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@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@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@gmail.com


On Thu, 14 Dec 2023 at 3:46 AM, Robert McMahon <rjmcmahon@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@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@gmail.com


On Wed, 13 Dec 2023 at 11:21 PM, Richard Roy <dickroy3777@comcast.net> wrote:

 

 

From: Starlink [mailto:starlink-bounces@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 in RDOF bids. Nearly 100 bidders have defaulted since the auction, leaving in limbo an estimated $2.8 billion of the $9.2 billion originally awarded. 

 

The FCC upheld another denial 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

 




All the best,

Frank
Frantisek (Frank) Borsik

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

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Nathan Simington
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