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Technology Stocks : FCC Regulations

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To: Kenneth E. De Paul who wrote (51)6/27/1999 10:41:00 AM
From: Frank A. Coluccio   of 54
 
Hello Ken,

"What do you think will happen with openning up cable offices to competition in light of the Oregon court decision and the FCC's statement that it might reverse that decision? Do you think the FCC will be forced to change its stance?"

In my opinion, the landscape as defined by the current physical attributes of HFC systems cannot withstand an onslaught from numerous ISPs, for reasons which I've documented on the ATHM and Last Mile threads many times. So, I wont get into the block diagram specifics here again, unless someone asks.

The cable modem architecture was never designed in its current state to support more than one service provider with the full breadth of capabilities needed to ensure end to end services of current and future multimedia features. Likewise for security, account admin and future QoS. There are simply too many software and hardware hooks and switches at the modem and head end levels, to be tuned on the fly for too many modes of utilization, to allow more than one cook to manage the stew.

Having said that, I do believe that these issues can be resolved with another pass of the DOCSIS standards, and with some redoing of the spectrum plans for both upstream and downstream allocation treatment, but this would take considerable time to retrofit and not something that could be done overnight except perhaps to support an additional one or two players, with the usual penalties that are exacted whenever a band-aid approach is used as a substitute for precise design and proper engineering.

The FCC change its stance?

It's not a matter of if, but when. I don't know when, but at some point the FCC will reverse its angelical view of T's activities, reversing itself from its current forbearance to a more traditional role whereby it will seek to open up of the markets.

Ironically, and I have to hypothesize here for a moment and disclaim any personal preference in this regard, if cable proves to be all that it says it is, then it will come to dominate many different areas (in many different dimensions) of "broadband delivery" at some point. It's too illogical to assume, then, that the regs would allow any one player in a serving area to monopolize Internet access, especially by the entrant whose framework proves to be best suited at it.

Again, hypothetically speaking. But this demonstrates how the cable industry's own worst enemy in this respect may very well prove to be, at some point, its own success.

Whether intentionally for strategic purposes, or by default during a earlier era when the MSOs didn't know any better, or otherwise, their architecture was designed to be administered and exploited by a single service provider, only. That service provider could be the MSO itself as in the case of TWX/RR, or a consortium proxy like ATHM (or any other ISP or enhanced service provider) using a MSO consortium player like TCI or Comcast, etc., as a facilities-based custodian of services. That's exactly what we have now with ATHM, isn't it?

The architectural matters I've alluded to are facts that can be either inferred or traced directly to the head-end and cable-modem DOCSIS standards, and other associated packet based cable standards looking into the future.

Regards, Frank Coluccio
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