Re: Fwd: FCC kills wholesale DSL - Has the time come for
(Rob: While trying to consolidate this topic on the website, I accidentally
deleted some of the postings. Here's a raw transcript from the mailing lists.
Thx for your patience. Keep Postin'!)
>From dopry at thing.net Thu Aug 11 21:03:13 2005
From: dopry at thing.net (dopry)
Date: Thu Aug 11 17:03:16 2005
Subject: Fwd: [nycwireless] FCC kills wholesale DSL - Has the
time come for NYC Muni-Wifi?
In-Reply-To:
References:
Message-ID:
On Thu, 2005-08-11 at 18:00 -0400, [EMAIL PROTECTED] wrote:
> On Thu, 11 Aug 2005, dopry wrote:
>
> > The FCC didn't necessarily kill wholesale DSL. They rules that ILEC no
> > longer have to provide access to their wireline broadband services.
> > Wireline broadband services being bundled layer2 or layer3 network
> > access and a physical line. It doesn't impact Unbundled Network
> > Elements(UNE-L), the physical lines. As long as you're running your own
> > DSLAM's you should be in the clear.
> I think you should see that it is a matter of time before UNE-L goes the
> way of UNE-P and line-sharing, with this FCC.
Let me maintain some optimism... I thought the hopes behind dropping
UNE-P was to get CLEC's to build out their own facilities using the
existing copper via UNE-L to get the ILEC's to stop complaining about
costs and how they can't compete with cable. I guess it is a logical
progression once the CLEC's have their own facilities.
> > It doesn't really change the broadband landscape that much. Covad and
> > their resellers are safe and secure. The independents running their own
> > DSLAMS and providing T1 are ok.. Verizon will probably let their
> > existing resellers sit pretty.
>
> a) Verizon may or may not let their resellers (or rather, partner ISPs
> like us) to sit pretty. Right now, we are sitting nervous.
I guess I can see that. I figure if verizon really wanted to when your
contract term is up they could just consume your userbase, and cut out
the middleman... It may seem unethical, but as long as it doesn't break
any laws or breach any contracts it is about the Quarterlies.
> b) Covad isn't sitting all that pretty. Covad executed "commercial
> agreements" with ILECs allowing them to continue to do line-sharing at a
> cost that is substantially higher than their previous line-sharing cost.
> Despite what you think, a minority of covad lines are UNE-L (non-shared).
I was unaware of that... Do you have a link to more info that I could
read up on? I'm a step farther out than you in covad territory...
> > FTTH is my real concern. Existing regulation only applies to the copper
> > plant, unless I've missed something in recent history. Incumbents do not
> > have to share access to their fiber networks. Hopefully they will to
> > help fulfill capacity and utilization, but that is a hope. While
> > Francois Menard alludes to pricing wars preventing municipalities from
> > enter the FTTH race, I think it is unfounded, currently incumbent
> > pricing is below cost for independent ISP's when scale is considered*. I
> > don't think municipalities want to get involved in the expenses of
> > rolling out or maintaining a fiber infrastructure, and Verizon will beat
> > them to the chase anyway.
> >
> > I do however see this as a nod from the FCC to FTTH and Cable carriers,
> > to go on their merry way and not to worry, their lobbying dollars have
> > worked and they can move everything onto an IP platform without worry of
> > having it yanked out from underneath them in the short term.
> Pretty much.
>
> > verizon's introductory DSL offer is ~324/yr / user provides up to
> > 3Mbps/768Kbps depending on what your line will carry
> >
> > access costs for a thousand users is ~60/yr(line) + ~156/yr(bandwidth)
> > -$5/month/user UNE access
> > -13K/mo or $13/user/mo for a gige connection from HE.net
> > so total access costs/mo is about $216...
> Your math is completely confused. Where'd you take "5$/month/user UNE
> access" number from? If you think "line sharing UNE" - that's *gone*. Now,
> you have to pay for UNE-L, which is 20+$/month.
I pulled it out of my arse of course... Now I know, and knowing is half
the battle.
I thought UNE-P was more expensive since it included both the loop and
the port, and UNE-L was just the copper loop. But UNE-P pricing was avg
10-15/mo/port in NYC area circa 2004.
> Also, you need only ~25-50Mbps of internet bandwidth to serve 1000 users
> (surprising but true.)
I was just going on a guaranteed bandwidth kind of idea... but I didn't
realize the ratio was in the area of 20-40:1. I guess it makes sense
with http browsing habits and the fact that all users won't be online
all the time.
I guess even with your corrections you're only looking at 100-200K
revenue per year with UNE-P and even less with current UNE-L pricing...
I think It still supports the fact that ILECS are pricing below
competitor costs when scale is considered, except a few large ISPs.
........
now I'm worried... Thanks for pointing out the pale horse alex..
I always appreciate it when you share your knowledge and opinions.
.darrel.
----
>From alex at pilosoft.com Fri Aug 12 01:13:13 2005
From: alex at pilosoft.com ([EMAIL PROTECTED])
Date: Thu Aug 11 21:16:46 2005
Subject: Fwd: [nycwireless] FCC kills wholesale DSL - Has the time come
for NYC Muni-Wifi?
In-Reply-To:
Message-ID:
On Thu, 11 Aug 2005, dopry wrote:
> > > Elements(UNE-L), the physical lines. As long as you're running your
> > > own DSLAM's you should be in the clear.
> > I think you should see that it is a matter of time before UNE-L goes
> > the way of UNE-P and line-sharing, with this FCC.
>
> Let me maintain some optimism... I thought the hopes behind dropping
> UNE-P was to get CLEC's to build out their own facilities using the
> existing copper via UNE-L to get the ILEC's to stop complaining about
> costs and how they can't compete with cable. I guess it is a logical
> progression once the CLEC's have their own facilities.
I disagree. Real goal is to reverse all provisions of TCA96 (even things
like Computer I and II, see "reclassification" of DSL), while giving ILECs
section 271 relief.
> > > It doesn't really change the broadband landscape that much. Covad
> > > and their resellers are safe and secure. The independents running
> > > their own DSLAMS and providing T1 are ok.. Verizon will probably let
> > > their existing resellers sit pretty.
> >
> > a) Verizon may or may not let their resellers (or rather, partner ISPs
> > like us) to sit pretty. Right now, we are sitting nervous.
>
> I guess I can see that. I figure if verizon really wanted to when your
> contract term is up they could just consume your userbase, and cut out
> the middleman... It may seem unethical, but as long as it doesn't break
> any laws or breach any contracts it is about the Quarterlies.
No, actually, FCC said that DSL partners like us get 12 months to make
commercial agreements with ILECs (obviously, on ILEC's terms). After that,
ILECs can just disconnect us all. It doesn't matter that technically,
under tariff, we have a 5-year term - ILECs will use "change in law" to
terminate that term.
> > b) Covad isn't sitting all that pretty. Covad executed "commercial
> > agreements" with ILECs allowing them to continue to do line-sharing at
> > a cost that is substantially higher than their previous line-sharing
> > cost. Despite what you think, a minority of covad lines are UNE-L
> > (non-shared).
>
> I was unaware of that... Do you have a link to more info that I could
> read up on? I'm a step farther out than you in covad territory...
These things aren't necessarily written up in articles by industry
analysts. But try to dig around, about a year ago when line-sharing went
away.
> > > FTTH is my real concern. Existing regulation only applies to the
> > > copper plant, unless I've missed something in recent history.
> > > Incumbents do not have to share access to their fiber networks.
> > > Hopefully they will to help fulfill capacity and utilization, but
> > > that is a hope. While Francois Menard alludes to pricing wars
> > > preventing municipalities from enter the FTTH race, I think it is
> > > unfounded, currently incumbent pricing is below cost for independent
> > > ISP's when scale is considered*. I don't think municipalities want
> > > to get involved in the expenses of rolling out or maintaining a
> > > fiber infrastructure, and Verizon will beat them to the chase
> > > anyway.
> > >
> > > I do however see this as a nod from the FCC to FTTH and Cable
> > > carriers, to go on their merry way and not to worry, their lobbying
> > > dollars have worked and they can move everything onto an IP platform
> > > without worry of having it yanked out from underneath them in the
> > > short term.
> > Pretty much.
> >
> > > verizon's introductory DSL offer is ~324/yr / user provides up to
> > > 3Mbps/768Kbps depending on what your line will carry
> > >
> > > access costs for a thousand users is ~60/yr(line) + ~156/yr(bandwidth)
> > > -$5/month/user UNE access
> > > -13K/mo or $13/user/mo for a gige connection from HE.net
> > > so total access costs/mo is about $216...
> > Your math is completely confused. Where'd you take "5$/month/user UNE
> > access" number from? If you think "line sharing UNE" - that's *gone*. Now,
> > you have to pay for UNE-L, which is 20+$/month.
>
> I pulled it out of my arse of course... Now I know, and knowing is half
> the battle.
>
> I thought UNE-P was more expensive since it included both the loop and
> the port, and UNE-L was just the copper loop. But UNE-P pricing was avg
> 10-15/mo/port in NYC area circa 2004.
UNE-L is 20-ish. UNE-P is lower monthly rate, because LECs make money on
minutes and other charges.
>
> > Also, you need only ~25-50Mbps of internet bandwidth to serve 1000
> > users (surprising but true.)
>
> I was just going on a guaranteed bandwidth kind of idea... but I didn't
> realize the ratio was in the area of 20-40:1. I guess it makes sense
> with http browsing habits and the fact that all users won't be online
> all the time.
>
> I guess even with your corrections you're only looking at 100-200K
> revenue per year with UNE-P and even less with current UNE-L pricing...
> I think It still supports the fact that ILECS are pricing below
> competitor costs when scale is considered, except a few large ISPs.
"below competitor costs" is an understatement. They are a monopoly. They
can have whatever pricing they need to get everyone else out of the
market. They *determine* competitors' costs, for crying out loud!
-alex
~~
On Mon, 2005-08-08 at 08:02 -0400, Dana Spiegel wrote:
> Alex,
>
> Given this new FCC ruling on DSL, what is your position? How are you
> affected by the change in DSL rules? Is muni-wireless now a more
> attractive option for you?
>
> I don't mean to single you out, but you are the most outspoken person
> on the subject a few weeks ago. I'd personally like to solicit your
> views on the matter because you had clear concerns before, and I'd
> like to better understand what the FCC ruling means for you, and how
> NYCwireless can help.
>
> I'd like to start a constructive discussion about _how_ wireless in
> NYC can help both ISPs and local people who want internet choice.
>
> Dana Spiegel
> Executive Director
> NYCwireless
> [EMAIL PROTECTED]
> www.NYCwireless.net
> +1 917 402 0422
>
> Read the Community Wireless blog: http://sociable.blogspot.com
>
>
> Begin forwarded message:
>
> > From: Dustin Goodwin
> > Date: August 6, 2005 11:03:49 AM EDT
> > To: "[email protected]"
> >
> > Subject: [nycwireless] FCC kills wholesale DSL - Has the time come
> > for NYC Muni-Wifi?
> >
> >
> > The FCC has let the other shoe drop, Verizon will no longer be
> > required to offer wholesale DSL to competitive ISPs. Between this
> > and the Brand X ruling Time-Warner/Cablevision and Verizon can now
> > run their duopoly without worry. This means there are only 2
> > providers of "affordable" broadband into any dwelling or business
> > in NYC. If this doesn't worry you it should. Now that the FCC has
> > effectively killed real broadband competition, what should the
> > concerned NYer do? Maybe it's time to start caring about Muni-Wifi.
> > What could Muni-Wifi do for NYers?
> > 1. Create competition in broadband services by providing an
> > alternative to Cable and DSL for last mile access for ISPs.
> > 2. Provide a infrastructure for delivering low cost broadband
> > access to NYC neediest.
> >
> > This can be achieved without the city competing with private
> > enterprise and without funding it with tax payer dollars. Please
> > see my earlier post on the cooperative wholesale model for
> > municipal broadband:
> > http://lists.nycwireless.net/pipermail/nycwireless/2005-July/
> > 009335.html
> >
> > - Dustin -
> >
> > -------- Original Message --------
> > Subject: [CYBERTEL] FCC kills mandated DSL wholesale and
> > sanctifies a wireline duopoly as vibrant competition - Gone is Muni
> > FTTH?
> > Date: Sat, 6 Aug 2005 03:50:42 -0400
> > From: Francois Menard (Mailing List Account) > [EMAIL PROTECTED]>
> > Reply-To: Telecom Regulation & the Internet > [EMAIL PROTECTED]>
> > To: [EMAIL PROTECTED]
> >
> >
> >
> > FCC kills mandated DSL wholesale and sanctifies a wireline duopoly
> > as vibrant competition - Gone is Muni FTTH?
> > by Fran?ois at 02:31AM (CDT) on August 6, 2005 | Permanent Link
> > http://tim.blogware.com/blog/_archives/2005/8/6/1112664.html
> >
> > In a press statement issued today, the FCC commissionners have
> > agreed that the future of broadband in the US was better left in
> > the hands of market forces.
> >
> > Commissionner Copps however concedes that what the FCC has chosen
> > to do today amounts to prospective regulatory making on a purely
> > theoritical basis. That has not stopped him however from
> > concurring with the other Commissionners with the only announced
> > accountability of the FCC being that he says he intends to keep
> > tabs to see if what is supposed to happen truly does. But just who
> > will be there to keep tabs when the term of Commissioner Coops
> > expires on May 1, 2006?
> >
> > In the same statement, the FCC annnounces that it intends to issue
> > a public inquiry in which it will begin to investigate issues
> > associated with the walledgardenization of broadband access and by
> > interence, must now look into intercarrier compensation in the
> > context of broadband peering at public Internet NAPs which to this
> > date has remained free from FCC investigations.
> >
> > While ISPs in Canada can behave like ostriches and duck their heads
> > in the dirt and avoid thinking about the ripple effects of the FCC
> > continuing to push the limits of the impossible in avoiding to
> > consider the impact of their policies on the survival of the same
> > independant ISPs which have created the market of retail internet
> > services, we can bet that the ILECs in Canada will take advantage
> > of the Telecom Review and start pointing out to the grand canyon
> > emerging between CRTC policies and the FCC policies.
> >
> > In analyzing regulatory policies from the perspective of a
> > regulatory framework which is supposed to lead to sustainable
> > competition by remaining conducive to further facilities-based
> > entry, consequences of the disappearance of mandated wholesale of
> > DSL facilities are evident, that is, no more reasons for retail
> > price discipline, thus no more price floors, which will arguably
> > lead to foreclosure of further entry by other entities than the
> > incumbent Telco's and cable carriers.
> >
> > Consequently, the risks of Municipal FTTH entry have just been
> > quintupled - do it and the ILECs and the Cable Carriers will
> > immediately react by way of targeted decreases of DSL and cable
> > modem services only for as long as necessary to kill Municipal FTTH
> > while still in the eggshell.
> >
> > While the FCC is surely not foolish enough to believe that the
> > public interest will be served by targeted price decreases of ILEC
> > and MSO fat wasteband, the FCC seems to believe that they are
> > acting in the public interest in making it more difficult to make a
> > business case for municipal FTTH.
> >
> > Unlike the CRTC, the actions of the FCC remain elusive as to
> > whether the FCC truly believes that its prospective regulatory
> > theories are compliant with the FCC's statutory obligation to
> > administer a regulatory framework conducive to sustainable
> > competition by ensuring that regulatory relief will exist for other
> > carriers than ILEC and MSOs interested in making investments into
> > their own facilities.
> >
> > It is frustrating to see the American public endorse the fact that
> > the FCC will be leading another 7 year market experiementation
> > cycle in total disregard for the lessons supposed to be learned
> > from the previous experiementation cycle with telecom competition
> > concluding today.
> >
> > With today's FCC action, it seems a safe bet that in 7 years, there
> > will be no more wireline providers serving homes of Americans than
> > their are today with only some exceptions coming to mind,
> > Lafayette, being the latest one.
> >
> > It is sad to see the FCC officialize new rules that will allow
> > targeted below cost pricing by incumbent Telco's and MSO's with no
> > systematic regulatory relief before the FCC. This could hardly be
> > construed as a positive thing.
> >
> > -=Francois=-
> > 819 692 1383
> >
> > --
> > NYCwireless - http://www.nycwireless.net/
> > Un/Subscribe: http://lists.nycwireless.net/mailman/listinfo/
> > nycwireless/
> > Archives: http://lists.nycwireless.net/pipermail/nycwireless/
> >
>
> --
> NYCwireless - http://www.nycwireless.net/
> Un/Subscribe: http://lists.nycwireless.net/mailman/listinfo/nycwireless/
> Archives: http://lists.nycwireless.net/pipermail/nycwireless/
>
>From alex at pilosoft.com Thu Aug 11 19:00:49 2005
From: alex at pilosoft.com ([EMAIL PROTECTED])
Date: Thu Aug 11 15:04:23 2005
Subject: Fwd: [nycwireless] FCC kills wholesale DSL - Has the time come
for NYC Muni-Wifi?
In-Reply-To:
Message-ID:
On Thu, 11 Aug 2005, dopry wrote:
> The FCC didn't necessarily kill wholesale DSL. They rules that ILEC no
> longer have to provide access to their wireline broadband services.
> Wireline broadband services being bundled layer2 or layer3 network
> access and a physical line. It doesn't impact Unbundled Network
> Elements(UNE-L), the physical lines. As long as you're running your own
> DSLAM's you should be in the clear.
I think you should see that it is a matter of time before UNE-L goes the
way of UNE-P and line-sharing, with this FCC.
> It doesn't really change the broadband landscape that much. Covad and
> their resellers are safe and secure. The independents running their own
> DSLAMS and providing T1 are ok.. Verizon will probably let their
> existing resellers sit pretty.
a) Verizon may or may not let their resellers (or rather, partner ISPs
like us) to sit pretty. Right now, we are sitting nervous.
b) Covad isn't sitting all that pretty. Covad executed "commercial
agreements" with ILECs allowing them to continue to do line-sharing at a
cost that is substantially higher than their previous line-sharing cost.
Despite what you think, a minority of covad lines are UNE-L (non-shared).
> FTTH is my real concern. Existing regulation only applies to the copper
> plant, unless I've missed something in recent history. Incumbents do not
> have to share access to their fiber networks. Hopefully they will to
> help fulfill capacity and utilization, but that is a hope. While
> Francois Menard alludes to pricing wars preventing municipalities from
> enter the FTTH race, I think it is unfounded, currently incumbent
> pricing is below cost for independent ISP's when scale is considered*. I
> don't think municipalities want to get involved in the expenses of
> rolling out or maintaining a fiber infrastructure, and Verizon will beat
> them to the chase anyway.
>
> I do however see this as a nod from the FCC to FTTH and Cable carriers,
> to go on their merry way and not to worry, their lobbying dollars have
> worked and they can move everything onto an IP platform without worry of
> having it yanked out from underneath them in the short term.
Pretty much.
> verizon's introductory DSL offer is ~324/yr / user provides up to
> 3Mbps/768Kbps depending on what your line will carry
>
> access costs for a thousand users is ~60/yr(line) + ~156/yr(bandwidth)
> -$5/month/user UNE access
> -13K/mo or $13/user/mo for a gige connection from HE.net
> so total access costs/mo is about $216...
Your math is completely confused. Where'd you take "5$/month/user UNE
access" number from? If you think "line sharing UNE" - that's *gone*. Now,
you have to pay for UNE-L, which is 20+$/month.
Also, you need only ~25-50Mbps of internet bandwidth to serve 1000 users
(surprising but true.)
> a thousand users over 1 year leaves you with
> 324K-216K = 108k
>
> and you still have to pay for salaries, rent, hardware, marketing, and
> businesses expenses... Don't worry about taxes... you'll probably be in
> the red..
-alex
>From Robert.Schainbaum at wharton.upenn.edu Thu Aug 11 20:59:05 2005
From: Robert.Schainbaum at wharton.upenn.edu (Schainbaum, Robert)
Date: Thu Aug 11 16:59:26 2005
Subject: Fwd: [nycwireless] FCC kills wholesale DSL - Has the time come
for NYC Muni-Wifi?
In-Reply-To:
References:
Message-ID:
You don't like a profit margin of 33 percent before fixed costs?
Try running a convenience store.
Robert Schainbaum
--
NYCwireless - http://www.nycwireless.net/
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