Hi folks,
(Apologies in advance to non-Americans or anyone who doesn't care about
American home broadband policy! Please feel free to immediately delete!)
I don't want to get overly political on this mailing list, but my statement on this topic
is a matter of public record: https://docs.fcc.gov/public/attachments/FCC-23-105A3.pdf.
As this item is now closed, there is no risk of any impermissible side-barring ("ex
partes" that would have to be filed on the record, in regulatory jargon) if anyone
wants to discuss this.
The FCC is funded through regulatory fees which, traditionally, fell predominantly
on broadcasters and monopoly-era AT&T. This mechanism, or at least how we
calculate it, is increasingly inapposite for a world in which so much video and
voice traffic takes place via unregulated services. That's one reason the agency is
shrinking even as the communications industry is growing. Another is that many of
our necessary functions, such as RF emissions enforcement, are on a non-fee basis
and thus short-term painless to cut (even if that means that we're abandoning
oversight of a rising noise floor, or of a device world where post-licensure
quality fade on emissions control is normal business practice.)
I'm on the record as saying that the FCC should reallocate resources and seek
additional money with the goal of hiring 500 more engineers and field
enforcement staff. That number is probably too small, but it would be a good
start ;-) I was horrified to learn recently, while researching my Title II
statement, that the FCC essentially has no internal experts left on peering and
transit. How in blazes was this allowed to happen? (I hired one of the handful
left as my chief of staff, but that just makes her unavailable to the career
staff, so...)
On this specific issue, I think a reasonable person could look at current
federal broadband programs and see a significant bias in favor of fiber to the
home. Someone drawing that conclusion might point, in addition to StarLink's
situation, to the specific exclusion of unlicensed-frequency fixed wireless
from the BEAD program, in defiance of the current tech trends. Anyone finding
bias there might further note that the federal government talks incessantly
about line speed but never about traffic management or router firmware and
conclude that technically shallow federal politicians have no better ideas than
to resort to the same metric that ISPs use in their advertising.
I don't always see eye to eye with TechFreedom, which is why I so appreciated
their filing on the same NOI that some in this group were involved with filing
on. Their filing noted that line speed is a misleading and inappropriate proxy
for customer experience quality, though not in the detail of the engineering
filers, and also pointed out (among other points) that selling broadband to the
public on the basis of telehealth and education is belied by the traffic
numbers, which show that entertainment uses predominate. Not that I have
anything against entertainment, but the feds haven't been candid (and perhaps
the public has allowed itself to be deceived as well) about the reality of how
its enormous fiber infrastructure subsidy commitments will be used in practice.
If we can provide good service to people without the huge lift of a universal
fiber to the home build, then the United States is headed in the wrong
direction and will be wasting a lot of public money. And, unlike StarLink, we
still won't have connected Dave's boat :-)
All best,
Nathan
On Thu, Dec 14, 2023 at 12:49 PM David Bray, PhD via Nnagain
<nnag...@lists.bufferbloat.net> wrote:
FCC's staff continues to shrink. 1420-or-so employees in 2022,
1755-or-so in 2012, 1952-or-so in 2004. So about a 25% reduction
over the last twenty years. There are several good people there
among the staff, however they also face an increasing number of
tasks and demands with less resources. Public service depends on
folks being willing to step up and be of service.
Also, ultimately it is the decision of the Commissioners. Staff
can brief the Commissioners and present evidence, the
Commissioners are there to make the policy decisions. Remember
Commissioners are Presidentially-appointed, Senate-confirmed which
selects for certain things in keeping with our Constitution. For
the staff, this means accepting that politics may supersede even
the best technical briefing.
Such is how representative governments work. And if you circle
back to Plato's The Republic, the conclusion is such is how
humanity wants it - we don't want a perfectly wise, benevolent,
philosopher king. Each of us wants compromises - the difference
being those specific compromises. Plato (through the voice of
Socrates) also concludes humanity would probably kill a perfectly
wise, benevolent, philosopher king if we were to ever have one -
again because despite everyone saying they want this, they really
only want such a person if that person agrees with them fully. Or
as Tears for Fears aptly put it: "Everybody Wants to Rule the
World" = https://www.youtube.com/watch?v=awoFZaSuko4
On Thu, Dec 14, 2023 at 1:00 AM Frantisek Borsik via Nnagain
<nnag...@lists.bufferbloat.net> wrote:
Thanks, Robert. Exactly what I meant. Therefore I added NN
list, because Nathan was engaging with us there, and with Dave
(me and some others, to my knowledge) either directly or via
his staffers and he really wanted to catch up on tech things
that are the culprits of Net Neutrality (bufferbloat.)
So instead of assuming that Nathan Simington and Brendan Carr
are “bought” as someone did, I can the FCC itself as an entity
can be understaffed at worse.
But still, I appreciate efforts to learn about what’s going in
here and getting it right.
All the best,
Frank
Frantisek (Frank) Borsik
https://www.linkedin.com/in/frantisekborsik
Signal, Telegram, WhatsApp: +421919416714
iMessage, mobile: +420775230885
Skype: casioa5302ca
frantisek.bor...@gmail.com
On Thu, 14 Dec 2023 at 3:46 AM, Robert McMahon
<rjmcma...@rjmcmahon.com> wrote:
I think this common in that appointment of commissioners
go through a political process. The FCC has a technology
group, too. When I worked with them about 8 years ago,
they had skilled researchers on staff and a highly skilled
director. They asked good questions about engineering
decisions, like what is limiting the number of mimo
streams on devices.
Their physical facility is a bit dated, and they don't get
stock grants. I respect the engineers I worked with for
what they did.
Bob
On Dec 13, 2023, at 2:38 PM, Frantisek Borsik via Nnagain
<nnag...@lists.bufferbloat.net> wrote:
I would love for Nathan to be here with us, and
comment on that :-) so I will add NN list as well.
All the best,
Frank
Frantisek (Frank) Borsik
https://www.linkedin.com/in/frantisekborsik
Signal, Telegram, WhatsApp: +421919416714
iMessage, mobile: +420775230885
Skype: casioa5302ca
frantisek.bor...@gmail.com
On Wed, 13 Dec 2023 at 11:21 PM, Richard Roy
<dickroy3...@comcast.net> wrote:
------------------------------------------------------------------------
*From:*Starlink
[mailto:starlink-boun...@lists.bufferbloat.net]
*On Behalf Of *Frantisek Borsik via Starlink
*Sent:* Wednesday, December 13, 2023 1:26 PM
*To:* Dave Taht via Starlink
*Subject:* [Starlink] FCC Upholds Denial of
Starlink’s RDOF Application
“*Elon Musk*’s Starlink was not the only major
company to inflate its capabilities
<https://broadbandbreakfast.com/2021/04/rdof-reverse-auction-criticized-google-makes-pandemic-gains-california-broadband-access-for-k-12/>
in
RDOF bids. Nearly 100 bidders have defaulted since
the auction, leaving in limbo an estimated $2.8
billion
<https://broadbandbreakfast.com/2023/06/what-happens-to-the-estimated-2-8-billion-in-rdof-defaults/>
of
the $9.2 billion originally awarded.
The FCCupheld another denial
<https://broadbandbreakfast.com/2023/12/fcc-proposes-22-million-fine-against-ltd-over-rdof/>on
Monday in the case of LTD Broadband, which
appealed the commission’s finding that it could
not reasonably serve the more than 500,000
locations to which it had committed. The
commission also hit LTD with a $21.7 million fine
for its default.
The commission’s two Republicans dissented to
Starlink’s denial, claiming they saw a path for
the company to improve its speeds before the first
deployment deadline in 2025.”
*/[RR] The reason two lawyers “saw a path” is
because they were bribed/conned into to see it. In
my nearly 50years of experience dealing with the
FCC, extremely rarely are the people at the top in
the commission tech savvy. In general, they have
NO CLUE when it comes to technology … period! /**/JJ/*
https://broadbandbreakfast.com/2023/12/fcc-upholds-denial-of-starlinks-rdof-application/
All the best,
Frank
Frantisek (Frank) Borsik
https://www.linkedin.com/in/frantisekborsik
Signal, Telegram, WhatsApp: +421919416714
iMessage, mobile: +420775230885
Skype: casioa5302ca
frantisek.bor...@gmail.com
------------------------------------------------------------------------
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--
Nathan Simington
cell: 305-793-6899
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