[12082] in Commercialization & Privatization of the Internet
Please stop obfuscating
daemon@ATHENA.MIT.EDU (Bill Frezza (via RadioMail))
Wed May 4 15:39:19 1994
Date: Wed, 04 May 1994 06:39:39 PDT
From: Bill Frezza (via RadioMail) <frezza@radiomail.net>
Cc: farber@central.cis.upenn.edu, 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, mech@eff.org
To: djw@eff.org
Dan,
Thank you the courtesy of you reply. It is getting rather tedious to listen
to the busy Mr. Stanton flame on for hundreds of kbytes without
providing any substantive answers. At least when you don't answer
my questions you do it succinctly and with charm.
You say you believe in principles. Wonderful, this means we have
something in common. The EFF has loudly proclaimed a high-minded policy
principle regarding Guaranteed Universal Access. The EFF has also
quietly slipped in an extremely murky and ominous policy principle
regarding how this was to be financed and by whom. These principles will
have consequences. I am not asking you to write voluminous legislation
(wouldn't it be nice if no one did) but surely you have given some thought
to the consequences of your policy principles.
As an exercise for yourself please answer the questions below. Even if
you refuse to publish your answers and continue to hide behind the
fuzzy notion that somehow the political process will magically provide
the benefits of Universal Access without attendant costs (economic,
social, and political) you will find it a worthwhile endeavor.
It might also be interesting to see if anyone else on this list would like
to take a try at answering these questions.
OK NOW, ONE MORE TIME ...
Please provide a succinct official EFF response to the following questions.
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