[2314] in Commercialization & Privatization of the Internet
FCC Video Dialtone
daemon@ATHENA.MIT.EDU (mnl@apple.com)
Thu Feb 6 21:42:53 1992
Date: Thu, 6 Feb 92 18:17:25 PST
To: com-priv@uu.psi.com
From: mnl@apple.com
The current FCC Video Dialtone inquiry has far broader implications than
the Cable-Telco debate. The commission has asked for comments on a wide
range of issues relating to the deployment of "of an efficient,
nationwide, publicly accessible advanced telecommunications
infrastructure," which facilitates robust competition and fosters a
diversity of information sources.
In our comments below, I have linked the inquiry directly to a number of
issues of considerable interest to com.priv readers and, indeed, the larger
Internet community.
Mike Liebhold
Media Architecture Research
Apple Computer, Inc.
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Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of )
) CC Docket No. 87-266
Telephone Company-Cable Television )
Cross-Ownership Rules )
To: The Commission
COMMENTS OF APPLE COMPUTER, INC.
The creation "of an efficient, nationwide, publicly accessible advanced
telecommunications infrastructure," which facilitates robust competition
and fosters a diversity of information sources, is not only a worthy goal
it is a national necessity. Apple Computer, Inc. ("Apple") commends the
Commission for taking the requisite steps to make this far-reaching vision
a reality. Apple supports the Commission's "video dialtone" proposal as a
practical means of developing a regulatory environment capable of
accommodating an increasingly complex mix of information industries,
technologies, and services.
In the comments that follow, Apple states that, as a prerequisite to
creation of the nationwide telecommunications infrastructure, there must be
a healthy commercial environment for services, in which carriers have
sufficient financial stake to induce them to construct the infrastructure
in the first place. Apple also believes that there are issues of
interconnection, interoperability, and data exchange between and among the
gateways on the first tier of the network, which should be addressed in
this proceeding, in addition to issues of fair and open access to the first
tier.
Moreover, given the expected profusion of gateways and services available
to the public at the first tier, provision should be made for having a
programmable digital interface to that tier using customer premise
equipment, i.e., a proprietary enhancement at the CPE level, to assist
consumers in navigating among the gateways. Finally, Apple commends to the
Commission's attention the system architecture and operating protocols of
the present Internet network, which is the federally-sponsored successor to
DARPA-NET and is used widely by both the public and private sectors for
correspondence and scientific exchange. Internet could well serve as a
model for, or even the nucleus of, the type of ubiquitous, advanced network
infrastructure that is the Commission's goal in this proceeding.
Access to Public Interest Services
The "video dialtone" concept, although excellent in large part, does not
automatically assure complete fulfillment of all of the Commission's stated
public interest goals. Economics and market mechanisms must sustain viable
communications, computing, information and media businesses. A reasonable
probability for economic success of these commercial communications
services is prerequisite, as an economic impetus, for local exchange
carriers to deploy high performance network infrastructures capable of
supporting such potentially desirable public interest services as: medical
and social services for the housebound, disabled and elderly; online
libraries offering titles of electronic books and journals, including high
resolution images and video; "home-work helper" multimedia curriculum
servers for children; and remote access to high performance computers and
scientific instruments for scientists and scholars.
In order for any video dialtone concept to provide an incentive for
provision of such educational, library, scientific and social services to
the general public, there must also be network traffic demands for
potentially popular services such as entertainment, video and games on
demand, video conferencing, and electronic shopping and transactions.
Without reliance on marketplace forces, consumers - as taxpayers - will be
called upon to subsidize separate facilities, such as an expanded Internet,
which currently serves educational and research institutions, in order to
build a communications network infrastructure for the most desired social
services.
While there is much to be gained by mixing commercial and public services
on one network, there are a number of issues associated with reliance on a
commercially-financed and supported network for all public interest
services. The Commission, for example, should inquire whether equitable
network access to services provided by hospitals, libraries, and schools
should be legally mandated for the first tier of video dialtone
directories. Is it reasonable or fair to assume that access to such
services and other public services be provided pro-bono by the network
provider? If there's a video dialtone, is there a need for a "video 911"
emergency service? Are market forces alone sufficient to insure the
provision of these public-interest services?
Interconnection, Interoperability, and Data Exchange Among Gateways
There are additional considerations associated with the Commission's
proposed requirement of "non-discriminatory access for program suppliers
and consumers" and that "local exchange carriers...will ultimately
determine the precise basic features and functions of they choose to offer
as part of the platform [i.e.,the first-tier of a two-tier gateway ], the
platform is likely to include basic directory and routing functions."
Local exchange providers are offering an increasing number and variety of
network points of presence at or near the customers' premises. Local and
long distance communications are increasing over such widely diverse media
as two-way cable television (co-axial and fiber ), switched copper-pair,
(eventually ISDN and perhaps ADSL), alternate local exchange carriers
[e.g., Metropolitan Fiber Services ], voice and data PCS, and, ultimately,
switched gigabit fiber and other high-capacity wireless channels. Private
business LANS are becoming bridged through intra and inter-LATA services
such as SMDS. Academic and scientific communities are becoming connected
to Internet at an accelerating pace. In this emerging environment, it is
easy to anticipate a profusion of first tier gateways.
In this regard, to what degree may the Commission's requirement for
"non-discriminatory access" be interpreted as assuring minimum requirements
for interconnection, interoperability and data exchange between and among
the various first tier gateways? Lack of such requirements could seriously
retard the success of new service and equipment enterprises within the
communications, computing, consumer electronics, information and media
industries.
First Tier Directory - An open, public and programmable digital interface.
By definition, first-tier, computer-based "video dial-up" directories could
grow to include millions of distinct listings of individuals, services,
institutions, enterprises, and other gateways. Searching unaided to find
any one listing on a vast, sequentially scrolling alphanumeric computer
network server will be extremely tedious, at best.
An open, public, and programmable digital interface to first tier listings
will assure continually improving access methods, such as those based on
computer graphics, digital video, speech recognition, and artificial
intelligence. Such an open interface would encourage the connection of a
rich variety of customer premise equipment, consumer electronics, and
computational devices and, therefore, contribute to the development of a
healthy U.S. electronics industry.
The Internet Backbone
As part of this proceeding, the Commission should consider the example and
experience of the Internet network, referred to above. Internet is fast
becoming the backbone of the global electronic mail system and even could
serve as the nucleus of the type of advanced network infrastructure that is
the Commission's goal in this proceeding.
Internet presently is almost ubiquitous among high-technology public and
private sector entities and institutions in the U.S. and abroad, but its
full services are not available to the public at large. Subscribers have
access to a "first tier" directory supported by a "first tier channel," on
which end user and file server addressing and routing update information
is circulated continually by regional address servers. Now, as a result of
the High Performance Computing and Communications Act of 1991, Pub. L. No.
194, 105 Stat. 1594 (1991), Internet is beginning to develop even greater
capabilities as a backbone research and educational network. Packet
traffic has been widely reported as growing at a rate of 20% per month.
It may well be that the Internet addressing and message delivery system
could develop sufficient critical momentum to serve as a central element (
if not the central element) in the foundation of a global network
infrastructure eventually capable of supporting the type of video dialtone
services envisioned by the Commission. If Internet were able to serve as
the nucleus of a broader, integrated public network infrastructure, the
Commission would have to address a set of issues that are converse to the
type of issues, noted above, regarding the use of commercial networks for
public service purposes.
For example, how should the government-supported academic networks treat
commercial packets? How should the costs of the networks be born
equitably? How should federal and state agencies deal with issues relating
to equitable billing for communications services? Which agencies have
jurisdiction to adjudicate such issues? Is legislation required to
establish such authority?
Conclusion
Apple does not claim to have the answers to the issues confronting the
Commission in this proceeding. Nor does Apple suggest that the public
interest necessarily mandates only a single model for the advanced networks
of the future. Apple believes, however, that the questions raised in these
comments should be considered in this important and far-reaching inquiry.
Respectfully submitted,
APPLE COMPUTER, INC.
By:
Michael Liebhold
Manager, Media Architectures
Research
Advanced Technology Group
20400 Stevens Creek Blvd., MS: 756J
Cupertino, California 95014
(408) 974-6025
February 3, 1992
Of Counsel
Goldberg & Spector
1229 19th Street, N.W.
Washington, D.C. 20036
(202) 429-4900
