At 8/9/2011 03:32 PM, you wrote:
Yesterday WISPA filed FCC comments in the "Outage Reporting" NPRM (attached).

This was a challenging filing to make because there is a diversity of opinion on Outage Reporting. Some prefer to simply tell the FCC to "go take a hike and stay out of my business" while others want to respond to, address, shape and minimize the proposed Outage Reporting requirements.

In making this filing, we tried to take positions that would eliminate or minimize the reporting burdens on WISPs and keep WISPA "at the table" and engaged in the official discussion. In this way, we hope to shape the outcome in the direction that burdens us the least and, in many cases, not at all. We propose exempting smaller WISPs completely from any reporting requirements except an outage to a Public Safety Answering Point (PSAP) - in other words, a 911 call center.

Please read the FCC NPRM and our official response (attached) and feel free to ask any questions on-list. If you wish to go on-record publicly with your own FCC Comments, you can do so by going to this page <http://fjallfoss.fcc.gov/ecfs/upload/display?z=q2dk7> and filing your Comments on Docket 11-82.

If there are any aspects of this filing (or any filing) that you wish to discuss privately, please feel free to phone me anytime.

Good work, Jack.

I note that the FCC's proposals reflect a virtually total lack of understanding of how the Internet works! They think somehow that end-to-end connectivity across the global Internet is broken if there is 1% packet loss or 100 ms. delay! TCP uses packet loss as a flow control mechanism so it is supposed to have loss end to end. There has to be. And given the diameter of the Internet, 100 ms. delays with lots of jitter are better than normal on many paths. So the Internet is always broken and always will be, so long as it uses TCP/IP or any other protocol that tolerates loss.

On the other hand they gave a pretty good description of Frame Relay's CBR service. Or telephone calls. Too bad they can't tell the Internet from the telephone network.


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 Fred Goldstein    k1io   fgoldstein "at" ionary.com
 ionary Consulting              http://www.ionary.com/
 +1 617 795 2701 

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