Net neutrality filing

Stephen Satchell list at
Sun Jun 18 01:13:27 CST 2017

On 06/17/2017 02:10 PM, Jeremy Austin wrote:
> I appreciate that a target of 35,000 per county or "county equivalent"
> (parish, borough?) is just a number — but I believe I would prefer a metric
> keyed to actual geographic population density rather than to political or
> municipal boundaries qua boundaries. At least it seems to me that you are
> wanting to encourage rural development, given that the current broadband
> 'divide' is largely a rural vs. urban one, according to the 2016 Broadband
> Progress Report.

If you have a better idea regarding how to differentiate rural monopoly
broadband providers to urban monopoly providers, please submit a comment
to the FCC about your ideas of the right way to differentiate them.

> Natural monopolies worked for electrification. Do you anticipate Title I
> providers as being sufficient to the task of narrowing this divide, with or
> without a federal incentives program? Historically, federal incentives have
> largely gone to Title II providers or their affiliated ISPs, if I
> understand the math correctly.

Title I providers did an excellent job back in the early days of the
Internet providing service in virtually every area, including rural
locations.  Let me explain.

I was on the Telecommunications Industry Associations' Transmitter Group
30 (TR30) by invitation of members, because I was publishing modem
reviews in places like Byte and MacWorld magazines.  The membership
invited me to learn how to do it "right" to better serve the readership.

(By the way, TIA TR30 used to be known as the "Modem Working Group".
See the references to 47 CFR 68.)

What was interesting is that the model "loops" (telephone circuits)
included wire simulation for calls between  rural locations to town
upramps to the 'Net.  When I incorporated the recommended loop models in
my testing, I was able to show what modems would be good for the
outliers to use.  In that sense, that was the industry's way of trying
to serve everyone, not just the "townies".

The only Title II involvement was over the PSTN circuits themselves.

Now, I can't talk to federal incentives.  I can understand why, though
-- the large providers have enough lawyers to put in bids "in the proper
language" to win awards.  The small ISPs can't afford a law firm with
sixty names on the masthead.

You may want to check the FCC site to see if there is a NPRM on
subsidies on rural broadband, and comment on the questions contained in
such a document.  Or file a request for consideration -- there is a way
to do that on EFCS.

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