Bill, another well though-out reply, thanks. Was my tongue pressing the wall? Yes, in a way, but with an extreme amount, let me repeat that, with an extreme amount, of reverse tension being applied.
Let me see how much of your message I can reply to while I have some time left for lunch. Don't mind me if I type with food in my mouth.
Notice is Hereby Given to Onviewers: This is only a high-level academic discussion!
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FAC: >Perhaps there should be four franchising privileges in every locale for the ILEC, the CableCo, the utility company, and a fourth one for all others.<
WTC: >>Why limit wireline access competitors (CLECs) as long as there is no inherent limitation like spectrum?<<
If you view the totality of my upstream message, this suggestion was only one of several options, and in retrospect it could have been lumped into several permutations with the others. But we'll take it as a standalone for now, for discussion purposes. And that's all this is, an academic discussion, lest anyone conclude differently.
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Spectrum is a scarce resource, according to many [and some disagree, depending on their modulation choice du jour], and that is why it's rationed, allocated and ultimately regulated. And I'm sure there are some more sinister reasons that some may offer up here, but I'd rather not get into those now.
Pole space and interconnection attachments, and real estate in the pedestal, all fit into this category, as well.
The potential confusion caused by dozens if not hundreds of aspiring CLECs, all contending for interconnection in the field... where the unbundled wire elements, or UNEs, would be broken out, is great, and I would suggest in many parts, untenable. One could envision a single household having live connections in place to three or five different providers, one to suit a different specialization in the future. Which isn't all bad, just unwieldy, to the point of impractical.
[I can see the last mile access aggregators lining up at the door now.]
You've made this last point yourself in an earlier post, which is what started me off on this hunt in the first place.
I'd rather not refer back to photos which by now are cliche, depicting the maze of pole attachments that once mired the 'landscape' of Wall Street during the turn of the century. But these visions are not beyond contemplation when it comes to the present-day situation we are discussing at the UNE in many regions and locales, and certainly in suburban and urban areas.
Micro miniaturization can, in fact, be used to ameliorate the potential gravity of this situation, say, by the use of digital routing and cross connect assemblies, but said components would be neutral in nature, leaving the unanswered question as to who would pay for them? And to take this approach at the routing level, then, would be no different than to unbundle the upper layers as I've offered in another option, at the central office or deeper into the cloud.
This is where the buildout for "all others" option comes in.
If such a fourth buildout were permitted by all non-ILEC contenders under the auspices of a consortium umbrella effort, then it's at least plausible that these answers could get answered. I know that this would be a Manhattan Project-like undertaking, but if that's what it takes to win a war, then so be it.
The fourth build out would not represent hardly as much of an egregious environmental impact, or administrative boondoggle with a recalcitrant ILEC or CableCo MSO, as would be the case if the multitudes were allowed to pull cable and dig up controlled environmental vaults (CEVs) one by one. And to do a one-by-one deployment of physical latey, would cause each player to price themselves out of business before they could ever got started.
Rather, it would be a single endeavor at the physical layer (hopefully all fiber, with copper coax and t.p. pigtails being limited to rare cases) using fiber as a least common denominator, potentially to the residence or business location as well, with neighborhood caging for up to a certain amount of competitors [here we go again, how many would a certain amount be?] which could be overseen by quasi-municpal entities, or professionally run colo businesses, a la re-engineered carrier hotels.
The Q-M or colo entities' charters would include Chamber of Commerce-like verbiage in every case. The full service area network (FSAN) architecture would do nicely here, but that would only be one economy-size options for the competitors. Other overlays would be permitted on the basis of space division, or routing, or whatever.
WTC: >>Isn't a taxi medallion, or an IBM reseller medallion of old, about as anti-competitive as it gets? Aren't these designed quite specifically to protect incumbants from the downward price pressure that comes from unrestrained new competitive entrants? Where is the public good there?<<
In a way, that's correct. The medallions, along with testing and licensing, are also designed to ensure that some minimum qualifications are met prior to allowing entry (or at least that was the initial intend... please, no cabby jokes here...;-)
But my point about minimum qualifications should not be lost in this discussion. Every future connection on the 'net, whether physical or virtual, will have the potential of affecting service to every other point on the 'net... dependent on where a call is initiated from and to. We'll leave carrier certification, however, to another thread.
WTC: >>I think you are mixing baseline situations and reaching a highly suspect conclusion (I'm assuming here that your tongue is not pushed hard into the side of your face.)<<
FAC: Like I said, reverse tension was used.
WTC: >>Your examples are all based on limited allocation of spectrum -- the FCC needed some way to fit 'x' prospective service providers each needing 'y' MHz of spectrum into 'n' MHz of spectrum available. We might argue that the results from comparative hearings, lotteries, and some auctions are so ugly that we certainly don't want to go there unless there is no choice whatever. There certainly seem to be choices with wireline.<<
FAC: What are they? Assuming that unlimited access is permitted, of course. On that score, if there were only a handful of fools, er... competitors, who would want to get into this race, I too would see no problems except for the artificial barriers that have already been erected by the incumbents.
WTC: >>This is a cogent argument (perhaps unintentional) against some interesting ideas that have been put forward by Diamond Lane proposing what they term "Logical Collocation" -- what has been termed elsewhere in discussions "virtual collocation." ...Under that scheme, the ILEC would sell and deliver a UNE or a combination of "glued" UNEs that incorporate ILEC subloops, ILEC DSLAMs, ILEC ATU-R and ATU-C, and ILEC fiber backhaul facilities from the remote DSLAM to a CO hand-off point, say, the MDF. Those ideas have a lot of merit for sidestepping the snarl of collocation complexity in field locations, but they create some new requirements for new shared access DSL management systems that all participating CLECs can access, with the ILEC presumably managing the (OSS)system. <<
FAC: We were good up until that last sentence. In my scenario, the OSSs would be the purview of a company or other form of entity whose "business" was solely that of colocation. There are a growing number of such firms, who I am sure would be more than happy to take on such an undertaking on a cost-plus basis.
WTC: >>Such a system does not presently exist, but it would not seem like a man-to-the-moon level development effort.<<
What'e the alternative? We've waited three years come next month to see the fruits of regulated deregulation, and nada. Actually, while we're discussing this, I think that LVLT is already onto this opportunity, and they are already proceeding with a colo model [that combines at least two of my stated options] that may be a good fit here, although their means of transport may differ radically from what some of the CLECs have in mind.
WTC: >> The bigger criticism of such a plan has to be that it could discourage innovation and delivery of new services via new DSL technology that is not part of the ILECs "approved list" of compatible and supported vendors/models.<<
FAC: BINGO!
WTC: >>This problem hurts everyone: the customers could be denied the benefits of innovation; the CLECs could be denied opportunities for differentiation in the market; <<
Not under my neighborhood caging scheme
WTC: >>...and the ILECs descend into a purgatory where everyone is mad at them even though they are working very hard in good faith to deliver what they promised, probably successfully at some point.<<
FAC: I won't argue your assessment, except to state that it may be true over time, because it would require prescience on my part. But there is something intrinsically wrong with a model that has the hens continuously being cared for, and nurtured, and monitored, by the fox. And that is precisely what we would have here under a UNE model, structural separations or no structural separations, IMO.
WTC: >>The requirements would certainly be constantly in flux, with new technological capablities needing to be added to the "supported" list faster that the ILECs can assure themselves the new items work as promised, and don't interfere with the rest of the installed "approved" hardware and software. <<
Such would be the case if we followed the road to ILEC reuse and collocation. It need not, however, be the case in a totally partitioned fourth buildout scenario.
Lunch is now over. I'll look forward to replying to the remainder of your message later on tonight. In the meantime, comments and corrections are always welcome.
Regards, Frank Coluccio |
