USTA v. FCC: A Decision Ripe for the Supremes, co-authored with attorney Jonathan Marashlian for ISP-Planet, discusses the March, 2004 DC Circuit Court of Appeals remand of the FCC's Triennial Review Order, and explains why the Court's ruling did not square with either the law or the facts and is worthy of Supreme Court review.

VoIP Needs a Reality Check was Fred Goldstein's latest CNET article (2004), explaining why Internet Protocol is not always the best way to carry telephone calls, and why even old-fashioned Time Division Multiplexing has plenty of life, even while new "softswitch" technology has made most existing TDM switches obsolete.

Replacing the North American Numbering Plan describes the mess that currently exists in assigning telephone numbers, and suggests that a new numbering plan with 8-digit local numbers would be both preferable and possible to achieve. Expanding the North American Numbering Plan provides the details.

The Telecom Blame Game was a 2002 CNET news.com "Perspectives" piece outlining some of the reasons for the financial debacle facing the telecom industry, noting that the Telecommunications Act of 1996 did not play the major role that many commentators have ascribed to it.  This article was a preview of The Great Telecom Meltdown, which was being researched at the time.

Enterprise Network Strategy After the Bubble, a little article written by Fred Goldstein and Arthur Solomon for Business Communications Review. The online version is, alas, substantially abridged.

Cable Should Take a Fresh Look at Access  (available again from local copy) was written by Fred Goldstein and Peter Shapiro for Multichannel News in 1999. It explains why "forced access" by ISPs to cable modem networks is not a good thing, but why cable operators themselves should instead be actively opening up their networks to ISPs because it's in their own best interest.

In PS 06-229 and WT 06-150, the 700 MHz auction, Ionary drafted a comment for Interisle Consulting Group, 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.

In 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.

In 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.
 
In WT 02-353, the Commission sought input on rules for new Advanced Wireless Service ("3G") allocations in the 1700 and 2100 GHz band.  I suggested that about 5 MHz be "carved out" of at least one auctioned license and given to rural local exchange carriers for use as a broadband wireless local loop.  This would displace some of their future universal service "high cost support" funding.  My Comment also touched upon WT 02-381, which more directly addressed rural service issues.  (See this Ion for how the FCC dealt with the idea.)

In FCC 02-33, the Commission suggests treating DSL telecommunications services which are used by ISPs as if they were themselves information services, which the ISPs are.  This would effectively cut off the ISPs' right to use ILEC-provided DSL.  I filed a Brief Comment with the FCC explaining the technical error of their confusing content with carriage.  (Yes, I realize that my comments are usually not this brief!)