[170071] in North American Network Operators' Group

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RE: Level 3 blames Internet slowdowns on Technica

daemon@ATHENA.MIT.EDU (Naslund, Steve)
Sun Mar 23 23:29:42 2014

From: "Naslund, Steve" <SNaslund@medline.com>
To: Frank Bulk <frnkblk@iname.com>
Date: Mon, 24 Mar 2014 03:29:17 +0000
In-Reply-To: <001c01cf4710$0441be60$0cc53b20$@iname.com>
Cc: "nanog@nanog.org" <nanog@nanog.org>
Errors-To: nanog-bounces+nanog.discuss=bloom-picayune.mit.edu@nanog.org

Correct,  there is competition to them including the local cable company (i=
f there is one).  You just cannot get competitive access to their infrastru=
cture.  You have to pay at least the full wholesale rate.  That tends to ma=
ke them the most cost effective choice for wireline services like DSL and l=
ocal T-1s and makes it impossible to sell facilities based POTS service in =
their area.  The idea was that they are at a competitive disadvantage becau=
se the cost of their infrastructure to serve these areas so they deserved s=
ome special consideration.  If these guys were put in a fully competitive s=
ituation that made them insolvent, who would step up to provide POTS servic=
e to grandma on the end of that five mile cable run out to the farm.  That =
was the thinking when the Telecom Act passed.

The RLEC are where a lot of your "universal access charges" go to help subs=
idize their buildouts.

My point was that there is some regulation in place that recognizes that in=
 some areas (actually a lot of the US in terms of square miles) it is just =
not cost effective to provide infrastructure in a fully competitive environ=
ment.  If you think you can make money just selling infrastructure without =
services, it might work in a major metro area but not in these areas.

Steven Naslund

-----Original Message-----
From: Frank Bulk [mailto:frnkblk@iname.com]=20
Sent: Sunday, March 23, 2014 10:21 PM
To: Naslund, Steve
Cc: nanog@nanog.org
Subject: RE: Level 3 blames Internet slowdowns on Technica

I think I understand what you're saying -- you believe that RLECs that don'=
t have to provide UNE's are exempt from competition.  I guess I don't see t=
he lack of that requirement meaning that there's no competition -- it just =
means that the kind of competition is different.

Frank

-----Original Message-----
From: Naslund, Steve [mailto:SNaslund@medline.com]
Sent: Sunday, March 23, 2014 10:16 PM
To: Frank Bulk
Cc: nanog@nanog.org
Subject: RE: Level 3 blames Internet slowdowns on Technica

Many rural LECs are not required to provide unbundled network elements.  As=
 a network provider you can resell their service but they are not required =
to provide unbundled elements necessary to compete against them as a facili=
ties based provider.  So, for example, in Alamo Tennessee or Northern Wisco=
nsin you can get a T-1 from a competitive carrier that resells their servic=
es but you cannot get competitive POTS service.  You can buy DSL service fr=
om anyone but they are reselling the RLECs DSL access services not just run=
ning on their cable pairs.  One of the biggest players that specializes in =
being a rural LEC is Frontier Communications.

Yes, there are wireless carriers and satellite providers but especially in =
rural areas they are not a real viable alternative for high speed data sinc=
e we know the characteristic of satellite service and WISPs have the same d=
ensity problem in providing service in rural areas.  It is hard for a WISP =
to be profitable when you only have a handful of customers per mile.  Same =
formula, low density, long distances, high infrastructure per customer cost=
 for the WISP.

Steven Naslund
Chicago IL

-----Original Message-----
From: Frank Bulk [mailto:frnkblk@iname.com]
Sent: Sunday, March 23, 2014 10:08 PM
To: Naslund, Steve
Cc: nanog@nanog.org
Subject: RE: Level 3 blames Internet slowdowns on Technica

Not sure which rural LECs are exempt from competition.  Some areas are effe=
ctively exempt from facilities-based (i.e. wireline) competition because it=
's unaffordable, without subsidy, to build a duplicate wireline infrastruct=
ure.  There are also wireless carriers and WISPs the compete against RLECs,=
 as well as satellite providers.  I'm not aware of any exclusivity.

Frank

-----Original Message-----
From: Naslund, Steve [mailto:SNaslund@medline.com]
Sent: Sunday, March 23, 2014 9:00 PM
To: Joe Greco
Cc: nanog@nanog.org
Subject: RE: Level 3 blames Internet slowdowns on Technica

<snip>

In a low density area you can never fund a build out which is where univers=
al access charges came from and the reason that rural LECs are exempt from =
competition.  In return for building a network that is not profitable easil=
y they get exclusive access to sell services on it to give them a chance.  =
Will your NRC be reasonable anywhere outside a major metro area?

<snip>

Steven Naslund
Chicago IL








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