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To: Kenneth E. De Paul who wrote (405)11/19/1999 3:43:00 PM
From: Frank A. Coluccio  Read Replies (2) | Respond to of 1782
 
re: the DSL line sharing order

Ken, here are some references on the order, below. My suggestion would be to first digest these documents and weigh their import against other known factors and arguments -and don't rule out the possibility of court appeals- before formulating an opinion on the mattter. My first take will be that we will not see a unified kind of response from the LECs, but one never knows.

During the earlier run of messages on this topic here, I stated that I had initially confused this pending order, at the time, with other initiatives that were on the books at the Fed. In retrospect, however, I now see that they are all related. For, this sharing order is sure to contaminate or otherwise influence the unbundling of UNEs elsewhere in the network, and the terms by which subsidiary LEC operators might be set up, as well.

Regards, Frank Coluccio
-------

The Press Release:

fcc.gov

The Text version of same:

fcc.gov
================

FAQS: Third Report and Order "Line Sharing"

fcc.gov

I. Technical Aspects of Order

ADSL modems are capable of transmitting at up to 120 times faster than the speed of 56
kilobits per second (kbps) dial-up modems.

ADSL modems are capable of receiving up to 8 megabits per second
(Mbps) "downstream," and transmitting up to 1 Mbps "upstream."

The high frequency portion of the loop is the frequency range above the voiceband on a
copper loop facility used to carry analog circuit-switched voiceband transmissions.

Carriers use a passive filter, or splitter, to split the digital and voice signals and direct
them to the packet-switched network and circuit-switched network, respectively.

II. Pro-Competitive Aspects of Order

Consumers will not have to buy a 2nd telephone line to have access to a competitive
carrier's high-speed Internet access.

Consumers will not have to change their phone number to get access to a competitive
carrier's high-speed Internet access service.

Line sharing will facilitate further investment by competitive data providers and
encourage these providers to deploy advanced services in areas where, heretofore, it has
not been economically viable to do so.

III. Operational Aspects of Order

Incumbents must provide unbundled access to the high frequency portion of the loop to
any carrier that seeks to deploy any version of xDSL that is presumed to be acceptable
for shared line deployment in accordance with the rules adopted in the Order.

Incumbents are not required to unbundle the lower frequency portion of the loop
(voiceband).

Incumbents must share the line with only one requesting carrier.

Carriers may not request access to just the high frequency portion of a loop if the
inclument is not presently using that loop to provide analog voice service.

The requirements set forth in the Order will go into effect 30 days from publication in the
Federal Register. The Order recognizes, however, that it will take additional time to work
out operational issues.


Indeed.




To: Kenneth E. De Paul who wrote (405)11/19/1999 8:33:00 PM
From: Frank A. Coluccio  Respond to of 1782
 
re: some reflections on twisted pairs?

Ken, one of the reasons that I am reluctant to provide you with a knee jerk on this one is because I feel that some of the ILECs may be looking at this as a mixed blessing. Indeed, it's even occurred to me that in some situations some of them may be getting exactly what they want in the way of surrogate organizations to do their dirty work for them. This would be the case in some of their underserved areas, while they improve upon their next gen loop platforms.

Some of these NGDLCs may not be ready for general consumption for another year or two, or longer. And when those deep fiber access platforms are ready? I can only speculate, but given the choice to stay with marginal services or the option to go full DSL, I think that there will be some major churning going on at that time. That is, unless there are further moves made by the FCC to include those deeper network elements in the sharing, or resale, space, by then. And this is where the separate subsidiary issue surfaces, again.

Also, I'm not so sure that some of the competitive DSL providers are too keen on the use of existing pairs which are already carrying voice in all situations. For some purposes, I think that some of them would have rather gotten very deep discounts on a loop resale basis than to ride on someone else's gravy train.

I say this because much of their anticipated incremental revenues are (were?) predicated on voice services and value-adds lopped on top of those voice services. Especially in the small business/home office, or SO-HO, space, where VoDSL products are now beginning to proliferate in the market place.

So, in one way this removes an incentive from the customer to go with a bundled offering from the startup, thus lowering their potential take down the road. Of course, neither side would likely admit to what I've stated here, but someone's projections have just been altered.

Regards, Frank Coluccio
=============

NEW EDGE NETWORKS INKS DEALS WITH THREE RBOCS

Annie Lindstrom

New Edge Networks (www.newedgenetworks.com), which is on a mission to provide
small and medium businesses located outside major urban areas with broadband access in
all 50 states, announced it has reached interconnection and co-location agreements with
three regional telephone companies covering almost half the country.

The Vancouver, Wash.-based competitive local exchange carrier (CLEC) has signed
interconnection and co-location agreements with BellSouth (www.bellsouth.com), SBC
Communications (www.sbc.com) and US West (www.uswest.com) for major portions of
the West, Northwest, Texas and Southeast regions of the country, covering 21 states.
New Edge Networks is in negotiations with other regional Bell operating companies
(RBOC's) and independent local telephone companies to establish similar agreements
covering all remaining states.

While negotiating these agreements, New Edge Networks has been identifying and
applying for co-location space in more than 300 telephone company switching center
locations 16 states. The CLEC has received space in more than 30 of these sites and is
currently installing digital subscriber line (DSL) equipment in them, according to Dan
Moffat, president, CEO and founder of New Edge.

New Edge Networks expects to receive space in more than 40 additional central offices
before the end of the year, when the company plans to be offering wholesale DSL service
to customers in six states. According to the CLEC, two out of 10 DSL users choose to live
or operate businesses in small and medium size communities outside the major urban
areas, which is where New Edge plans to offer wholesale DSL service in all 50 states
within two years' time.



To: Kenneth E. De Paul who wrote (405)11/20/1999 3:06:00 PM
From: Frank A. Coluccio  Read Replies (2) | Respond to of 1782
 
re: Saturday morning musings by a Fiber Hawk re the recent FCC copper sharing order

Thread, I would like to offer some opposing views to some of the positions voiced here and over in the Last Mile Thread on the above subject, if, for no other reason, than to volunteer to be the devil's advocate in order to stimulate some further discussion on this topic.

[Late edit, please forgive some of the disjointedness below, since I prepared this on interrupts and found myself wrestling with the edit clock at one point. If you've been there, you know what I mean.]

Today's technology, and the dramatically-reduced physical form factors which said technologies now permit, can now be used to provide us with the means to overcome the usual arguments of the past... namely, those arguments which position for or against the reasons for the local monopoly, and its interests.

Perhaps we're not quite there yet, but if we're not, it's surely not the fault of technology alone, at this point. It's more likely the result of the mind's own inertia, and the comfort that we take, which AHhaha likes to cite, i.e., how we always tend to look to those in government to dictate how we should proceed.

Having said that, I think technology is actually on our side, and it will surely come to our rescue if we give it, and the creativity which engenders it, a chance. The problem is that we always seem to defer to government, instead, and in some ways the reasons for doing so are now becoming anachronistic, in nature.

But even technology, it seems, can not come to the rescue of all situations. At least not soon enough to prevent this last government initiated action, it would appear.

------

It doesn't matter to me if the incumbents win or lose, or if the competitors win or lose. The fact is, IMO, that in some pervase way everyone loses with this most recent ruling, in the longer term, because it merely portends to momentarily satisfy the appetite for bandwidth, and therefore, will have the effect of severely damping the flow of new innovation, at the same time... while consuming enormous amounts of shrinking resources in downsized LEC organizations. And all of this is taking place in order to make an old technology which is slated for the garbage heap more accessible to startups who should be spending their time more productively on more transcendent forms of technology implementations.

The FCC should not be mandating anything in this space at this point. If they should be doing anything at all in these venues (and this is even suspect, IMO), then they should be getting more involved in making recommendations about how to facilitate deeper fiber and wireless penetrations into the neighborhoods, by a plurality of xLECs, and making some substantive recommendations about how to facilitate wireless licensing and spectrum allocations, instead of the bureaucracy-strewn processes which are now in place.

But the FCC should not, IMO, be a force behind extending the life expectancy of twisted pair copper in this late chapter of local distribution technology... copper, whose longevity is surely slated to be a guaranteed by-product of this order.
---

ARGUMENT:

To Upgrade or Not to Upgrade:

ILECs have already undertaken many much-needed fiber upgrades (the PUCs have actually mandated some of these upgrades in some cases) which serve to replace very lossy, very lousy, and very noisy copper pairs with new "fiber-based" alternatives. And they have scheduled many more undertakings for those areas which have not been covered yet.

Fiber is going to be used to achieve this. Fiber. Don't mind me if you see me repeating the term "fiber" almost incessantly throughout this post, but fiber is both the enabler of information delivery and at the same time a form of nemesis to the DSL community for obvious reasons, both to the DSL service providers, and the DSL vendors, alike, when viewed in this new penetration scheme which the FCC has defined.

Fiber to the neighborhood, Fiber to the Curb, Fiber to the Home, Fiber to the pedestal, etc. Either through next gen DLC implementations, or increasingly through the more sophisticated passive optical networking (PON) deployments involving optical networking units (ONUs) which feed homes via twisted pairs and other media, including (you guessed it), fiber, itself. And wireless extensions, as well, but there is only so much tolerance for futurism in one post, so I'll attempt to keep this on the brief side.
-----

These upgrades I've alluded to are much overdue by today's suddenly-cast-upon-us expectations, granted, but they must be undertaken, nonetheless. Lest, of course, they be stalled indefinitely, for the sake of allowing some startups the dubious opportunity to exploit what has been there all along. Which leads me to an irony of sorts which should also be mentioned:

Startups usually make hey in their marketecture over the inadequacies of the incumbent's facilities, citing obsolescence, poor quality, noisy conditions, lethargy, etc. Now that the incumbent is finally upgrading to fiber based distribution, the startups must also change their fabric, through necessity, too. So? What do they do?

The startups may attempt to thwart the incumbents from changing their
loops to fiber in some situations. I can see the petitions for injunctive relief now citing predatory practices and restraint of trade. That is, until the fledglings convince their VC backers that they, too, at some point have a plan to compete on these new terms... namely, how they will be able to support extending DSL services from the pedestal, once fiber and field electronics replace the longer, rapidly-aging, copper loops with much shorter, newer, drops to the structure.

Does anyone here think that this is a simple matter? Think again. Think TRUCK ROLLS. TRs represent the curse of death in startupdom. And think this, too: The employees which will be needed to do this. The employees who do not exist, yet. And employees, too, which represent another set of antithetics to today's startups arsenal of advantages, which they will use to beat the incumbents at their own game. Employees go hand in hand, with the truck roll curse.

As background, many existing extended-loop conditions are often characterized as marginal, at best, even for voice services in some areas. And they may represent distances of from 12,000 to 20,000 to 30,000+ feet from the CO or wire center. As another aside, this also implies a maximum of some 128 kb/s for many prospective surfers, usually using IDSL-like technologies. Compare this to the potential of fiber deeper into the burbs, or 3G wireless supported services.
-----

Faced with the prospect of losing their newly acquired copper medium, what recourse does the DLEC now have, once the copper pairs are retired due to the upgrades? Is it reasonable to prevent the ILECs from following through with their upgrades simply to allow the piggy-backing of other people's data on the much older copper? Or, should there remain some duality consisting of new and old plant to allow grandfathering for those situations were the competitors have already made their mark?

Another interesting question to ponder IMO is this: If the ILECs are allowed to go forward with their upgrades, then does it follow that the DLECs should be permitted access to the new pedestal interfaces to the residence, too? That part, from what I can see, was not covered by Thursday's FCC order. Perhaps it should have been included in order to prepare for this contingency, but from what I can tell, it wasn't.

At some point the ILECs must be wondering, Who am I working for, anyway?
-----

Isn't it time that the monopoly schtick get tossed? Or, at least put into 20th, if not 21st Century perspective?

Advances in technology now allow 100,000,000 telephone calls to be
carried over a 9 micron core in a 250 micron outside diameter fiber, instead of a black twisted pair cable the size of Water Main No. 3 which now runs through most of NY City. Let me put this in perspective.

A twenty four hundred (2400) pair cable can be as thick as four inches in diameter. That's about as high as you go in a single sheath (okay, some go as high as 3,600 pairs, in case WTC is looking in, which I hope he is, because I'm going to need some support after this one) where twisted pairs are concerned.

Beyond the basic 2400 pair cable, you simply need to add more cables if you want to increase the number of talkers. Sooner or later you wind up with placing multiple ducts of conduit to support these cables, and then entire duct banks of 2400 pair cables. And then, you are occupying a tunnel which could handle a hook 'n ladder fire engine through it. And even then, you couldn't support same 100,000,000 voice services that could instead be transported over a single fiber, the diameter of a human hair.

Here one can begin to envisage why the newer form factors associated with fiber are not nearly as foreboding a burden along rights of way, by any stretch of the imagination, as the older copper loop model was.
----


Another issue which I find interesting is that we will be mixing two different worlds, and in two different ways.

One world speaks to criticality and the need for dependability, and one world speaks to some not so perfect physical properties, prone to the vagaries of environmental and man made factors, if not the inexplicable world of the artifacts of an imperfect medium which we write off as phenomena.

The latter phenomena, of course, in a totally unpredictable and hostile environment, presents a much more scary prospect than those other attributes which are purely based on bias and spin.

Normally, I wouldn't find mixing applications on a medium as a particularly threatening prospect, if one vendor were in charge. Especially if their presence is supported by a consistent, uniform protocol model. But here, we are talking about something entirely different than interleaving similar analog or digital packet profiles in a consistent multiplexed format by a single service provider.

I know, the telcos profess to offer both forms of service (voice and data) over ADSL, too. On one pipe, as well. But if it's their (the ILEC's) responsibility to make them both work, voice and data, then they will be incented to make it so, and they will make it so, even if they have to go through a period of loss-lead in order to make it happen. It's only a matter of doing business, and many businesses operate in the same way when introducing new product.

But, if they are only charged with voice, forget about it. The glove hasn't been invented yet that has the necessary number of fingers to fit this situation.

The FCC's order implies that two different physical media approaches be used on the same physical wire by two different providers, which may very well cross over from one to the other through the well-known and documented effects of near end and far end cross-talk.

And, through other anomalies which are also well documented having to do with ordinary and customary central office and field activities which take place anytime one service (or an adjacent service) is being modified or tested by the provider. Make that service providers, plural, in this case, and we shouldn't expect them to coordinate with one another every time a group of elements must be touched or tweaked, unless one is paying the other under SLA terms to do so.

And when the end user's own use, or abuse, of the service is in question? Forget about it, squared.

As for criticality, while it may seem okay for little Johnny to do without surfing AOL after school lets out, the same can't be said about the lifeline telephone service at 11:30 PM when hubby or momma suddenly has a chest pain. I hate to leave it on that note, but I've already gone on too long at this point. Besides, I owe a few people here some replies on other matters. Comments welcome.

Regards, Frank Coluccio