[Starlink] [NNagain] FCC Upholds Denial of Starlink's RDOF Application

Thu Dec 14 14:44:05 EST 2023

Thanks, Nathan.

I’m adding Brendan’s dissent as well:
https://x.com/brendancarrfcc/status/1734696706795778126

All the best,

Frank
Frantisek (Frank) Borsik

https://www.linkedin.com/in/frantisekborsik
Signal, Telegram, WhatsApp: +421919416714
iMessage, mobile: +420775230885
Skype: casioa5302ca
frantisek.borsik at gmail.com

On Thu, 14 Dec 2023 at 7:51 PM, Nathan Simington via Nnagain <
nnagain at lists.bufferbloat.net> wrote:

> Hi folks,
>
> (Apologies in advance to non-Americans or anyone who doesn't care about
> American home broadband policy! Please feel free to immediately delete!)
>
> I don't want to get overly political on this mailing list, but my
> statement on this topic is a matter of public record:
> https://docs.fcc.gov/public/attachments/FCC-23-105A3.pdf. As this item is
> now closed, there is no risk of any impermissible side-barring ("ex partes"
> that would have to be filed on the record, in regulatory jargon) if anyone
> wants to discuss this.
>
> The FCC is funded through regulatory fees which, traditionally, fell
> predominantly on broadcasters and monopoly-era AT&T. This mechanism, or at
> least how we calculate it, is increasingly inapposite for a world in which
> so much video and voice traffic takes place via unregulated services.
> That's one reason the agency is shrinking even as the communications
> industry is growing. Another is that many of our necessary functions, such
> as RF emissions enforcement, are on a non-fee basis and thus short-term
> painless to cut (even if that means that we're abandoning oversight of a
> rising noise floor, or of a device world where post-licensure quality fade
> on emissions control is normal business practice.)
>
> I'm on the record as saying that the FCC should reallocate resources and
> seek additional money with the goal of hiring 500 more engineers and field
> enforcement staff. That number is probably too small, but it would be a
> good start ;-) I was horrified to learn recently, while researching my
> Title II statement, that the FCC essentially has no internal experts left
> on peering and transit. How in blazes was this allowed to happen? (I hired
> one of the handful left as my chief of staff, but that just makes her
> unavailable to the career staff, so...)
>
> On this specific issue, I think a reasonable person could look at current
> federal broadband programs and see a significant bias in favor of fiber to
> the home. Someone drawing that conclusion might point, in addition to
> StarLink's situation, to the specific exclusion of unlicensed-frequency
> fixed wireless from the BEAD program, in defiance of the current tech
> trends. Anyone finding bias there might further note that the federal
> government talks incessantly about line speed but never about traffic
> management or router firmware and conclude that technically shallow federal
> politicians have no better ideas than to resort to the same metric that
> ISPs use in their advertising.
>
> I don't always see eye to eye with TechFreedom, which is why I so
> appreciated their filing on the same NOI that some in this group were
> involved with filing on. Their filing noted that line speed is a misleading
> and inappropriate proxy for customer experience quality, though not in the
> detail of the engineering filers, and also pointed out (among other points)
> that selling broadband to the public on the basis of telehealth and
> education is belied by the traffic numbers, which show that entertainment
> uses predominate. Not that I have anything against entertainment, but the
> feds haven't been candid (and perhaps the public has allowed itself to be
> deceived as well) about the reality of how its enormous fiber
> infrastructure subsidy commitments will be used in practice.
>
> If we can provide good service to people without the huge lift of a
> universal fiber to the home build, then the United States is headed in the
> wrong direction and will be wasting a lot of public money. And, unlike
> StarLink, we still won't have connected Dave's boat :-)
>
> All best,
> Nathan
>
> On Thu, Dec 14, 2023 at 12:49 PM David Bray, PhD via Nnagain <
> nnagain at lists.bufferbloat.net> wrote:
>
>> FCC's staff continues to shrink. 1420-or-so employees in 2022, 1755-or-so
>> in 2012, 1952-or-so in 2004. So about a 25% reduction over the last twenty
>> years. There are several good people there among the staff, however they
>> also face an increasing number of tasks and demands with less resources.
>> Public service depends on folks being willing to step up and be of service.
>>
>> Also, ultimately it is the decision of the Commissioners. Staff can brief
>> the Commissioners and present evidence, the Commissioners are there to make
>> the policy decisions. Remember Commissioners are Presidentially-appointed,
>> Senate-confirmed which selects for certain things in keeping with our
>> Constitution. For the staff, this means accepting that politics may
>> supersede even the best technical briefing.
>>
>> Such is how representative governments work. And if you circle back to
>> Plato's The Republic, the conclusion is such is how humanity wants it - we
>> don't want a perfectly wise, benevolent, philosopher king. Each of us wants
>> compromises - the difference being those specific compromises. Plato
>> (through the voice of Socrates) also concludes humanity would probably kill
>> a perfectly wise, benevolent, philosopher king if we were to ever have one
>> - again because despite everyone saying they want this, they really only
>> want such a person if that person agrees with them fully. Or as Tears for
>> Fears aptly put it: "Everybody Wants to Rule the World" =
>> https://www.youtube.com/watch?v=awoFZaSuko4
>>
>>
>>
>>
>> On Thu, Dec 14, 2023 at 1:00 AM Frantisek Borsik via Nnagain <
>> nnagain at lists.bufferbloat.net> wrote:
>>
>>> Thanks, Robert. Exactly what I meant. Therefore I added NN list, because
>>> Nathan was engaging with us there, and with Dave (me and some others, to my
>>> knowledge) either directly or via his staffers and he really wanted to
>>> catch up on tech things that are the culprits of Net Neutrality
>>> (bufferbloat.)
>>>
>>> So instead of assuming that Nathan Simington and Brendan Carr are
>>> “bought” as someone did, I can the FCC itself as an entity can be
>>> understaffed at worse.
>>>
>>> But still, I appreciate efforts to learn about what’s going in here and
>>> getting it right.
>>>
>>> All the best,
>>>
>>> Frank
>>> Frantisek (Frank) Borsik
>>>
>>> https://www.linkedin.com/in/frantisekborsik
>>> Signal, Telegram, WhatsApp: +421919416714
>>> iMessage, mobile: +420775230885
>>> Skype: casioa5302ca
>>> frantisek.borsik at gmail.com
>>>
>>>
>>> On Thu, 14 Dec 2023 at 3:46 AM, Robert McMahon <rjmcmahon at rjmcmahon.com>
>>> wrote:
>>>
>>>> I think this common in that appointment of commissioners go through a
>>>> political process. The FCC has a technology group, too. When I worked with
>>>> them about 8 years ago, they had skilled researchers on staff and a highly
>>>> skilled director. They asked good questions about engineering decisions,
>>>> like what is limiting the number of mimo streams on devices.
>>>>
>>>> Their physical facility is a bit dated, and they don't get stock
>>>> grants. I respect the engineers I worked with for what they did.
>>>>
>>>> Bob
>>>> On Dec 13, 2023, at 2:38 PM, Frantisek Borsik via Nnagain <
>>>> nnagain at lists.bufferbloat.net> wrote:
>>>>
>>>>> I would love for Nathan to be here with us, and comment on that :-) so
>>>>> I will add NN list as well.
>>>>>
>>>>>
>>>>> All the best,
>>>>>
>>>>> Frank
>>>>> Frantisek (Frank) Borsik
>>>>>
>>>>> https://www.linkedin.com/in/frantisekborsik
>>>>> Signal, Telegram, WhatsApp: +421919416714
>>>>> iMessage, mobile: +420775230885
>>>>> Skype: casioa5302ca
>>>>> frantisek.borsik at gmail.com
>>>>>
>>>>>
>>>>> On Wed, 13 Dec 2023 at 11:21 PM, Richard Roy <dickroy3777 at comcast.net>
>>>>> wrote:
>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> ------------------------------
>>>>>>
>>>>>> *From:* Starlink [mailto:starlink-bounces at lists.bufferbloat.net] *On
>>>>>> Behalf Of *Frantisek Borsik via Starlink
>>>>>> *Sent:* Wednesday, December 13, 2023 1:26 PM
>>>>>> *To:* Dave Taht via Starlink
>>>>>> *Subject:* [Starlink] FCC Upholds Denial of Starlink’s RDOF
>>>>>> Application
>>>>>>
>>>>>>
>>>>>>
>>>>>> “*Elon Musk*’s Starlink was not the only major company to inflate
>>>>>> its capabilities
>>>>>> <https://broadbandbreakfast.com/2021/04/rdof-reverse-auction-criticized-google-makes-pandemic-gains-california-broadband-access-for-k-12/> in
>>>>>> RDOF bids. Nearly 100 bidders have defaulted since the auction, leaving in
>>>>>> limbo an estimated $2.8 billion
>>>>>> <https://broadbandbreakfast.com/2023/06/what-happens-to-the-estimated-2-8-billion-in-rdof-defaults/> of
>>>>>> the $9.2 billion originally awarded.
>>>>>>
>>>>>>
>>>>>>
>>>>>> The FCC upheld another denial
>>>>>> <https://broadbandbreakfast.com/2023/12/fcc-proposes-22-million-fine-against-ltd-over-rdof/>
>>>>>>  on Monday in the case of LTD Broadband, which appealed the
>>>>>> commission’s finding that it could not reasonably serve the more than
>>>>>> 500,000 locations to which it had committed. The commission also hit LTD
>>>>>> with a $21.7 million fine for its default.
>>>>>>
>>>>>> The commission’s two Republicans dissented to Starlink’s denial,
>>>>>> claiming they saw a path for the company to improve its speeds before the
>>>>>> first deployment deadline in 2025.”
>>>>>>
>>>>>> *[RR] The reason two lawyers “saw a path” is because they were
>>>>>> bribed/conned into to see it. In my nearly 50years of experience dealing
>>>>>> with the FCC, extremely rarely are the people at the top in the commission
>>>>>> tech savvy.  In general, they have NO CLUE when it comes to technology …
>>>>>> period! **JJ*
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> https://broadbandbreakfast.com/2023/12/fcc-upholds-denial-of-starlinks-rdof-application/
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> All the best,
>>>>>>
>>>>>> Frank
>>>>>> Frantisek (Frank) Borsik
>>>>>>
>>>>>> https://www.linkedin.com/in/frantisekborsik
>>>>>> Signal, Telegram, WhatsApp: +421919416714
>>>>>> iMessage, mobile: +420775230885
>>>>>> Skype: casioa5302ca
>>>>>> frantisek.borsik at gmail.com
>>>>>>
>>>>> ------------------------------
>>>>>
>>>>> Nnagain mailing list
>>>>> Nnagain at lists.bufferbloat.net
>>>>> https://lists.bufferbloat.net/listinfo/nnagain
>>>>>
>>>>> _______________________________________________
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>>> https://lists.bufferbloat.net/listinfo/nnagain
>>>
>> _______________________________________________
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>> Nnagain at lists.bufferbloat.net
>> https://lists.bufferbloat.net/listinfo/nnagain
>>
>
>
> --
> Nathan Simington
> cell: 305-793-6899
> _______________________________________________
> Nnagain mailing list
> Nnagain at lists.bufferbloat.net
> https://lists.bufferbloat.net/listinfo/nnagain
>
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