To: Frank A. Coluccio who wrote (2576 ) 12/16/1998 10:57:00 AM From: WTC Read Replies (3) | Respond to of 12823
Frank, You present an intriguing roadmap for encouraging wireline competition in the last mile [#2576]. You seem to address consensus thinking with most of the goals, but between two of your posts [#2576 & ****] I'm left wondering where you propose to make the push, and what is essential for that push to really enhance competition. One post suggests it has to be at a physical layer, "additional wires" (perhaps figurative) into the home, a subsequent post notes that competition that really matters might come at layers 2-4 (or thereabouts) in the virtual realm. Those are both interesting ideas, but it's not obvious why the faithful need to don belt AND suspenders to worship the God of Competition. Might not one or the other approach meet reasonable goals for enhancing competition? I've spent some years very close to the realities of planning, budgeting, engineering, constructing, administering, and maintaining ILEC last mile plant, in cities, suburbs, and the country. I don't dismiss your experience in similar pursuits. However, that experience just leaves me daunted (not haunted, really!) by the prospect that a new carrier of consortium of carriers can economically build last mile plant and profitably serve residential telecom service demand. I say residential, because I contend that the business world is already well served in many urban markets by a variety of Competitive Access Providers, wireline and some wireless, and that business will grow in volume and geographic coverage (long list will not follow here.) If I follow your "fourth build out" proposition, there seem to be aspects of that already incorporated in the trajectory we are now on with the FCC and the matters they are leaving to the states. I'm just a bit unclear where the new competitor is actually building new plant. Is the new competitor (let's call them a CLEC) securing access to ILEC (and possibly MSO??) plant at points convenient to their business plan? (In the FCC words from the Local Competition Order, for interconnection with ILECs, this could be at "any technically feasible point", a term left to be defined in practical terms at some later date.) AS for MSO plant -- we can all wait and see. That is the path we are on now, with manifest questions about the implementation details. Do you think the problems with "recalcitrant ILECs" are so beyond the reach of regulators that a new structure is needed, even at enormous cost? I think privately run and managed collocation sites are certainly a possible outcome from the eventual decision in CC Docket 98-188. That could be a far better, i.e., more fair and transparent (but not necessarily cheaper to CLECs), solution to remote collocation issues. Of course we have some today for Enhanced Services equipment that is not currently allowed in ILEC collocation space, so there is a model. I agree with your apparent view that spectrum need not be managed as the FCC manages it, slicing and dicing allocations to the point that they are less useful than they might be and often not suitable for technologies that could be effectively applied (like BB spread spectrum) if the allocations were not so chopped up. But I still claim my point that as long as the FCC administers spectrum as they do, and they gave no indication after the last en Banc hearing on spectrum management that they had a mind to change, spectrum here is indeed a "scarce resource." You make an interesting point about qualifications. Qualifications and competency are certainly essential for running any part of a globally interconnected network. Network protection today seems based on certain gateway software and procedural safeguards (limited at best, and subject to some newsworthy failures) and reliance on the competency of peering network operators. There are also limits as to what connections IP nets can now make into SS7 nets, but that is obviously all changing, with network security one of the tall poles in the tent for that effort. That all leads to my question: what would be so different in your paradigm that we need a new approach to network security and continuity? Does it really create significant new vulnerabilities? If so, don't those vulnerabilities need to be addressed with system solutions, so even the "qualified" operator can't make a bonehead mistake on Monday morning and bring a major net crashing down? Finally, I would go for a competent third party managing the hypothetical sub-loop management system, the OSS that holds inventory data and effects provisioning changes in the network. My thought that it would be managed by the ILEC was based on 1) history shows that the ILEC(s) will fund development and on-going software enhancement and maintenance, and 2) the key inventory data, physical plant inventory details, is daily affected by normal course of business activity of the ILEC, so the ILEC is perhaps best positioned to assure the base record is up to date and data changes are synchronized. That goal could certainly be accomplished by partitioning the system and implementing application to application interfaces between a loop data subsystem (ILEC) and the provisioning subsystem (3rd party.) You could even have the 3rd party do it all, but I think there is a bit price paid in efficiency, timeliness and effectiveness. p.s., It's actually "Tim", rather than "Bill", but I don't mind being Bill on this thread that you so ably monitor and contribute to so generously and cogently.