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	<title>Comments on: George Ou &amp; Bret Swanson on Berkman Broadband Report</title>
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	<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/</link>
	<description>Keeping politicians&#039; hands off the Net &#38; everything else related to technology</description>
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		<title>By: HIREDGUN</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-65442</link>
		<dc:creator>HIREDGUN</dc:creator>
		<pubDate>Wed, 04 Nov 2009 05:37:37 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-65442</guid>
		<description>&lt;p&gt;The reality is that if you take out fibre deployments that haven&#039;t been made by (a) municipalities (Sweden, Holland), (b) consumer-owned energy trusts (Denmark), or made with (c) significant helping hands on both the supply and demand side (Korea), there&#039;s really not much commercial FTTH deployment outside the USA.  Yet non-commercial investments are not impacted by access pricing and access regulation like commercial investments are, so their presence in my view has zero relevance to assessing the efficacy of access pricing and access regulation policies.&lt;br&gt;&lt;br&gt;It seems very clear that some European countries have done better on penetration than the US, although here too it&#039;s not really clear that prices are always lower there.  But in terms of commercial fibre deployment, the US is far ahead of WesternEurope.  Indeed, in terms of all fibre deployment, the US is still far ahead of  Western Europe.  Even if we took the sum of FTTH plus FTTN plus DOCSIS 3.0 subscribers, the US would be ahead of Europe although data on some of this is missing.  These differences in penetration versus advanced services deployment are unlikely to be a function of just the regulatory variables, but they are consistent with what one would expect.&lt;br&gt;&lt;br&gt;I don&#039;t see how you can get around the fact that US telcos have made massive investments.  Particularly Verizon.  &lt;br&gt;&lt;br&gt;I found it troubling that Berkman don&#039;t even discuss pricing issues, because the moment you say &quot;open access&quot;, the next question is &quot;at what prices?&quot;.  Factors like option values and asymmetric risks that conventional TSLRIC pricing didn&#039;t handle well have been addressed in European regulatory settings, but I am not aware of any great solutions that have been achieved.  It seems like a really futile exercise in providing spurious precision.  Simply translating regulation from copper to fibre seems pretty weird, given the amount of attention these issues have received in Europe.&lt;br&gt;&lt;br&gt;Re: data, they say that looking at household penetration rates are inappropriate because one needs to account for business lines.  Well, actually counting business lines is one big issue.  My firm (in the UK) benefits from a shared 100 Mbps Ethernet service to our building; but we probably just get counted as one connection, because we are one customer for our vendor.  But prior to the recession, there were 110 of us, 100% of whom had our own Internet-enabled computers.  &lt;br&gt;&lt;br&gt;Spain has almost as many enterprise DSL connections as the US according to one source that I&#039;ve seen.  With 1/7th the population.  Shock, horror?  I think not.  The root cause of this is that enterprises in the US get their Internet access much more often via special access/dedicated access/T-1/DS-3.  Corporate data revenue per head of population in the US is much higher than in Spain.  &lt;br&gt;&lt;br&gt;The relevant metrics should be: proportion of households who have broadband access, proportion of employees that have broadband access at work, proportion of businesses that have broadband access, proportion of adults who have a 3G mobile connection (European mobile penetration numbers are massively inflated by counting inactive users and multiple SIM users).  In any case, the evidence that the US is &quot;failing&quot; on these counts is very thin.   &lt;br&gt;&lt;br&gt;Until the 1980s, the US was the clear leader in telecoms.  However if you look at data such as fibre route deployment, ISDN deployment, and digitalisation of exchanges, the US was behind several OECD nations in the 1990s.  Other countries opened up their markets, and smartened up their act.  They also began producing more IP-- e.g., innovation starting originating elsewhere.  In Finland, in Japan etc.  The world became much more level, because information technology enabled greater information flows.  This is the big reason that the US is not an absolute leader in telecoms, although its outcomes are actually quite good, especially in wireless.&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>The reality is that if you take out fibre deployments that haven&#39;t been made by (a) municipalities (Sweden, Holland), (b) consumer-owned energy trusts (Denmark), or made with (c) significant helping hands on both the supply and demand side (Korea), there&#39;s really not much commercial FTTH deployment outside the USA.  Yet non-commercial investments are not impacted by access pricing and access regulation like commercial investments are, so their presence in my view has zero relevance to assessing the efficacy of access pricing and access regulation policies.<br /><br />It seems very clear that some European countries have done better on penetration than the US, although here too it&#39;s not really clear that prices are always lower there.  But in terms of commercial fibre deployment, the US is far ahead of WesternEurope.  Indeed, in terms of all fibre deployment, the US is still far ahead of  Western Europe.  Even if we took the sum of FTTH plus FTTN plus DOCSIS 3.0 subscribers, the US would be ahead of Europe although data on some of this is missing.  These differences in penetration versus advanced services deployment are unlikely to be a function of just the regulatory variables, but they are consistent with what one would expect.<br /><br />I don&#39;t see how you can get around the fact that US telcos have made massive investments.  Particularly Verizon.  <br /><br />I found it troubling that Berkman don&#39;t even discuss pricing issues, because the moment you say &#8220;open access&#8221;, the next question is &#8220;at what prices?&#8221;.  Factors like option values and asymmetric risks that conventional TSLRIC pricing didn&#39;t handle well have been addressed in European regulatory settings, but I am not aware of any great solutions that have been achieved.  It seems like a really futile exercise in providing spurious precision.  Simply translating regulation from copper to fibre seems pretty weird, given the amount of attention these issues have received in Europe.<br /><br />Re: data, they say that looking at household penetration rates are inappropriate because one needs to account for business lines.  Well, actually counting business lines is one big issue.  My firm (in the UK) benefits from a shared 100 Mbps Ethernet service to our building; but we probably just get counted as one connection, because we are one customer for our vendor.  But prior to the recession, there were 110 of us, 100% of whom had our own Internet-enabled computers.  <br /><br />Spain has almost as many enterprise DSL connections as the US according to one source that I&#39;ve seen.  With 1/7th the population.  Shock, horror?  I think not.  The root cause of this is that enterprises in the US get their Internet access much more often via special access/dedicated access/T-1/DS-3.  Corporate data revenue per head of population in the US is much higher than in Spain.  <br /><br />The relevant metrics should be: proportion of households who have broadband access, proportion of employees that have broadband access at work, proportion of businesses that have broadband access, proportion of adults who have a 3G mobile connection (European mobile penetration numbers are massively inflated by counting inactive users and multiple SIM users).  In any case, the evidence that the US is &#8220;failing&#8221; on these counts is very thin.   <br /><br />Until the 1980s, the US was the clear leader in telecoms.  However if you look at data such as fibre route deployment, ISDN deployment, and digitalisation of exchanges, the US was behind several OECD nations in the 1990s.  Other countries opened up their markets, and smartened up their act.  They also began producing more IP&#8211; e.g., innovation starting originating elsewhere.  In Finland, in Japan etc.  The world became much more level, because information technology enabled greater information flows.  This is the big reason that the US is not an absolute leader in telecoms, although its outcomes are actually quite good, especially in wireless.</p>]]></content:encoded>
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		<title>By: HIREDGUN</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-63291</link>
		<dc:creator>HIREDGUN</dc:creator>
		<pubDate>Wed, 04 Nov 2009 01:37:37 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-63291</guid>
		<description>&lt;p&gt;The reality is that if you take out fibre deployments that haven&#039;t been made by (a) municipalities (Sweden, Holland), (b) consumer-owned energy trusts (Denmark), or made with (c) significant helping hands on both the supply and demand side (Korea), there&#039;s really not much commercial FTTH deployment outside the USA.  Yet non-commercial investments are not impacted by access pricing and access regulation like commercial investments are, so their presence in my view has zero relevance to assessing the efficacy of access pricing and access regulation policies.&lt;br&gt;&lt;br&gt;It seems very clear that some European countries have done better on penetration than the US, although here too it&#039;s not really clear that prices are always lower there.  But in terms of commercial fibre deployment, the US is far ahead of WesternEurope.  Indeed, in terms of all fibre deployment, the US is still far ahead of  Western Europe.  Even if we took the sum of FTTH plus FTTN plus DOCSIS 3.0 subscribers, the US would be ahead of Europe although data on some of this is missing.  These differences in penetration versus advanced services deployment are unlikely to be a function of just the regulatory variables, but they are consistent with what one would expect.&lt;br&gt;&lt;br&gt;I don&#039;t see how you can get around the fact that US telcos have made massive investments.  Particularly Verizon.  &lt;br&gt;&lt;br&gt;I found it troubling that Berkman don&#039;t even discuss pricing issues, because the moment you say &quot;open access&quot;, the next question is &quot;at what prices?&quot;.  Factors like option values and asymmetric risks that conventional TSLRIC pricing didn&#039;t handle well have been addressed in European regulatory settings, but I am not aware of any great solutions that have been achieved.  It seems like a really futile exercise in providing spurious precision.  Simply translating regulation from copper to fibre seems pretty weird, given the amount of attention these issues have received in Europe.&lt;br&gt;&lt;br&gt;Re: data, they say that looking at household penetration rates are inappropriate because one needs to account for business lines.  Well, actually counting business lines is one big issue.  My firm (in the UK) benefits from a shared 100 Mbps Ethernet service to our building; but we probably just get counted as one connection, because we are one customer for our vendor.  But prior to the recession, there were 110 of us, 100% of whom had our own Internet-enabled computers.  &lt;br&gt;&lt;br&gt;Spain has almost as many enterprise DSL connections as the US according to one source that I&#039;ve seen.  With 1/7th the population.  Shock, horror?  I think not.  The root cause of this is that enterprises in the US get their Internet access much more often via special access/dedicated access/T-1/DS-3.  Corporate data revenue per head of population in the US is much higher than in Spain.  &lt;br&gt;&lt;br&gt;The relevant metrics should be: proportion of households who have broadband access, proportion of employees that have broadband access at work, proportion of businesses that have broadband access, proportion of adults who have a 3G mobile connection (European mobile penetration numbers are massively inflated by counting inactive users and multiple SIM users).  In any case, the evidence that the US is &quot;failing&quot; on these counts is very thin.   &lt;br&gt;&lt;br&gt;Until the 1980s, the US was the clear leader in telecoms.  However if you look at data such as fibre route deployment, ISDN deployment, and digitalisation of exchanges, the US was behind several OECD nations in the 1990s.  Other countries opened up their markets, and smartened up their act.  They also began producing more IP-- e.g., innovation starting originating elsewhere.  In Finland, in Japan etc.  The world became much more level, because information technology enabled greater information flows.  This is the big reason that the US is not an absolute leader in telecoms, although its outcomes are actually quite good, especially in wireless.&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>The reality is that if you take out fibre deployments that haven&#39;t been made by (a) municipalities (Sweden, Holland), (b) consumer-owned energy trusts (Denmark), or made with (c) significant helping hands on both the supply and demand side (Korea), there&#39;s really not much commercial FTTH deployment outside the USA.  Yet non-commercial investments are not impacted by access pricing and access regulation like commercial investments are, so their presence in my view has zero relevance to assessing the efficacy of access pricing and access regulation policies.<br /><br />It seems very clear that some European countries have done better on penetration than the US, although here too it&#39;s not really clear that prices are always lower there.  But in terms of commercial fibre deployment, the US is far ahead of WesternEurope.  Indeed, in terms of all fibre deployment, the US is still far ahead of  Western Europe.  Even if we took the sum of FTTH plus FTTN plus DOCSIS 3.0 subscribers, the US would be ahead of Europe although data on some of this is missing.  These differences in penetration versus advanced services deployment are unlikely to be a function of just the regulatory variables, but they are consistent with what one would expect.<br /><br />I don&#39;t see how you can get around the fact that US telcos have made massive investments.  Particularly Verizon.  <br /><br />I found it troubling that Berkman don&#39;t even discuss pricing issues, because the moment you say &#8220;open access&#8221;, the next question is &#8220;at what prices?&#8221;.  Factors like option values and asymmetric risks that conventional TSLRIC pricing didn&#39;t handle well have been addressed in European regulatory settings, but I am not aware of any great solutions that have been achieved.  It seems like a really futile exercise in providing spurious precision.  Simply translating regulation from copper to fibre seems pretty weird, given the amount of attention these issues have received in Europe.<br /><br />Re: data, they say that looking at household penetration rates are inappropriate because one needs to account for business lines.  Well, actually counting business lines is one big issue.  My firm (in the UK) benefits from a shared 100 Mbps Ethernet service to our building; but we probably just get counted as one connection, because we are one customer for our vendor.  But prior to the recession, there were 110 of us, 100% of whom had our own Internet-enabled computers.  <br /><br />Spain has almost as many enterprise DSL connections as the US according to one source that I&#39;ve seen.  With 1/7th the population.  Shock, horror?  I think not.  The root cause of this is that enterprises in the US get their Internet access much more often via special access/dedicated access/T-1/DS-3.  Corporate data revenue per head of population in the US is much higher than in Spain.  <br /><br />The relevant metrics should be: proportion of households who have broadband access, proportion of employees that have broadband access at work, proportion of businesses that have broadband access, proportion of adults who have a 3G mobile connection (European mobile penetration numbers are massively inflated by counting inactive users and multiple SIM users).  In any case, the evidence that the US is &#8220;failing&#8221; on these counts is very thin.   <br /><br />Until the 1980s, the US was the clear leader in telecoms.  However if you look at data such as fibre route deployment, ISDN deployment, and digitalisation of exchanges, the US was behind several OECD nations in the 1990s.  Other countries opened up their markets, and smartened up their act.  They also began producing more IP&#8211; e.g., innovation starting originating elsewhere.  In Finland, in Japan etc.  The world became much more level, because information technology enabled greater information flows.  This is the big reason that the US is not an absolute leader in telecoms, although its outcomes are actually quite good, especially in wireless.</p>]]></content:encoded>
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		<title>By: billgoat</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-63030</link>
		<dc:creator>billgoat</dc:creator>
		<pubDate>Thu, 22 Oct 2009 03:07:29 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-63030</guid>
		<description>&lt;p&gt;Harold (or should I say Che)... I love the shirts actually.  Very funny, made me laugh out loud and am thinking about ordering one for friends -- although I&#039;d be supporting PK financially, and that gives me pause.&lt;br&gt;&lt;br&gt;Berkman is clearly advocating for structural  separation and for them to hide behind a supposedly objective report is disingenuous.  It was David Weinberger (also from Berkman) who in an op-ed a month ago said &quot;We could require access providers to open up their lines to other companies at profitable wholesale rates. Users would benefit from a newly competitive market. Or, we could legally separate those who provide access from those who provide content and services.&quot;  &lt;br&gt;&lt;a href=&quot;http://www.npr.org/templates/story/story.php?storyId=113038106&quot; rel=&quot;nofollow&quot;&gt;http://www.npr.org/templates/story/story.php?st...&lt;/a&gt;&lt;br&gt;&lt;br&gt;This op-ed was written and posted before Yochai&#039;s study was done.&lt;br&gt;&lt;br&gt;So, a reasonable skeptic could easily conclude that Yochai, Weinberger and the Berkman Utopians put together a &quot;study&quot; that supported their structural separation worldview and then loaded it up with data to support a conclusion they&#039;d obviously already reached.&lt;br&gt;&lt;br&gt;So yes... I think &quot;socialize&quot; is the appropriate phraseology here.  Instead of playing semantic games, have the courage of your convictions and own it.&lt;br&gt;&lt;br&gt;Now, having said all of that... I thoroughly enjoy reading your stuff and find you very intelligent and quite witty (although I obviously strenuously disagree with just about everything you write).... How&#039;s that for the velvet glove treatment?&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>Harold (or should I say Che)&#8230; I love the shirts actually.  Very funny, made me laugh out loud and am thinking about ordering one for friends &#8212; although I&#39;d be supporting PK financially, and that gives me pause.<br /><br />Berkman is clearly advocating for structural  separation and for them to hide behind a supposedly objective report is disingenuous.  It was David Weinberger (also from Berkman) who in an op-ed a month ago said &#8220;We could require access providers to open up their lines to other companies at profitable wholesale rates. Users would benefit from a newly competitive market. Or, we could legally separate those who provide access from those who provide content and services.&#8221;  <br /><a href="http://www.npr.org/templates/story/story.php?storyId=113038106" rel="nofollow">http://www.npr.org/templates/story/story.php?st&#8230;</a><br /><br />This op-ed was written and posted before Yochai&#39;s study was done.<br /><br />So, a reasonable skeptic could easily conclude that Yochai, Weinberger and the Berkman Utopians put together a &#8220;study&#8221; that supported their structural separation worldview and then loaded it up with data to support a conclusion they&#39;d obviously already reached.<br /><br />So yes&#8230; I think &#8220;socialize&#8221; is the appropriate phraseology here.  Instead of playing semantic games, have the courage of your convictions and own it.<br /><br />Now, having said all of that&#8230; I thoroughly enjoy reading your stuff and find you very intelligent and quite witty (although I obviously strenuously disagree with just about everything you write)&#8230;. How&#39;s that for the velvet glove treatment?</p>]]></content:encoded>
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		<title>By: mwendy</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-63024</link>
		<dc:creator>mwendy</dc:creator>
		<pubDate>Wed, 21 Oct 2009 17:26:04 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-63024</guid>
		<description>&lt;p&gt;I have a bigger question.  If the FCC used one of the RBOCs consultants to perform the agency&#039;s analysis function, wouldn&#039;t that raise some red flags.  Let&#039;s say, NERA writes this report instead - the choice of the author has likely predetermined the answer.  And, I think in this instance, we see the same.&lt;br&gt;&lt;br&gt;So, isn&#039;t this a waste of tax dollars - we knew when Berkman was chosen by the agency, that it would get this answer.  They could have $500-or-so Large as a result, and then just have Susan Crawford write the durned thing.&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>I have a bigger question.  If the FCC used one of the RBOCs consultants to perform the agency&#39;s analysis function, wouldn&#39;t that raise some red flags.  Let&#39;s say, NERA writes this report instead &#8211; the choice of the author has likely predetermined the answer.  And, I think in this instance, we see the same.<br /><br />So, isn&#39;t this a waste of tax dollars &#8211; we knew when Berkman was chosen by the agency, that it would get this answer.  They could have $500-or-so Large as a result, and then just have Susan Crawford write the durned thing.</p>]]></content:encoded>
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		<title>By: Harold Feld</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-63022</link>
		<dc:creator>Harold Feld</dc:creator>
		<pubDate>Wed, 21 Oct 2009 16:15:52 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-63022</guid>
		<description>&lt;p&gt;&quot;Socilaize.&quot; Oh please! Is this really the new buzzword.&lt;br&gt;&lt;br&gt;The Berkman folks did not cover the U.S. in the 1990s because that wasn&#039;t their mandate. They were asked by the FCC to do a specific thing: look at what other countries did and see how that worked out for them. This the Berkman folks did, extensively.&lt;br&gt;&lt;br&gt;You are certainly free to argue that it isn&#039;t a complete picture because of the sustainability issues -- although Japan and S. Korea have been at this long enough that we would have expected the sustainability issues to become more urgent. You can also make the case that unbundling did not work here, although I think the data for that points the other way. But it seems foolish to me to criticize Berkman for doing the job they were asked as if the failure to go and do an entirely separate report to support your objections was a failure of their initiative.&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>&#8220;Socilaize.&#8221; Oh please! Is this really the new buzzword.<br /><br />The Berkman folks did not cover the U.S. in the 1990s because that wasn&#39;t their mandate. They were asked by the FCC to do a specific thing: look at what other countries did and see how that worked out for them. This the Berkman folks did, extensively.<br /><br />You are certainly free to argue that it isn&#39;t a complete picture because of the sustainability issues &#8212; although Japan and S. Korea have been at this long enough that we would have expected the sustainability issues to become more urgent. You can also make the case that unbundling did not work here, although I think the data for that points the other way. But it seems foolish to me to criticize Berkman for doing the job they were asked as if the failure to go and do an entirely separate report to support your objections was a failure of their initiative.</p>]]></content:encoded>
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		<title>By: mwendy</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-63021</link>
		<dc:creator>mwendy</dc:creator>
		<pubDate>Wed, 21 Oct 2009 15:35:47 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-63021</guid>
		<description>&lt;p&gt;The Net Neuts are asking for Title 2-like subsidies for their content dissemination.  They want the network effect without taking the risk to build it themselves.  Is there an entitlement to a privately-created network effect, especially when no demonstrable harm has yet resulted from those who own that network effect?  No.&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>The Net Neuts are asking for Title 2-like subsidies for their content dissemination.  They want the network effect without taking the risk to build it themselves.  Is there an entitlement to a privately-created network effect, especially when no demonstrable harm has yet resulted from those who own that network effect?  No.</p>]]></content:encoded>
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		<title>By: sleeplesssueinstlouis</title>
		<link>http://techliberation.com/2009/10/21/george-ou-bret-swanson-on-berkman-broadband-report/comment-page-1/#comment-63016</link>
		<dc:creator>sleeplesssueinstlouis</dc:creator>
		<pubDate>Wed, 21 Oct 2009 09:35:54 +0000</pubDate>
		<guid isPermaLink="false">http://techliberation.com/?p=22771#comment-63016</guid>
		<description>&lt;p&gt;Why is Oboma so interested in Net Neutrality? Isn&#039;t there an important vote this week? Why has he set aside $76+ million for &quot;net neutrality&quot;? (Wasn&#039;t that money supposed to go to creating jobs!) Is net neutrality going to affect my emailing you in the middle of the night? I am suspect of anything the eighteen wheeler rushing down the hill with Obama&#039;s picture on it wants.&lt;/p&gt;
</description>
		<content:encoded><![CDATA[<p>Why is Oboma so interested in Net Neutrality? Isn&#39;t there an important vote this week? Why has he set aside $76+ million for &#8220;net neutrality&#8221;? (Wasn&#39;t that money supposed to go to creating jobs!) Is net neutrality going to affect my emailing you in the middle of the night? I am suspect of anything the eighteen wheeler rushing down the hill with Obama&#39;s picture on it wants.</p>]]></content:encoded>
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