in :)
>
> Tim
>
>
> On Wed, Nov 19, 2014 at 9:24 AM, Sam Tetherow  wrote:
>
>>  I'm guessing that while the phone companies may not like the idea it
>> seems a little less onerous to them since they are already dealing with
>> Title II.  If nothing else it will weed out the smaller competition in
>> their eyes.
>>
>> While t

Re: [WISPA] Quick Question: Title II, for or against?

[Sam Tetherow]

The 16% fee may not be enough to cover the reporting costs.  This is why 
I said depending on how the rules shake out, since this is all still up 
in the air as to what out of Title II would actually be applied to 
broadband.  It is possible that we could get all of the reporting 
requirements and none of the funding.  Or we could get funding for the 
reporting requirements, or we can get small business exemptions, or who 
knows what subset...


As far as fair treatment of traffic, while I agree with you on principal 
(and in practice currently), a big part of the problem is consumer 
education.  If you want to be 100% transparent 99% of the consumers eyes 
are going to glaze over 5 minutes in and they will go somewhere simpler 
(like the folks that gloss over all the details). Some days it is 
difficult to explain the difference between speed and download, "I get 
10 gigabytes with Verizon, why are you only doing 6 megabits?"  Let 
alone the fact that the majority of customers don't have any handle on 
how much speed they need or download they will use so all of the 
transparency will be meaningless to them.


The other problem which was brought out largely by netflix (and other 
streaming video) is the over-subscription model changed drastically and 
with little warning, granted that was a couple years ago, and I think 
most ISPs have found ways to adapt, but for some it was a more costly 
adaptation than for others, not everyone gets sub $5/mbps pricing for 
bandwidth and not everyone can just hang more sectors at a minimal cost 
increase.  In the last 10 years I have went from a 25 to 1 
over-subscription down to 6 to 1 and my bottleneck has moved from my 
upstream to my final hop to the customer.


It is unrealistic to think you can manage with a 1-1 over-subscription 
model, and you will be leaving money on the table.  The 'up to' is CYA 
terminology for ios release day and other large spikes in customer base 
traffic.  It shouldn't be relied on for 6pm-10pm netflix viewing 
congestion other than normal growing pains while you upgrade equipment 
to handle the increased usage.


On 11/19/2014 09:50 AM, Tim Way wrote:
Here is my confusion on this issue. Everyone is acting like it is the 
great harbinger for Internet companies. One of the biggest problems I 
have is lack of clear information. I'm not saying I have any of those 
answers for certainty but I will point a few things I have picked up 
meanwhile donning my flame proof cap.


  * Requires us to be able to provide per service reporting of traffic
(I think of it as a port span or flow-analysis of a particular
service user, which is fairly easy to do and you should already be
able to do this)
  * Talks about potentially a 16% fee on service. This will not make
you shut your doors big or small because every provider will have
to do this and I can assure you in the long run no one is eating
that cost but the consumer. Also this is fundamentally good for
rural Americans. Rural areas have phone service because of that
fund when used properly. Now it would include proper broadband
access. This is the only risk I see to the WISP model. There is
nothing that says you can't play both sides and become a
participant in utilizing the USF to build out infrastructure even
if that means doing scary things like diving into ground models
like fiber.
  * The biggest one I have is fair treatment of traffic. To me this is
the default way to run an ISP. I don't want an ISP that slows down
certain traffic and I definitely don't want to be the service
provider that does that. I'd rather see more guaranteed bandwidth
numbers and a flatter pricing scheme even if that means a higher
cost to the consumer. What I mean by that is if you deploy 100mbps
of service to an area and you start signing up users and all the
sudden you are promising everyone 20% over what you can provide
them at the head-end don't use the words "up to" in your service
agreement. Either adjust the service speeds to control the talking
on a head-end radio or make adjustments to your architecture to
accommodate the bursts in traffic. What that might mean is more
smaller cells to service an area and yes that costs money. Nothing
is free in this world so if it costs X dollars to provide Y
services to consumers that want Y then such is life. No on
complains when they need to upgrade their electrical service at
home because they want to run more equipment or devices. If that
means I as the consumer that wants to stream HD Netflix in 4 rooms
has to upgrade my service then so be it. The provider (You/Me) can
then build out our infrastructure to accommodate that need at the
cost you and your customer agree on or he/she just decides that
their bandwidth needs doesn't match the price point to achieve
what they are trying to do and goes back to buying DVDs through
Amazon.

Re: [WISPA] Quick Question: Title II, for or against?

[Fred Goldstein]

On 11/19/2014 8:49 AM, Drew Lentz wrote:
> I put up a quick poll, results will be shared and are anonymous.
>
> https://www.surveymonkey.com/s/3R6YTH9
>
> I'm curious to see what the percentages are between those that support 
> and those that don't support the Title II argument. I've been trying 
> to get a good feel for who would and wouldn't like it (mostly it seems 
> carriers love it, web services hate it.) I have a feeling WISPs might 
> be on the "hate it" side, but I'm interested to find out. Thanks for 
> your answer and have a fantastic day!
>

You asked the question very poorly, so there is no one correct answer.

"Broadband" is an adjective. You don't regulate adjectives, you regulate 
nouns.  Broadband what? This is the fallacy of today's public discourse 
-- they are using this adjective as a noun without the noun, so 
different people use it to have different referents.

I think I'm in pretty close harmony with the WISPA position here, given 
that Steve Coran chose me to help him give his NN talk in Vegas last 
month based on my detailed Comments on the topic to the FCC.  And I've 
been writing and Commenting on this for years. Several years ago I told 
the FCC that they were using this adjective as a noun, but that they 
could separate the two primary implied nouns by using a Spanish-language 
convention.  El Broadband would refer to the physical facility, the high 
speed transmission medium. La Broadband would refer to the content of 
the facility, including Internet service delivered over it.  (If you 
don't know Spanish, "el radio" is a device and "la radio" is a 
program.)  But in lawyer terms, El Broadband is the telecommunications 
component, and La Broadband is the information service riding atop it.

The reason NN is a Thing is that the FCC, in 2005, threw away the law 
(TA96) and decided that telephone companies could stop being common 
carriers, stop providing ISPs with El Broadband (raw DSL), and simply 
sell La Broadband as a vertically-integrated service with exclusive 
access to their formerly common-carrier facilities.  So typical 
consumers in cities went from having many ISP choices (one cable company 
and many ISPs available via DSL) to two (one each cable and DSL).

The public reaction to this was, understandably, rather negative. They 
recognized that they could be screwed by their cable and telco 
duopolists (monopolists in many areas, and more in the future as the 
ILECs abandon their copper plant without replacing it).  But not 
recognizing the difference between a "network" (what carries IP) and an 
"internetwork" (the Internet itself, content slung across many 
networks), they demanded "network neutrality" referring to the ISP 
function itself.  And the FCC obliged, being basically political, by 
proposing the regulation of Internet services, but not regulating the 
actual telecom provided by the monopolists.

So I'm in favor of applying Title II to the actual telecommunications 
component of broadband services provided by incumbents, and those using 
rivalrous facilities (those that exclude others, including pole 
attachments, conduits, and exclusively-licensed frequencies).  But those 
who only compete with incumbent cable and telco, or who use 
non-rivalrous facilities and frequencies (that includes essentially all 
WISPs), would not fall under Title II whatsoever, and neither would the 
Internet backbone or anything done on the Internet itself (IP layer on 
up, but this does not refer to IP-based voice services provided by 
facility owners).

So I'm in favor of Title II for some broadband stuff (where it opens 
monopoly wire to competitive ISPs) but not others (where it regulates 
the Internet or WISPs).  Got it?  That's why the question is wrong.

-- 
  Fred R. Goldstein  k1iofred "at" interisle.net
  Interisle Consulting Group
  +1 617 795 2701

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Scott Reed]

Have you looked at the real cost involved in providing all of the 
reporting you are going to have to do?


Fundamental difference of opinion on, "Also this is fundamentally good 
for rural Americans." Regulation seldom makes it better for the consumer 
in the long run.  Just higher cost; as you state, the consumer will foot 
the bill.  I see things like USF as a form of double taxation.  I pay my 
taxes so someone in the government decides I should pay another fee.


On 11/19/2014 10:50 AM, Tim Way wrote:
Here is my confusion on this issue. Everyone is acting like it is the 
great harbinger for Internet companies. One of the biggest problems I 
have is lack of clear information. I'm not saying I have any of those 
answers for certainty but I will point a few things I have picked up 
meanwhile donning my flame proof cap.


  * Requires us to be able to provide per service reporting of traffic
(I think of it as a port span or flow-analysis of a particular
service user, which is fairly easy to do and you should already be
able to do this)
  * Talks about potentially a 16% fee on service. This will not make
you shut your doors big or small because every provider will have
to do this and I can assure you in the long run no one is eating
that cost but the consumer. Also this is fundamentally good for
rural Americans. Rural areas have phone service because of that
fund when used properly. Now it would include proper broadband
access. This is the only risk I see to the WISP model. There is
nothing that says you can't play both sides and become a
participant in utilizing the USF to build out infrastructure even
if that means doing scary things like diving into ground models
like fiber.
  * The biggest one I have is fair treatment of traffic. To me this is
the default way to run an ISP. I don't want an ISP that slows down
certain traffic and I definitely don't want to be the service
provider that does that. I'd rather see more guaranteed bandwidth
numbers and a flatter pricing scheme even if that means a higher
cost to the consumer. What I mean by that is if you deploy 100mbps
of service to an area and you start signing up users and all the
sudden you are promising everyone 20% over what you can provide
them at the head-end don't use the words "up to" in your service
agreement. Either adjust the service speeds to control the talking
on a head-end radio or make adjustments to your architecture to
accommodate the bursts in traffic. What that might mean is more
smaller cells to service an area and yes that costs money. Nothing
is free in this world so if it costs X dollars to provide Y
services to consumers that want Y then such is life. No on
complains when they need to upgrade their electrical service at
home because they want to run more equipment or devices. If that
means I as the consumer that wants to stream HD Netflix in 4 rooms
has to upgrade my service then so be it. The provider (You/Me) can
then build out our infrastructure to accommodate that need at the
cost you and your customer agree on or he/she just decides that
their bandwidth needs doesn't match the price point to achieve
what they are trying to do and goes back to buying DVDs through
Amazon. This also works on the upstream, as a small WISP do you
really want to be on the receiving end of a big provider possibly
your only option for decent upstream connectivity to suddenly
start slowing down certain types of traffic? Then you are faced
with trying to provide a service that your customers might demand
without any ability other than potentially an extremely expensive
one to fill that need. I think it is always better to not shape
traffic for customers. Let them manage their connection to the
Internet. Instead for high throughput applications we should push
for the option to deploy CDN like edge devices from these larger
service providers if the actual throughput is not available or
more costly.

Alright I've got my flame retardant cap on let the replies flood in :)

Tim


On Wed, Nov 19, 2014 at 9:24 AM, Sam Tetherow > wrote:


I'm guessing that while the phone companies may not like the idea
it seems a little less onerous to them since they are already
dealing with Title II.  If nothing else it will weed out the
smaller competition in their eyes.

While the cable companies or more strongly in the hate it camp I
doubt they will be getting out of the business if it comes about.

Depending on what requirements actually come out of Title II for
ISPs will probably have several WISPs close their doors.  If there
isn't some sort of small business exemption I doubt I will stay in
the business.


On 11/19/2014 07:51 AM, Mike Hammett wrote:

I can't imagine why anyone other than a blind consumer would

Re: [WISPA] Quick Question: Title II, for or against?

[Tim Way]

Here is my confusion on this issue. Everyone is acting like it is the great
harbinger for Internet companies. One of the biggest problems I have is
lack of clear information. I'm not saying I have any of those answers for
certainty but I will point a few things I have picked up meanwhile donning
my flame proof cap.


   - Requires us to be able to provide per service reporting of traffic (I
   think of it as a port span or flow-analysis of a particular service user,
   which is fairly easy to do and you should already be able to do this)
   - Talks about potentially a 16% fee on service. This will not make you
   shut your doors big or small because every provider will have to do this
   and I can assure you in the long run no one is eating that cost but the
   consumer. Also this is fundamentally good for rural Americans. Rural areas
   have phone service because of that fund when used properly. Now it would
   include proper broadband access. This is the only risk I see to the WISP
   model. There is nothing that says you can't play both sides and become a
   participant in utilizing the USF to build out infrastructure even if that
   means doing scary things like diving into ground models like fiber.
   - The biggest one I have is fair treatment of traffic. To me this is the
   default way to run an ISP. I don't want an ISP that slows down certain
   traffic and I definitely don't want to be the service provider that does
   that. I'd rather see more guaranteed bandwidth numbers and a flatter
   pricing scheme even if that means a higher cost to the consumer. What I
   mean by that is if you deploy 100mbps of service to an area and you start
   signing up users and all the sudden you are promising everyone 20% over
   what you can provide them at the head-end don't use the words "up to" in
   your service agreement. Either adjust the service speeds to control the
   talking on a head-end radio or make adjustments to your architecture to
   accommodate the bursts in traffic. What that might mean is more smaller
   cells to service an area and yes that costs money. Nothing is free in this
   world so if it costs X dollars to provide Y services to consumers that want
   Y then such is life. No on complains when they need to upgrade their
   electrical service at home because they want to run more equipment or
   devices. If that means I as the consumer that wants to stream HD Netflix in
   4 rooms has to upgrade my service then so be it. The provider (You/Me) can
   then build out our infrastructure to accommodate that need at the cost you
   and your customer agree on or he/she just decides that their bandwidth
   needs doesn't match the price point to achieve what they are trying to do
   and goes back to buying DVDs through Amazon. This also works on the
   upstream, as a small WISP do you really want to be on the receiving end of
   a big provider possibly your only option for decent upstream connectivity
   to suddenly start slowing down certain types of traffic? Then you are faced
   with trying to provide a service that your customers might demand without
   any ability other than potentially an extremely expensive one to fill that
   need. I think it is always better to not shape traffic for customers. Let
   them manage their connection to the Internet. Instead for high throughput
   applications we should push for the option to deploy CDN like edge devices
   from these larger service providers if the actual throughput is not
   available or more costly.

Alright I've got my flame retardant cap on let the replies flood in :)

Tim


On Wed, Nov 19, 2014 at 9:24 AM, Sam Tetherow  wrote:

>  I'm guessing that while the phone companies may not like the idea it
> seems a little less onerous to them since they are already dealing with
> Title II.  If nothing else it will weed out the smaller competition in
> their eyes.
>
> While the cable companies or more strongly in the hate it camp I doubt
> they will be getting out of the business if it comes about.
>
> Depending on what requirements actually come out of Title II for ISPs will
> probably have several WISPs close their doors.  If there isn't some sort of
> small business exemption I doubt I will stay in the business.
>
>
> On 11/19/2014 07:51 AM, Mike Hammett wrote:
>
> I can't imagine why anyone other than a blind consumer would love it.
>
>
>
> -
> Mike Hammett
> Intelligent Computing Solutions
> http://www.ics-il.com
>
>  
> 
> 
> 
>
>  --
> *From: *"Drew Lentz"  
> *To: *"WISPA General List"  
> *Sent: *Wednesday, November 19, 2014 7:49:20 AM
> *Subject: *[WISPA] Quick Question: Title II, for or against?
>
> I put up a quick poll, results will be shared and are anonymous.
>
>  https://www.surveymonkey.com/s/3R6YTH9
>
>  I'm curio

Re: [WISPA] Quick Question: Title II, for or against?

[Sam Tetherow]

I'm guessing that while the phone companies may not like the idea it 
seems a little less onerous to them since they are already dealing with 
Title II.  If nothing else it will weed out the smaller competition in 
their eyes.


While the cable companies or more strongly in the hate it camp I doubt 
they will be getting out of the business if it comes about.


Depending on what requirements actually come out of Title II for ISPs 
will probably have several WISPs close their doors.  If there isn't some 
sort of small business exemption I doubt I will stay in the business.


On 11/19/2014 07:51 AM, Mike Hammett wrote:

I can't imagine why anyone other than a blind consumer would love it.



-
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com




*From: *"Drew Lentz" 
*To: *"WISPA General List" 
*Sent: *Wednesday, November 19, 2014 7:49:20 AM
*Subject: *[WISPA] Quick Question: Title II, for or against?

I put up a quick poll, results will be shared and are anonymous.

https://www.surveymonkey.com/s/3R6YTH9

I'm curious to see what the percentages are between those that support 
and those that don't support the Title II argument. I've been trying 
to get a good feel for who would and wouldn't like it (mostly it seems 
carriers love it, web services hate it.) I have a feeling WISPs might 
be on the "hate it" side, but I'm interested to find out. Thanks for 
your answer and have a fantastic day!


-d

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless



___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless


___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless

Re: [WISPA] Quick Question: Title II, for or against?

[Mike Hammett]

I can't imagine why anyone other than a blind consumer would love it. 




- 
Mike Hammett 
Intelligent Computing Solutions 
http://www.ics-il.com 



- Original Message -

From: "Drew Lentz"  
To: "WISPA General List"  
Sent: Wednesday, November 19, 2014 7:49:20 AM 
Subject: [WISPA] Quick Question: Title II, for or against? 


I put up a quick poll, results will be shared and are anonymous. 


https://www.surveymonkey.com/s/3R6YTH9 


I'm curious to see what the percentages are between those that support and 
those that don't support the Title II argument. I've been trying to get a good 
feel for who would and wouldn't like it (mostly it seems carriers love it, web 
services hate it.) I have a feeling WISPs might be on the "hate it" side, but 
I'm interested to find out. Thanks for your answer and have a fantastic day! 


-d 
___ 
Wireless mailing list 
Wireless@wispa.org 
http://lists.wispa.org/mailman/listinfo/wireless 

___
Wireless mailing list
Wireless@wispa.org
http://lists.wispa.org/mailman/listinfo/wireless