[12014] in Commercialization & Privatization of the Internet

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Fwd: Short substantive EFF policy question

daemon@ATHENA.MIT.EDU (Bill Frezza (via RadioMail))
Mon May 2 11:22:14 1994

Date: Mon, 02 May 1994 06:47:22 PDT
From: Bill Frezza (via RadioMail) <frezza@radiomail.net>
Cc: farber@central.cis.upenn.edu, djw@eff.org, com-priv@psi.com,
        stahlman@radiomail.net, dbuck@world.std.com, ggilder@mcimail.com,
        gbolles@radiomail.net, rre-maintainers@weber.ucsd.edu,
        Sam_Boyle@mcimail.com, brodsky@radiomail.net
To: mech@eff.org

Stanton,

Two weeks ago you committed to provide an authoritative answer to a few 
basic questions submitted to the EFF on its envisioned funding mechanisms 
for ensuring Guaranteed Universal Service on the 'Information
SuperHighway'. To date, we have not heard from you or anyone else from 
the EFF that was copied on these questions.

Could it be that the EFF issued its Open Platform 2.0 policy without
thinking this through? Could it be that the EFF doesn't really want people 
to think about these issues as it pursues its ambitious fund raising
program?

The questions are repeated below for your convenience. Many of us would
still be interested in hearing your answers.

Regards,

Bill Frezza
frezza@radiomail.net

----- Forwarded Message

Date: 04-18-94  08:46:24
Subject: Short substantive EFF policy question
To: mech@eff.org, rre-maintainers@weber.ucsd.edu
Cc: gnu@toad.com, barlow@eff.org, farber@central.cis.upenn.edu, djw@eff.org, com-priv@psi.com, stahlman, dbuck@world.std.com, ggilder@mcimail.com, gbolles

..

Please provide a succinct official EFF response to the following questions.
(Other EFF executives are welcome to pipe up.)

The EFF in Open Platform 2.0 has called for universal service guarantees for
the Information Superhighway <sic>. While stopping short of demanding
direct government subsidies, cross subsidization of service for the
information "have-nots" was demanded of vendors and carriers, financed
according to the folowing formula:

"The scope of these obligations should certainly be proportionate to 
the companies' market presence."

Please delineate SPECIFIC regulatory proposals that would embody this
principle. In doing so, answer the following questions. Include concrete
examples where appropriate:

1) What is "the market". Which communications media, products, 
and services are included? Which are not included? What is the criteria 
for inclusion? Who is responsible for defining and enforcing such criteria?

2) How do you measure "market 
presence". Who will do the measuring?

3) Describe specific criteria by which one qualifies as an information
"have-not" and thereby qualifies for the subsidy. Who will define this
criteria? How will this be monitored?

4) How will the subsidy be collected and distributed? Who will monitor
compliance? How does this differ from a tax?

5) What happens to a company that refuses to go along? Describe specific
enforcement penalties that might be used to ensure compliance.

6) What are the geographic limits of the mandate to provide universal
service? Who will set these? Who will grant exemptions in cases of 
financial infeasiblity?

7) Universal service guarantees have historically been linked to guaranteed
rate-of-return regulation and/or protection from competition via 
the granting of a government monopoly (eg,. POTS or a municipal cable TV
franchise). How will this be accomplished in a mutli-vendor
environment in which numerous wired, cabled, wireless, and satellite link
one-way and two-way local and long distance providers will all by busy
trying to bypass each other? If done by blanket rate regulation (eg., mandated
"lifeline" service rates) how would one determine the basis for "equivalence"
amongst the various modalities? Data rate? Throughput? Latency? Number of
"channels" (what's a channel?) Total traffic volume? All of the above?

7) Describe how this scheme can be accomplish without a massive government
regulatory intrusion into this business.

Thank you for your spirited advocacy on behalf of "the public".

Bill Frezza
frezza@radiomail.net





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