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	<title>Comments for Bits on Broadband</title>
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	<link>http://www.bitsonbroadband.com</link>
	<description>with Fred Campbell</description>
	<lastBuildDate>Tue, 24 Jan 2012 23:15:26 +0000</lastBuildDate>
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		<title>Comment on The FCC’s Section 332 Problem: Why the FCC Can’t Regulate Mobile Wireless Broadband as a Common Carrier Service by gratis advokat</title>
		<link>http://www.bitsonbroadband.com/2010/07/the-fcc%e2%80%99s-section-332-problem-why-the-fcc-can%e2%80%99t-regulate-mobile-wireless-broadband-as-a-common-carrier-service/comment-page-1/#comment-3005</link>
		<dc:creator>gratis advokat</dc:creator>
		<pubDate>Tue, 24 Jan 2012 23:15:26 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=258#comment-3005</guid>
		<description>We&#039;re a gaggle of volunteers and starting a brand new scheme in our community. Your web site provided us with helpful info to work on. You have performed a formidable job and our entire community will likely be grateful to you.</description>
		<content:encoded><![CDATA[<p>We&#8217;re a gaggle of volunteers and starting a brand new scheme in our community. Your web site provided us with helpful info to work on. You have performed a formidable job and our entire community will likely be grateful to you.</p>
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		<title>Comment on The House Spectrum Bill Is Already a Compromise by Michael Marcus</title>
		<link>http://www.bitsonbroadband.com/2011/12/the-house-spectrum-bill-is-already-a-compromise/comment-page-1/#comment-2977</link>
		<dc:creator>Michael Marcus</dc:creator>
		<pubDate>Sat, 17 Dec 2011 18:34:46 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=619#comment-2977</guid>
		<description>Two points.  Fred writes: &quot;Although I appreciate the FCC’s desire for unlimited authority, it isn’t surprising that the House has proposed to limit the scope of the FCC’s delegation over spectrum policies granting special market privileges to favored technologies, services, or industry groups. Rather than make things better, FCC attempts to fine tune the market through government privilege typically result in unintended consequences that make things worse.&quot;

Today&#039;s ubiquitous Wi-Fi, subject of a love/hate relationship by the cellular industry, comes from precisely &quot;spectrum policies granting special market privileges to favored technologies&quot;  - see http://www.marcus-spectrum.com/page4/SSHist.html  Was that so bad?

I agree with Fred&#039;s statement, &quot;the FCC’s attempt to make cleared spectrum available for unlicensed use in the PCS band was largely considered a disaster&quot;, but like the Milgrom report he attributes this to the issue of whether the band was licensed or unlicensed.  The U-PCS failure was in my opinion more of a result of a very detailed set of technical specifications that industry demanded the FCC adopt whereas the ISM band (Wi-Fi/Bluetooth) FCC rules were also unlicensed but very general so they could adapt with changing requirements.

So while both Fred and Milgrom focus on the unlicensed/licensed dichotomy as being the key factor in success, I feel that technical flexibility and deregulation, available in both the ISM band and the CMRS rules, has also been a key factor.</description>
		<content:encoded><![CDATA[<p>Two points.  Fred writes: &#8220;Although I appreciate the FCC’s desire for unlimited authority, it isn’t surprising that the House has proposed to limit the scope of the FCC’s delegation over spectrum policies granting special market privileges to favored technologies, services, or industry groups. Rather than make things better, FCC attempts to fine tune the market through government privilege typically result in unintended consequences that make things worse.&#8221;</p>
<p>Today&#8217;s ubiquitous Wi-Fi, subject of a love/hate relationship by the cellular industry, comes from precisely &#8220;spectrum policies granting special market privileges to favored technologies&#8221;  &#8211; see <a href="http://www.marcus-spectrum.com/page4/SSHist.html" rel="nofollow">http://www.marcus-spectrum.com/page4/SSHist.html</a>  Was that so bad?</p>
<p>I agree with Fred&#8217;s statement, &#8220;the FCC’s attempt to make cleared spectrum available for unlicensed use in the PCS band was largely considered a disaster&#8221;, but like the Milgrom report he attributes this to the issue of whether the band was licensed or unlicensed.  The U-PCS failure was in my opinion more of a result of a very detailed set of technical specifications that industry demanded the FCC adopt whereas the ISM band (Wi-Fi/Bluetooth) FCC rules were also unlicensed but very general so they could adapt with changing requirements.</p>
<p>So while both Fred and Milgrom focus on the unlicensed/licensed dichotomy as being the key factor in success, I feel that technical flexibility and deregulation, available in both the ISM band and the CMRS rules, has also been a key factor.</p>
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		<title>Comment on The FCC’s Signal Boosters Proposal Would Codify a Market Failure by Mike Marcus</title>
		<link>http://www.bitsonbroadband.com/2011/08/the-fcc%e2%80%99s-signal-boosters-proposal-would-codify-a-market-failure/comment-page-1/#comment-2970</link>
		<dc:creator>Mike Marcus</dc:creator>
		<pubDate>Thu, 29 Sep 2011 19:16:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=601#comment-2970</guid>
		<description>CTIA could not have written this better as it fully reflects their viewpoint.

Now, like the blind men and the elephant, let me give an alternative viewpoint:

While you state &quot;Until recently, the FCC appeared to believe that the Communications Act prohibited the marketing and sale of signal boosters without licensee consent or control&quot; - this is contradicted by the fact that FCC has been granting equipment authorization to these devices for at least a decade and the manuals made no secret what their use was.

Maybe WTB staffers wanted to please CTIA by banning them.

In reality there is poor cellular coverage in many rural areas and that is precisely where these devices sell well.  If the cellular industry offered alternative technology and service at a fair price then these devices would disappear from the market.  I recently installed one on my sailboat for the basic reason that a lot of creeks on the Eastern Shore where I like to go on summer weekends have no cellular coverage.  Indeed, Tolchester Marina (http://www.tolchestermarina.com/) near Chestertown MD is in an area without coverage even though it is a business on a main road.

Early generation boosters indeed did cause interference due to feedback.  It is troubling that FCC refused to take any real action in this area and basically stonewalled CTIA&#039;s  11/07 petition (http://files.ctia.org/pdf/filings/FINAL--CTIA--_Jammers_Petition_for_Declaratory_Ruling.pdf)for several years.  Fred, weren&#039;t you in charge when this was filed at FCC?

In any case, boosters sold now by the top manufacturers have features that prevent this interference from feedback.  But the lack of ANY FCC action allows old style booster to still be sold.  The cellular industry has raised some other technical issues where interference is possible.  After demanding a total ban on boosters, several carriers are reported now to be negotiating with responsible booster manufacturers for technical standards that would avoid other types of interference even if it means that in some places boosters would have to turn off to avoid a small interference risk.  

Such mutually agreeable standards would be win-win and would allow the public in rural areas to get the service expected elsewhere that the cellular industry has not been able to provide while preventing interference.  Indeed, rural law enforcement are presently big users of these boosters as is well documents in the 10-4 docket file.</description>
		<content:encoded><![CDATA[<p>CTIA could not have written this better as it fully reflects their viewpoint.</p>
<p>Now, like the blind men and the elephant, let me give an alternative viewpoint:</p>
<p>While you state &#8220;Until recently, the FCC appeared to believe that the Communications Act prohibited the marketing and sale of signal boosters without licensee consent or control&#8221; &#8211; this is contradicted by the fact that FCC has been granting equipment authorization to these devices for at least a decade and the manuals made no secret what their use was.</p>
<p>Maybe WTB staffers wanted to please CTIA by banning them.</p>
<p>In reality there is poor cellular coverage in many rural areas and that is precisely where these devices sell well.  If the cellular industry offered alternative technology and service at a fair price then these devices would disappear from the market.  I recently installed one on my sailboat for the basic reason that a lot of creeks on the Eastern Shore where I like to go on summer weekends have no cellular coverage.  Indeed, Tolchester Marina (<a href="http://www.tolchestermarina.com/" rel="nofollow">http://www.tolchestermarina.com/</a>) near Chestertown MD is in an area without coverage even though it is a business on a main road.</p>
<p>Early generation boosters indeed did cause interference due to feedback.  It is troubling that FCC refused to take any real action in this area and basically stonewalled CTIA&#8217;s  11/07 petition (<a href="http://files.ctia.org/pdf/filings/FINAL--CTIA--_Jammers_Petition_for_Declaratory_Ruling.pdf)for" rel="nofollow">http://files.ctia.org/pdf/filings/FINAL&#8211;CTIA&#8211;_Jammers_Petition_for_Declaratory_Ruling.pdf)for</a> several years.  Fred, weren&#8217;t you in charge when this was filed at FCC?</p>
<p>In any case, boosters sold now by the top manufacturers have features that prevent this interference from feedback.  But the lack of ANY FCC action allows old style booster to still be sold.  The cellular industry has raised some other technical issues where interference is possible.  After demanding a total ban on boosters, several carriers are reported now to be negotiating with responsible booster manufacturers for technical standards that would avoid other types of interference even if it means that in some places boosters would have to turn off to avoid a small interference risk.  </p>
<p>Such mutually agreeable standards would be win-win and would allow the public in rural areas to get the service expected elsewhere that the cellular industry has not been able to provide while preventing interference.  Indeed, rural law enforcement are presently big users of these boosters as is well documents in the 10-4 docket file.</p>
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		<title>Comment on Netflix CEO Advocates for Internet Price Regulation – the Net Neutrality Endgame by testing</title>
		<link>http://www.bitsonbroadband.com/2011/07/netflix-ceo-advocates-for-internet-price-regulation-%e2%80%93-the-net-neutrality-endgame/comment-page-1/#comment-2925</link>
		<dc:creator>testing</dc:creator>
		<pubDate>Sat, 27 Aug 2011 21:19:37 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=543#comment-2925</guid>
		<description>This website online is mostly a stroll-by means of for all the info you wished about this and didn’t know who to ask. Glimpse right here, and also you’ll undoubtedly uncover it.</description>
		<content:encoded><![CDATA[<p>This website online is mostly a stroll-by means of for all the info you wished about this and didn’t know who to ask. Glimpse right here, and also you’ll undoubtedly uncover it.</p>
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		<title>Comment on What’s Good for the Cable Goose Isn’t Good for the Wireless Gander by Bambi Granados</title>
		<link>http://www.bitsonbroadband.com/2010/05/what%e2%80%99s-good-for-the-cable-goose-isn%e2%80%99t-good-for-the-wireless-gander/comment-page-1/#comment-2877</link>
		<dc:creator>Bambi Granados</dc:creator>
		<pubDate>Thu, 14 Jul 2011 08:29:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=196#comment-2877</guid>
		<description>Very good task and nicely carried out!</description>
		<content:encoded><![CDATA[<p>Very good task and nicely carried out!</p>
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		<title>Comment on Cause and Effect: A response to Harold Feld’s post on the AWS-3 band by fruits</title>
		<link>http://www.bitsonbroadband.com/2010/03/cause-and-effect-a-response-to-harold-feld%e2%80%99s-post-on-the-aws-3-band/comment-page-1/#comment-2876</link>
		<dc:creator>fruits</dc:creator>
		<pubDate>Thu, 07 Jul 2011 23:59:31 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=96#comment-2876</guid>
		<description>I have returned to your blog many times. The additional articles are very fascinating and interesting. I wanted to signup for your rss feed,  so I can keep informed of your latest posts.</description>
		<content:encoded><![CDATA[<p>I have returned to your blog many times. The additional articles are very fascinating and interesting. I wanted to signup for your rss feed,  so I can keep informed of your latest posts.</p>
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		<title>Comment on The Fiber-To-The-Premises Dream by Jess</title>
		<link>http://www.bitsonbroadband.com/2011/05/the-fiber-to-the-premises-dream/comment-page-1/#comment-2678</link>
		<dc:creator>Jess</dc:creator>
		<pubDate>Fri, 27 May 2011 22:39:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=496#comment-2678</guid>
		<description>VZN may well be losing money on FIOS, but you can&#039;t prove that from the fact that its revenue and subscribers are lower than those of some other product. FIOS is only available in a small fraction of VZN&#039;s territory, so one would expect those numbers to be lower even if it were wildly profitable.

Even if we were to stipulate that VZN is losing money on all its fixed-wire products, it seems fishy that there is only one national wireless provider left that doesn&#039;t have its own significant ILEC holdings underwriting backhaul for the wireless business. Doesn&#039;t it seem possible that backhaul is undervalued when they&#039;re putting these numbers together?

As for USF, it seems quite unlikely that anything pro-consumer could ever be salvaged from that mess.</description>
		<content:encoded><![CDATA[<p>VZN may well be losing money on FIOS, but you can&#8217;t prove that from the fact that its revenue and subscribers are lower than those of some other product. FIOS is only available in a small fraction of VZN&#8217;s territory, so one would expect those numbers to be lower even if it were wildly profitable.</p>
<p>Even if we were to stipulate that VZN is losing money on all its fixed-wire products, it seems fishy that there is only one national wireless provider left that doesn&#8217;t have its own significant ILEC holdings underwriting backhaul for the wireless business. Doesn&#8217;t it seem possible that backhaul is undervalued when they&#8217;re putting these numbers together?</p>
<p>As for USF, it seems quite unlikely that anything pro-consumer could ever be salvaged from that mess.</p>
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		<title>Comment on The FCC’s New Interpretation of Section 706(b) Opens a Pandora’s Box of Internet Regulation by dave</title>
		<link>http://www.bitsonbroadband.com/2011/05/the-fcc%e2%80%99s-new-interpretation-of-section-706b-opens-a-pandora%e2%80%99s-box-of-internet-regulation/comment-page-1/#comment-2673</link>
		<dc:creator>dave</dc:creator>
		<pubDate>Fri, 27 May 2011 15:29:26 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=489#comment-2673</guid>
		<description>Good points Fred and Agreed, but this is only more the reason to conclude that broadband service is a right of, and for, the good of the commons, and not for-private entities. 

Edge providers have creatively destructed old, entrenched, non innovative industry, and put a whole new generation to work. Scary, but thats how it works.

Hopefully voters will someday get the fact that without basic BB service, they will be locked out of the information game, job race, chance to educate/improve themselves/families. This is already happening with digital divide/rural issues.

Just as the private roadways were built -and gave way to public owned right of ways ( and now toll ways), but governed (and regulated) by law. Broadband should be everyones right to information and knowledge.

Trying to privatize this common right of way (information) ultimately will challenge our free speech, and the core of our freedoms ...all in the name of secular profit. 

And I believe in this case, trading near term privatized gain, for future common gains, will have proven to be a recipe for societal/ economic failure.</description>
		<content:encoded><![CDATA[<p>Good points Fred and Agreed, but this is only more the reason to conclude that broadband service is a right of, and for, the good of the commons, and not for-private entities. </p>
<p>Edge providers have creatively destructed old, entrenched, non innovative industry, and put a whole new generation to work. Scary, but thats how it works.</p>
<p>Hopefully voters will someday get the fact that without basic BB service, they will be locked out of the information game, job race, chance to educate/improve themselves/families. This is already happening with digital divide/rural issues.</p>
<p>Just as the private roadways were built -and gave way to public owned right of ways ( and now toll ways), but governed (and regulated) by law. Broadband should be everyones right to information and knowledge.</p>
<p>Trying to privatize this common right of way (information) ultimately will challenge our free speech, and the core of our freedoms &#8230;all in the name of secular profit. </p>
<p>And I believe in this case, trading near term privatized gain, for future common gains, will have proven to be a recipe for societal/ economic failure.</p>
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		<title>Comment on The FCC’s New Interpretation of Section 706(b) Opens a Pandora’s Box of Internet Regulation by FredCampbell</title>
		<link>http://www.bitsonbroadband.com/2011/05/the-fcc%e2%80%99s-new-interpretation-of-section-706b-opens-a-pandora%e2%80%99s-box-of-internet-regulation/comment-page-1/#comment-2658</link>
		<dc:creator>FredCampbell</dc:creator>
		<pubDate>Thu, 26 May 2011 23:26:52 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=489#comment-2658</guid>
		<description>Dave, I&#039;ll try to post tomorrow about why fiber isn&#039;t being built out by telcos (economics). I&#039;m not sure to which incumbent you refer? Cable? Insofar as the regulatory process goes, it&#039;s made deployment harder. Net neutrality shifts revenue (and thus infrastructure investment incentives) from service providers to edge providers. Ironically, edge provider profits and market caps (e.g., Google and Apple) are much higher than infrastructure providers. Edge providers are the ones profiting the most from broadband, but they don&#039;t build retail networks. They just use them.</description>
		<content:encoded><![CDATA[<p>Dave, I&#8217;ll try to post tomorrow about why fiber isn&#8217;t being built out by telcos (economics). I&#8217;m not sure to which incumbent you refer? Cable? Insofar as the regulatory process goes, it&#8217;s made deployment harder. Net neutrality shifts revenue (and thus infrastructure investment incentives) from service providers to edge providers. Ironically, edge provider profits and market caps (e.g., Google and Apple) are much higher than infrastructure providers. Edge providers are the ones profiting the most from broadband, but they don&#8217;t build retail networks. They just use them.</p>
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		<title>Comment on The FCC’s New Interpretation of Section 706(b) Opens a Pandora’s Box of Internet Regulation by Brett Glass</title>
		<link>http://www.bitsonbroadband.com/2011/05/the-fcc%e2%80%99s-new-interpretation-of-section-706b-opens-a-pandora%e2%80%99s-box-of-internet-regulation/comment-page-1/#comment-2657</link>
		<dc:creator>Brett Glass</dc:creator>
		<pubDate>Thu, 26 May 2011 22:03:59 +0000</pubDate>
		<guid isPermaLink="false">http://www.bitsonbroadband.com/?p=489#comment-2657</guid>
		<description>A close look at the definitions in Section 1302 (which supercedes and replaces Section 706) shows that &quot;advanced telecommunications capability&quot; doesn&#039;t refer to the Internet at all. It refers to &quot;switched&quot; (not packet-based) telecommunications services, like ISDN. How can the FCC claim regulatory power over the Net via a statute which doesn&#039;t even apply to the Internet?</description>
		<content:encoded><![CDATA[<p>A close look at the definitions in Section 1302 (which supercedes and replaces Section 706) shows that &#8220;advanced telecommunications capability&#8221; doesn&#8217;t refer to the Internet at all. It refers to &#8220;switched&#8221; (not packet-based) telecommunications services, like ISDN. How can the FCC claim regulatory power over the Net via a statute which doesn&#8217;t even apply to the Internet?</p>
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