Points of view...
Slightly charged little articles:
..nosiree, this isn't a blog, nope. it ain't a blog, just keep repeating, no blog, no, I Am Not A Blogger...
TCP/IP is obsolete! Yes, the familiar protocol suite that the Internet runs on is still chugging along, but behind the scenes, it's getting harder and harder to maintain. It's even less well suited to I.T. and telecom applications than it is for the Internet itself. The IETF's preferred solution, IPv6, just isn't the answer. A much better approach comes about from rethinking network architecture from top to bottom. John Day's book Patterns in Network Architecture: A Return to Fundamentals takes such a view, taking into account what we've learned in the 30-odd years since TCP/IP was created. We're happy to be associated with the Pouzin Society, an organization dedicated to developing solutions for solving the Internet crisis, starting with John Day's concepts, and recommend reading the book and the web site.
A successor to TCP/IP called RINA (Recursive InterNetwork Architecture) based on these ideas is now under development. Fred Goldstein and John Day have written a somewhat brief (18 pages) description called Moving Beyond TCP/IP. RINA, the protocol architecture based on the PNA concept, addresses the major failings of today's Internet and its IP network monoculture. These include scalability, security, multihoming, multicasting, and mobiliity. It also offers improved streaming capabilities, flexible Quality of Service options, and a technical solution for ensuring the benefits of "neutrality" without the many problems of other proposals. By using the same basic layer mechanism recursively for as many layers as required, rather than having a fixed stack with purpose-built protocols at each layer, it is fundamentally simple, yet very powerful. RINA can even coexist with IPv4 networks more easily than IPv6, making its adoption more practical. The IRATI project (Investigating RINA as an Alternative to TCP/IP) is developing prototype code. An "All-IP Network" would thus be a step in the wrong direction.
The Internet is Ungovernable. In November, 2013, the Columbia Institute for Tele-Information (CITI) hosted a webinar Is There A Third Way For The Internet: Neither The US Nor The UN But Independence? Fred Goldstein was a panelist, delivering a presentation Internet by Definition, that explained why The Internet (big-I), a prototype internet, cannot be governed like the telephone network. An internet is merely a voluntary agreement, and rides in the payload of telecommunications networks, which are what can be regulated. Fred Goldstein's talk begins at 1:07:54 on this YouTube recording of the event. The December, 2013 TMCnet article below covers the same ground in prose.
Has Divestiture Worked? The Internet Society of New York held a 25th Anniversary of the AT&T Divestiture presentation, an "assessment on the breakup of AT&T", in 2009. As one of the panelists, Ionary principal Fred Goldstein gave a 20-minute presentation Telecom Policy Going Forward: A model for competitive change, or, the case for a second Divestiture. It's the first part of this video presentation.
Structural Separation is one way to solve many of the problems in the telecom and Internet worlds: Would we all be better served if the incumbent telephone companies were split into separate companies, one (LoopCo) to own the natural-monopoly plant, and one (ServiceCo) to provide services? Then competitive carriers and ISPs would be on an equal footing with the ServiceCo, and issues like "network neutrality" could be dealt with via enhanced competition. Fiber upgrades would be more practical because one plant build by LoopCo could be shared by all potential users, even cable But of course the devil's in the details! Here's Ionary's draft of a state-level bill to legislate separation, either functional (one company, separate subsidiaries) or structural (two companies).
Fred Goldstein has a column on TMCnet! Articles include:
Why the Internet is, By Definition, Ungovernable (12/27/2013). While international organizations debate "internet governance", they misunderstand the fundamental nature of the Internet and of internets in general.
America's Three-Way Digital Divide (4/9/2013) While unsubsidized carriers invest in urban areas because it's profitable, and some rural carriers have received huge subsidies to upgrade, rural areas served by the big carriers have been left behind. And now the Bells want to simply abandon them.
The End of the Line, But Which Line? (12/19/2012) Some are talking about "the end of the PSTN", but after two decades minimal wireline investment, maybe time has caught up with the big ILECs themselves.
The FCC's 'Connect America Fund' Order Proposes Regulating the Internet Backbone (12/21/2011) By conflating "IP" with "Internet", and ignoring standard VoIP practices, the FCC's new proposals open the door to put Internet itself under PSTN regulation.
There's No Such Thing as VoIP (10/28/2011) Trying to regulate or manage Voice over IP as if it were one specific thing is doomed ot fail. VoIP is a tool that is part of many different things, which should be viewed on their own merits.
Fiber Dividend or New Digital Divide? (7/29/2011) Fiber optics dramatically lower the cost of bits. So why are ILECs often still pricing fiber-based services like DS3 and Carrier Ethernet based on the value of the toll cals that it could theoretically displace?
Embracing Failure: The FCC's Disastrous Internet Policy (1/31/2011). Two ISPs is enough, but the FCC says ISPs need to be regulated because telephone and cable duopolies are not sufficiently competitive. Say what?
Living in the Past. (11/18/2010) Many aspects of today's network scene, from "local calls" to "end to end", are relics of a bygone era, but we can't seem to escape them..
After Comcast, can the FCC Order Network Neutrality? (4/20/2010) The DC Circuit's decision striking down the FCC's "Title I" approach may turn out to be the most pro-neutrality ruling possible.
The Net that Got Away. (12/04/2009). Telephone companies made huge profits from deregulation, which was granted in the early 1990s in exchange for promising to build networks that never got built.
What does it mean to be Internet? (6/08/2009). Internet is a business model, not a protocol. "Internet (n.) A voluntary agreement among network operators to exchange traffic for their mutual benefit."
How Workarounds Drive Telecom and Networking (4/29./2009). What passes for progress is often just hacks that work around regulatory and legal issues, and workarounds around those workarounds.
Universal Service: Uncle Sam's Blank Check (12/18/2008) The Universal Service Fund supports rural telephone companies with no cost-benefit analysis, and the results are predictable.
Of Network Privacy, Neutrality, and Turtles (7/09/08) When carriage is treated like content, privacy of the payload is a more sensible policy goal than "neutrality".
The Dismal Reality of Internet Management (3/05/08) Internet usage isn't free; ISPs need to align costs with prices.
Quality of Service Doesn't Justify IMS Walled Gardens (11/05/07) IP Multimedia Subsystem advocates come up with the strangest reasons to break the Internet.
Intermodel Competition: The Internet's Threat to Telcos (4/13/07) It's the competiitive business model, not technology, that makes the Internet so attractive.
The Tyranny of the Low Home Phone Rate (9/27/06) So much of the US regulatory system is out of kilter just because regulators want the basic monthly phone rate to be low.
Net Neutrality and the Internet Video Red Herring (6/16/06) There are a lot of ways to deliver video. Whether they use IP or not does not make them the Internet, and does not justify IMS.
How Big Ed Torpedoed Lucent, and Other Stories (4/17/06) When there are more sellers than buyers, it's not a good time to be a seller.
Spectrum Banking: How the FCC Creates Scarcity (3/09/06) Spectrum licenses can be left fallow, which may be more valuable to incumbents than actually using them.
Network Neutrality is an Answer to the Wrong Problem (2/10/06) What's needed is common carriage, to allow many ISPs to compete over the same wire.
These ions are exclusive here:
IPv6: More Filling, Less Taste (12/28/05). The "new" Internet Protocol is over a decade old and still going nowhere fast, for good reason.
Rolling, Rolling, Rolling on the (Madison) River (10/23/05). The FCC's Consent Decree with Madison River Communications perpetuates a myth that there's some kind of rule against ISPs' blocking VoIP traffic. Guess again. More likely, Madison River just got rolled.
FCC to ISPs: Drop Dead (8/9/05). The FCC's decision to deregulate ILEC raw DSL services puts independent ISPs in jeopardy. Yet it appears to be based on a profoundly flawed, even backwards, reading of the Supreme Court's Brand X ruling.
When broadband offers less, not more (7/7/05). It's called "broadband" but it's not the Internet as we know it. Will re-monopolized ILEC DSL adopt "walled garden" services instead of "getting Skyped"?
That Curious American style of regulation (1/29/05) The American telecommunications regulatory system is based on the categorization of services that reflects conditions at one point in time, ignoring the rationale behind regulation, such as competition and market power.
ILECs and their Amazing Astroturf Machine (10/6/04) The Bells positions get public support from supposed "consumer" groups such as TRAC, but behind them is a public relations machine hired by the Bells.
Broadband over Power Lines -- how bad an idea can you get? (7/30/04) The FCC is encouraging electric companies to use their wires for high-speed Internet access, even if it wipes out much of the radio spectrum.
Cable telephony -- parasite or profit? (3/15/04) Cable operators should team up with CLECs and ISPs to become their last mile access wholesalers, rather than leave all of the VoIP business to providers who don't pay them anything.
Drawing the lines around VoIP isn't so easy (1/8/04) It's one thing to say "don't regulate VoIP", but it's another thing to figure out just what should be regulated, or even what VoIP is, especially if it were given favorable regulatory status.
A brief, sad study in how the FCC reads Comments (12/16/03) One way they dismiss a Comment that doesn't go along with their preferred outcome is to misquote it. As in the recent Advanced Wireless Service docket...
Fiber to the home -- is too much really enough? (11/10/03) The economics of FTTH aren't compelling, but the FCC is solving this non-problem by removing its potential benefits to the customer.
Call classification, the Achilles Heel of telecom regulation (8/12/03) The wholesale price of a phone call varies drastically depending upon rather arbitrary classification, which doesn't work in a competitive market...
A free-market approach to canning spam (7/21/03) Spam is prevalent because email is free to the sender, even if it comes from a stranger; if it were merely extremely cheap, spam would dry up...
The compelling business imperative of Open Source software (5/13/03) Linux, it isn't just for weenies any more...
Postmodern network architecture and the failure of reregulation (4/5/03) When the FCC wrote its rules to implement the Telecom Act, they enshrined 1996's state of the art...
The Bells and Broadband -- the promise never kept (2/23/03) Fiber to the home? Now when have we heard that before?
Carterfone and Unbundled Network Elements (2/03/03) In 1969, the FCC's Carterfone decision broke the telco's monopoly on terminal equipment, and they still don't get it....
VoIP -- Inevitable or Impractical? (12/23/02) Voice over Internet Protocol has its applications, but it's terribly oversold; there's plenty of life left in supposedly-obsolete telephone technology...
Breaking up the ILECs: A win-win proposition (11/10/02) While structural separation may sound draconian, separating the incumbent local exchange carriers from their outside plant can be good for them as well as their competitors....
Is the UNE Platform the answer to the CLEC's prayers? (11/6/02) This controversial approach allows CLECs to enter the market quickly with relatively little capital expenditure, but it's more of a short-term entry tool than a long-term strategy....
A few other "papers" and articles written by Fred Goldstein, principal of Ionary Consulting
Some FCC Comments of interest written by Ionary's Fred Goldstein:
In the FCC's 2012 review of the AT&T Petition to Launch a Proceeding Concerning the TDM-to-IP Transition, Interisle filed Comments that explained why AT&T's premise is fundamentally flawed, and why further deregulation in the name of IP is unwarranted. Our Comments focus on core issues such as the meaning of the terms PSTN, POTS, and IP. Most of the time when IP is used for telephony, it is not via the Internet, so it should not be treated as if it were. Our Reply Comments were more supportive of the NTCA petition and others who support a gradual transition of technology within the PSTN.
In the FCC's 2010 Framework for Broadband Internet Service GN 10-127, in which the FCC suggested three alternative approaches to enforcing "network neutrality", Ionary filed Comments focusing on the need for a layered appoach, to distinguish between carriage and content. Internet should be seen as content, but bit-neutral common carriage should be made available as a wholesale product.. When the FCC asked for comments on six specific proposals addressing "two under-developed issues" in GN-09-191, Ionary filed these consistent Comments.
In the FCC's massive 2009 Broadband Plan proceeding GN 09-51, Ionary filed Comments distinguishing between broadband carriage and content. This results in flexibility and freedom without the potential content regulation of "network neutrality". Universal service, spectrum policy and privacy issues are also addressed.
In the 2008 reopening of WC 01-92, WC 05-33, WC 06-122 and numerous other related dockets, on behalf of the Coalition for Rational Universal Service and Intercarrier Reform, a group of clients, Ionary drafted this Comment on the proposed Universal Service Fund reform, opposing a numbers-and-connection-based fee, and this Comment on the proposed Intercarrier Compensation reform, supporting unified intercarrier compensation. An additional Comment and Reply Comment on three specific intercarrier compensation issues, and a longer Comment in the April round and Comment and Reply Comment in the August-September round, on broader issues including the Connect America Fund, were filed in the 2011 reopening of the Comment period. The FCC issued a 751-page Order and Further Notice of Proposed Rulemaking in November, 2011. You can read Fred Goldstein's Summary and Analysis of the FCC’s November, 2011 Universal Service and Intercarrier Compensation Order here. Warning: It is 18 pages and over 10,000 words long..
In PS 06-229 and WT 06-150, the 700 MHz auction, Ionary drafted a comment for Interisle Consulting Group, at the time one of our collaborating consultancies. We had helped Frontline Wireless and were familiar with the issues that led to the faillure of the combined D-Block and Public Safety Broadband License auction. We suggest that this is both a procurement and an auction, and must be treated like a competitive procurement, with reasonable and well-defined requirements.
In WC 06-172, Ionary filed an Opposition to Verizon's request for forbearance from unbundling obligations. Their proposal would have put most CLECs out of business in most of Verizon's territories and inflamed the "network neutrality" crisis by further reducing ISP competiton.
In WC 01-92 (reopened by Further Notice FCC 05-33), the Commission addressed the intercarrier compensation rates paid for telephone calls. The Comment filed by Ionary and several clients supported a system of unified, totally unclassified cost-based payments, abolishing the Switched Access system and merging all calls onto a reciprocal compensation basis.
In WC 05-25, the Commission sought guidance for Special Access (leased line) rates charged by the big ILECs. The Comment filed by Ionary on behalf of several clients pointed out how rates are far above cost, especially in rural areas where ILEC mileage rates are many times the rates arrived at in recent cost studies. This proves that competition is often not sufficient to keep prices in line, so new cost studies should be performed and stricter rate limits should be implemented.
WC 04-313, the
Commission re-opened the Triennial Review of Unbundled Network
Elements, following the D.C. Circuit's remand order. My Comment
pointed out how facilities-based CLECs engaged in UNE Loop
operation are dependent upon Interoffice Dedicated Transport and
entrance facilities, and how it is impractical to replaced
unbundled switching (UNE Platform) in small wire centers.
WC 04-36, the Commission
seeks input into the appropriate treatment for "IP-enabled"
voice services. I described how there are many different
types of service that could be seen as IP-enabled, and how even
IP itself is not well-defined, so rules that are not
technology-neutral would be hard to enforce. My Comment
suggested that the PSTN monopolies required strict regulation at
their boundaries, and that today's classification of calls by
type (local/access/ISP) or source should be replaced by fully
unified intercarrier compensation mechanism.
FCC 02-33, the
Commission suggests treating DSL telecommunications
services which are used by ISPs as if they were
services, which the ISPs are. This would
effectively cut off the ISPs' right to use ILEC-provided DSL.
I filed a Brief
with the FCC explaining the technical error of their
confusing content with
carriage. (Yes, I
realize that my comments are usually not this brief!)
In 1999, the FCC proposed rules for Low Power FM broadcasting. While actual implementation was delayed for a decade by Congressional meddling, it seems to me that the rules that FCC finally adopted were rather closer to my Comment than to the original proposal.