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".  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 a hot topic today: Would the industry's problems be 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? 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).

TCP/IP is obsolete!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.  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, a new organization dedicated to developing solutions for solving the Internet crisis, starting with John Day's PNA, and recommend reading the book and the web site.  

Ionary Principal Fred Goldstein  has a column on TMCnet!  Articles include:

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 "papers" and articles written by Fred Goldstein, principal of Ionary Consulting

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.

Some FCC Comments of interest written by Ionary's Fred Goldstein:

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.

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!)