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Technology Stocks : FCC Regulations -- Ignore unavailable to you. Want to Upgrade?


To: Kenneth E. De Paul who wrote (51)6/27/1999 10:41:00 AM
From: Frank A. Coluccio  Respond to 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



To: Kenneth E. De Paul who wrote (51)6/27/1999 12:17:00 PM
From: Frank A. Coluccio  Read Replies (1) | Respond to of 54
 
Ken, I should have added that in a pinch, it would actually be possible to force fit the universe of ISPs onto the cable channels now being used (or additional ones, for that matter) in some Rube Goldberg kind of way. Heck, it's done all the time at many SP routers in the dialup ISP regime. Note the results of that approach, however. The performance is usually so paltry that it serves as the primary impetus for going for cable modem access and DSL access, in the first place. As Dr. AHhaha has stated already in so many words on the ATHM thread (if my memory serves me correctly), opening up the cable modem pipes for the universe of ISPs at this time would be a Pyrrhic victory for them, at best.

GTE and AOL both recently grandstanded this capability, along with another local GTE-affiliated ISP, I believe, to demonstrate that open access is actually feasible. And, depending on your expectations, it is.

But that demo was in my opinion only a gambit, a major ploy, as far as I'm concerned. Either it was a very embarrassing ploy in the presence of the more enlightened, or someone at AOL had better start using their calculator.

I say this because neither AOL nor any other ISP would want to live with the eventual consequences if such an open access model were made available today under the current state of MSO implementations. If you take my last italicized qualifier into account, then it becomes clear that modifications are required, which are going to be both costly and time consuming, in order to upgrade the HFC model to a state where it could support everyone equally, and with the same feature sets as those currently available (and planned) by the cable industry.

[[I haven't heard any mention of how this would eventually be funded, nor have I heard of any reasonable time frames under which such an enhancement could begin to take place. Everyone, even T (for some inexplicable reason) is avoiding the specifics of these issues. Go figure. The only thing I can think of is that no one want to show their hand right now, keeping their options open, deferring to the possibility of yet additional negotiating ploys down the road. This, whether they can feasibly fulfill on any additional promises, or not. That's the way it's played today.]]

What this all means is this: Yes, it's possible to remove some of the architectural elements which represent barriers to multiple entry, those which are are essential to quality delivery, and open up the conduits for best effort delivery for Internet access by all.

But even if they (the MSOs) opened up four (4) 6 MHz video pipes, each one able to deliver on the average of an effective 10 to 20 Mb/s, as opposed to the usual single or dual channel approach currently being used, this would mean that at best their head ends could support less than 50 Mb/s for an entire serving area of potentially thousands of users per segment or branch. To put this into perspective, this would constitute a line capacity equal to a mere 33 ADSL lines, each operating at 1.5 Mb/s.

Think of it. Supporting access to multiple ISPs (possibly hundreds of them, depending on the locale) in a serving area of 000's of end users with the fire power that would be amenable for only 33 ILEC DSL users.

This would only be the case if an additional three video channels were offered up at the alter in a kind of AOLian sacrifice. Four video channels, in total, as opposed to the usual single or dual channel delivery schemes which are being contemplated, would be a very expensive price to pay from the video channel budgeting perspective, by any measure. Especially for a service that would, by definition, have to forfeit many of the already-in-place (and some, soon to be released) enhanced features afforded by the DOCSIS model. Comments and corrections are always welcome.

Regards, Frank Coluccio

ps - late edit: see the post just put up on the ATHM baord by Eric Davies re a San Francisco official's position on the ATT plan.

Message 10289837

The appointees and regs may have their hearts in the right places, but they are ignorant about the technical details involved, IMO. This, however, could be seen as a way to accelerate technical changes. But I wouldn't bet on this, tho. Once you take away the incentives, the laboratory gets very quiet.