Hi Bob,

thanks for the interesting discussion, I am learning a lot! I am unsure whether 
the following is too direct


> On Oct 8, 2023, at 18:37, Robert McMahon <rjmcma...@rjmcmahon.com> wrote:
> 
> Hi Sebastian,
> 
> The U.S. of late isn't very good with regulatory that motivates investment 
> into essential comm infrastructure. It seems to go the other way, regulatory 
> triggers under investment, a tragedy of the commons.

        [SM] My personal take on "tragedy of the commons" is that this is an 
unfortunate framing that tries to muddy the waters. What "tragedy of the 
commons" boils down to in insufficient or insufficiently enforced regulation. 
The tragic part is that we theoretically already know how to avoid that...

> 
> The RBOCs eventually did overbuild. They used wireless and went to contract 
> carriage, and special access rate regulation has been removed.

        [SM] Clearly sub-optimal regulation at play here that leaves obvious 
lucrative alternate pathways outside of the regulated component... the solution 
clearly would have been to put wireless under regulation as well (either 
immediately or as a pre-declared response to insufficient fiwed wire access 
plant maintenance and built-out). Then again easy to say now...

> The cable cos did HFC and have always been contract carriage.

        [SM] At least in Germany without good justification, once an access 
network is large enough to stymie growth of competitors by sheer size it needs 
to be put under regulations (assuming we actually desire competition in the 
internet access market*). Letting such players escape regulation is doubly 
problematic:
a) it results in anti-competitive market consolidation in the hands of those 
players.
b) it puts the other (incumbent) players subject to regulatory action at a 
clear disadvantage.

*) IMHO we will never get meaningful infrastructure competition in the access 
network though, too few players to land us anyway outside of monopoly/oligopoly 
regime...

> And they are upgrading today.
> 
> The tech companies providing content & services are doing fine too and have 
> enough power to work things out with the ISPs directly. 

        [SM] Yes and no, few ISPs if any are willing to try to strong arm 
Google/Facebook/Apple/... but smaller players do fall pray to sufficiently 
large ISPs playing games to sell access to their eye-balls (see e.g. the 
carefully and competently managed under-peering Deutsche Telekom (DT) does with 
the other T1-ISPs to "encourage" all content providers to also buy direct 
access t the Deutsche Telekom, technically billed as "transit", but far above 
alternative transit that few content providers will use this nominal transit to 
reach anything but Telekom eye-balls, but I digress. However DT did not invent 
that technique but learned from AT&T and Verizon*).


*) Only a few ISPs can really pull this off, as you need to be essentially 
transit-free yourself, otherwise your own Transit provider will allow others to 
reach you over typically not congested links. But as SwissCom and Deutsche 
Telekom demonstrated in the past, if you then collude with your Transit 
provider you might still be able to play such games. Side-note in Germany DT is 
forced by law to allow resellers on its copper plant so end-customers unhappy 
with DT's peering policy can actually change ISP and some do, but not enough to 
hinder DT from trying this approach.
In addition DT together with other European ex-monopoly telecoms lobbies the EU 
commission hard to force big tech to pay for access network build out in 
Germany... Now, I do have sympathies for appropriately taxing big tech in those 
countries they generate revenue, but not to line the coffers of telecoms for a 
service they were already paid for by their end-customers.


> 
> The undeserved areas do need support.

        [SM] I fully agree! We should give all regions and access links the 
same equitable starting point to participate in the digital society.


> The BEAD monies may help. I think these areas shouldn't be relegated to DSL.

        [SM] My take here is that FTTH is inevitable as the next step sooner or 
later. But for today's needs DSL would do just fine... except for rural areas 
moving outdoor DSLAMs close enough to the customers to allow acceptable access 
capacity is likely almost as expensive (if not more expensive due to the active 
DSLAM tech) as not stopping with the fiber at the potential outdoor DSLAM 
location, but putting it all the way to the end-customers.
However dark fibers in the ground are only half the problem, we still should 
allow for meaningful competition over these fibers in offering internet access 
services, as one thig we know about the free market is, it works better the 
more different players we have on the supply and demand side. (For internet 
access the demand side is not the problem, but the supply side is where we need 
to take steps to get over what Rosenworcel described as only 20% of US 
households have actual choice of broadband ISPs).

Regards
        Sebastian

P.S.: I am sure that in essence we pretty much agree, we differ a bit in how we 
want to reach the goal, but that allows for a healthy discussion.


> 
> Bob
> On Oct 8, 2023, at 2:38 AM, Sebastian Moeller <moell...@gmx.de> wrote:
> Hi Bob,
> 
> On 8 October 2023 00:13:07 CEST, rjmcmahon via Nnagain 
> <nnagain@lists.bufferbloat.net> wrote:
> Everybody abandoned my local loop. Twisted pair from multiple decades ago 
> into antiquated, windowless COs with punch blocks, with no space nor latency 
> advantage for colocated content & compute, seems to have killed it off. 
> 
> [SM] Indeed, throughput for DSL is inversely proportional to loop length, so 
> providing  'acceptable' capacity requires sufficiently short wire runs from 
> DSLAM to CPE, and that in turn means moving DSLAMs closer to the end users... 
> which in a densely populated area works well, but in a less densely populated 
> area becomes costly fast. And doing so will only make sense if you get enough 
> customers on such an 'outdoor DSLAM' so might work for the first to built 
> out, but becomes prohibitively unattractive for other ISP later. However 
> terminating the loops in the field clears up lots of spaces in the COs... not 
> that anybody over here moved much compute into these... (there exist too many 
> COs to make that an attractive proposition in spite of all the hype about 
> moving compute to the edge). As is a few well connected data centers for 
> compute seem to work well enough...
> 
> I suspect in some towns one can buy out the local loop copper with just a 
> promise of maintenance. 
> 
> [SM] A clear sign of regulatory failure to me, maintenance of the copper 
> plant inherited from Bell should never have been left to the ISPs to decide 
> about... 
> 
> 
> The whole CLEC open the loop to competitive access seems to have failed per 
> costs, antiquated technology, limited colocation, an outdated waveguide 
> (otherwise things like CDDI would have won over Cat 5), and market reasons. 
> The early ISPs didn't collocate, they bought T1s and E1s and connected the 
> TDM to statistical multiplexing - no major investment there either.
> 
> The RBOCs, SBC (now AT&T) & and VZ went to contract carriage and wireless 
> largely because of the burdens of title II per regulators not being able to 
> create an investment into the OSPs. The 2000 blow up was kinda real.
> 
> [SM] Again, I see no fault in title 2 here, but in letting ISPs of the hook 
> on maintaining their copper plant or replace it with FTTH...
> 
> 
> 
> 
> She starts out by complaining about trying to place her WiFi in the right 
> place. That's like trying to share a flashlight. She has access to the FCC 
> technology group full of capable engineers.  They should have told her to 
> install some structured wire, place more APs, set the carrier and turn down 
> the power. 
> 
> [SM] I rather read this more as an attempt to built a report with the 
> audience over a shared experience  and less as a problem report ;)
> 
> 
> My wife works in the garden now using the garden AP SSID with no issues. My 
> daughter got her own carrier too per here Dad dedicating a front end module 
> for her distance learning needs. I think her story to justify title II 
> regulation is a bit made up.
> 
> [SM] Hmm, while covid19 lockdown wasn't the strongest example, I agree, I see 
> no good argument for keeping essential infrastructure like internet access in 
> private hands without appropriate oversight. Especially given the numbers for 
> braodband choice for customers, clearly the market is not going to solve the 
> issues at hand.
> 
> 
> 
> Also, communications have been essential back before the rural free delivery 
> of mail in 1896. Nothing new here other than hyperbole to justify a 5 member 
> commission acting as the single federal regulator over 140M households and 
> 33M businesses, almost none of which have any idea about the complexities of 
> the internet.
> 
> [SM] But the access network is quite different than the internet's core, so 
> not being experts on the core seems acceptable, no? And even 5 members is 
> clearly superior to no oversight at all?
> 
>  I'm not buying it and don't want to hand the keys to the FCC who couldn't 
> protect journalism nor privacy. Maybe start there, looking at what they 
> didn't do versus blaming contract carriage for a distraction?
> 
> [SM] I can speak to the FCC as regulatory agency, but over here IMHO the 
> national regulatory agency does a decent job arbitrating between the 
> interests of both sides.
> 
> 
> 
> https://about.usps.com/who/profile/history/rural-free-delivery.htm#:~:text=On%20October%201%2C%201896%2C%20rural,were%20operating%20in%2029%20states.
> 
> Bob
>  My understanding, though I am not 100% certain, is that the baby bells
>  lobbied to have the CLEC equal access provisions revoked/gutted.
>  Before this, the telephone companies were required to provide access
>  to the "last mile" of the copper lines and the switches at wholesale
>  costs. Once the equal access provisions were removed, the telephone
>  companies started charging the small phone and DSL providers close to
>  the retail price for access. The CLEC DSL providers could not stay in
>  business when they charged a customer $35 / month for Internet service
>  while the telephone company charged the DSL ISP $35 / month for
>  access.
>  
>  
>  
>  
>   ---- On Sat, 07 Oct 2023 17:22:10 -0400  Dave Taht via Nnagain  wrote ---
>  I have a lot to unpack from this:
> 
>  https://docs.fcc.gov/public/attachments/DOC-397257A1.pdf
> 
>  the first two on my mind from 2005 are: "FCC adopted its first open
>  internet policy" and "Competitiveness"  As best as I recall, (and
>  please correct me), this led essentially to the departure of all the
>  3rd party DSL providers from the field. I had found something
>  referencing this interpretation that I cannot find right now, but I do
>  clearly remember all the DSL services you could buy from in the early
>  00s, and how few you can  buy from now. Obviously there are many other
>  possible root causes.
> 
>  DSL continued to get better and evolve, but it definately suffers from
>  many reports of degraded copper quality, but does an estimate exist
>  for how much working DSL is left?
> 
>  Q0) How much DSL is in the EU?
>  Q1) How much DSL is left in the USA?
>  Q2) What form is it? (VDSL, etc?)
> 
>  Did competition in DSL vanish because of or not of an FCC related order?
> 
>  --
>  Oct 30: https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
>  Dave Täht CSO, LibreQos
> 
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> 
> 
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