Monday, September 15, 2014

FCC Open Internet Comment

I submitted my comment to the FCC today (yes, I waited til the very last day).

It wasn't exactly on point with what the FCC wanted, but then the FCC wasn't very on point with what I wanted.

This feels pretty off-topic for the website, but I figure if I feel strongly enough about it send the FCC an email, I should feel strongly enough about it to leave a public record. Click on through if you are bored enough to read my thoughts on what the FCC should do about the internet.

Dear FCC,

I am not a networking specialist, and I don't pretend to know more than the cable company experts about how internet transit works, nor do I pretend to understand the law better than the FCC commissioners.

I do know that in the nine residences (apartments and stand-alone houses) in 7 cities in 3 states I have lived in in the past 5 years, Comcast was the only company that could provide me internet access greater than 15Mb/s. In fact, only in one location was there another company that could provide anything greater than 10Mb/s.

I know that despite the high advertised speeds I paid for, YouTube and Netflix were unusably slow when I got home from work around 6pm.

I know that proclaiming rules that a monopoly must "be better" is a fool's errand - at best, at best, you might get grudging, delayed cooperation. Most likely, the monopoly will shrug their collective shoulders and tell you they're doing the best they can.

The best way that I know of to improve a market is to have competition. Given the high cost of laying cable or fiber to individual houses and housing complexes, I can only see two paths to achieving a competitive marketplace in the near future, and one promising one in the long term.

1) Bring in Wireless Competition

Hope for a major market shift in the wireless internet industry. This is a long shot, but it does solve the "last mile" problem. And nominal LTE speeds exceed many advertised cable speeds. But it comes with the enormous handicap of tiny data caps. Most of the "Big Four" wireless companies effectively cap LTE data to 5 gigabytes (whether they cut you off, or drop you to an older, slower "2G" data connection depends on the carrier). That's one fiftieth of Comcast's old "don't call it a data cap" 250 gigabyte data cap, and an even smaller fraction of whatever they are currently not calling a data cap.

One way to help Wireless technology to compete with landline technology would be to eliminate the spectrum auctions. The wireless spectrum in the airspace of the United States is owned by the people of the United States. It is managed for the US Government by the FCC and periodically licensed out to companies for their exclusive use over a period of years. While this has been very effective fundraising for the government, it creates an artificial scarcity of spectrum, as the "Big Four" each try to have enough spectrum in a given region to serve the entire market, and as smaller companies hoard slivers of spectrum in disparate regions, hoping to wheel and deal their way into a national network.

The standardization of wireless networks on to LTE technology is an unprecedented opportunity to have all wireless carriers in the country share spectrum. If companies are no longer driving up the price of artificially scarce spectrum, prices on service would (ideally) fall. Obviously, this is regulation of an even greater degree than the landline companies are currently facing, and thus will be opposed even more vociferously than the cable companies are currently opposing regulation.

2) Regulate or Even Nationalize the "Last Mile".

Cable and Telco companies were granted exclusive monopolies on telecommunication and internet service to specific regions in order to financially incent them to build out their networks for the good of the people of the United States. In a large part, this method has succeeded, though the situation in New Jersey with Verizon springs to mind of a company over-promising and under-delivering on it's bargain for exclusivity. 

Even without the legal guarantee of a monopoly, the high cost in capital and time that would be required for a start-up to build out a redundant, competing network to all it's potential clients is prohibitive. Even Google, with it's vast cash reserves and willingness to spend money on moon-shots, is severely limiting the rollout of Google Fiber to a few cities which have strategic advantages (city controlled right-of-way, lot of dark fiber, etc) that many other cities do not possess.

But serviceable networks already exist. The cable companies and telcos have largely already reaped their rewards for the capital they laid out decades ago (I don't mean to advocate that the government should steal the property - I would fully endorse the idea of a company having period, say, 5 to 10 years, of exclusive access to cables, whether fiber or copper, that it directly finances and installs). These "last mile" sections of cable should be opened up for use by anyone able to pay a wholesale fee to the telco. With an influx of competition, the interconnection problems publicized by Netflix should largely disappear as Internet service providers compete for customers, rather than try to sell access to those very same customers.

3) Strike Down State Bans on Municipal Internet

The sheer hypocrisy of state officials ignoring local governments while telling the federal government they know what's best for their constituents because they are "closer" to the voters is astounding. Please strike down the bans against municipal internet. Sure, some programs have been mismanaged. Others are doing great. Just because a cable company *might* want to someday offer service in a region is no reason to ban people from organizing and supplying their own internet service now. It is a ludicrous situation that should never have happened. Allow people to compete, on their own, against the telcos. Competition won't spring up overnight, or even in the next few years, as it might in options 1 and 2. But in the long run, this is the surest way of breaking cable company monopolies.


One more complaint - enforcement of telecommunication regulations need to be cleaned up a bit. It is crazy that Verizon can run one fiber cable and claim it under Title II as a telephone service in order to get access to Title II right-of-ways and tax benefits, and turn around and claim Title VI as a cable company when another company wishes to use the cable under Title II! It's one cable, and rules should apply to that one cable consistently


That's how things look from my position down on the ground. 

In closing: I do not believe Chairman Tom Wheeler is a Dingo. Please prove me right.


-Brian Medema

1 comment:

  1. VERY INTERESTING thoughts. I believe unregulated Wi-Fi might work...but the issue of wi-fi vs. wire is one of physics (that's why 802.11N was created to allow two streams to the same device to make it seem faster). Wire/fiber has so much capability in speed and multiplexing. I REALLY like the idea of nationalizing the last mile...when I was working that would have fixed so many of my tele headaches.