Wednesday, November 3, 2010

On Elections ...

 Service makes humanity great.  It teaches us to rise above differences so that we can build something greater than rancor; it teaches us to respect considered differences in view or approach that our service may grow in wisdom; it teaches us to forgive that we remove from our eyes our brother's and sister's limits and thereby see the unlimited; it teaches us to have compassion for those who struggle because service of one uplifts all; it teaches us that the greatest wealth is not in receiving, but in giving.  There is no service without all of us.  Without service the wings of victory are bound in the ice of conflict & despair.  With service, victory knows no limits; we, the many, soar together.  We benefit, as one by the many, for the many and of the many.  When we serve us, we are won.  

Friday, May 21, 2010

Sea Change in Regulation (speed blogging under fire - I'm in litigation right now)

My email to Gordon Cook, who runs one of the most influential insider lists in communications space.  I'm usually fairly active, but dropped off for a bit because of pressures of work.  A good friend asked me to blog this so he could write about it.  So here you go:
From: Gordon Cook <>
Date: Thu, 20 May 2010 17:17:26 -0400
To: Economics of IP Networks
Subject: [Arch-econ] new FCC report on the entire mobile wireless ecosystem hat tip erik cecil
Erik Cecil asked me to take him off list about a week ago.  BUSY!

But today he sent me this material.  This document is a veritable BOOK -250 pages and nearly 1000 footnotes.

FCC dings wireless industry for having no competition - news report here:

300 page report here:

p.s. some of the key quotes from the FCC's Wireless Competition Report ...

"This Report also goes beyond previous reports in reflecting the transformative importance of mobile wireless broadband, which has resulted in a shift from devices that can place traditional phone calls to pocketable devices that can access the entire Internet. Because each of the interrelated segments of the mobile wireless ecosystem has the potential to affect competition, this Report analyzes competition across the entire mobile wireless ecosystem, including, for the first time, in-depth analyses of "upstream" and "downstream" market segments, such as infrastructure and devices."

"The two largest providers, AT&T, Inc. (AT&T) and Verizon Wireless, have 60 percent of both subscribers and revenue, and continue to gain share (accounting for 12.3 million net additions in 2008 and 14.1 million during 2009). The two next- largest providers, T-Mobile USA (T-Mobile) and Sprint Nextel Corp. (Sprint Nextel), had a combined 1.7 million net loss in subscribers during 2008 and gained 827,000 subscribers during 2009. One widely-used measure of industry concentration indicates that concentration has increased 32 percent since 2003 and 6.5 percent in the most recent year for which data is available."

"Especially as mobile wireless data usage grows, spectrum becomes an increasingly pivotal input. In particular, lower-frequency spectrum possesses superior propagation characteristics that create certain advantages in the provision of mobile wireless broadband service, especially in rural areas. Lower-frequency spectrum potentially allows for a higher quality of coverage with fewer cell sites, when compared to other frequency bands used to provide mobile services. Conversely, higher-frequency spectrum may be effective for increasing capacity, particularly within smaller, more densely-populated geographic areas. Recent auctions reflect that lower frequency bands are more highly valued than higher frequencies. A significant portion of spectrum below 1 GHz is held by the two largest providers: 67 percent of the 700 MHz band, and 91 percent of the Cellular band, based on megahertz-POPs (MHz-POPs).

"While the seven largest mobile wireless service providers all had EBITDA margins over 20 percent during the second quarter of 2009, only four - AT&T, MetroPCS, T-Mobile, and Verizon Wireless - had EBITDA margins greater than 30 percent, and the two largest providers had the highest EBITDA margins. In addition, these two providers had the highest EBITDA minus CAPEX per subscriber of the top four providers in 2007 and 2008."  VERIZON WIRELESS HAD 46.3% EBITDA MARGIN IN 2009!

Erik writes: Keep reading the report; it just keeps getting better.  I am thrilled; this is the best piece of work I've seen out of the FCC in more than a decade.   (my emphasis.... other emphasis is eriks) I don't know how or why the wake up call came, but finally, I think they get it.  (And this is good fact-based stuff, not to mention that for once in their existence they see the market as an inter-related whole.  The numbers tell the story we've discussed on list forever - the age of selling hand-held minute vending machines and set-top channel vending machines is over.)  What this country must do is move from subsidizing infrastructure via these older business model paradigms and shift to one where infrastructure is more directly subsidized while, at the same time, freeing ALL businesses to innovate as they please over the top of that.  The first step will be to fund the newest forms of business and technology; the second step will be to fund pure infrastructure.  The sooner we get out of minute wars and content wars, however, the better.  Even in an over the top world, however, regulation will still be required - mostly in the form of Title II-lite - i.e. real Title II, but zero state involvement in unnecessary details like minutes, local calling areas, and the arcana of bell monopoly-isms, with actual, direct, and meaningful antitrust enforcement where simple rules of the road are not enough to constrain bad behavior.  (all telecom, all 100% interstate; voice is interstate telephone exchange service; forbear from the ancient requirements, but apply things like 911, CALEA, etc. even-handedly across networks; eliminate rate arbitrage with a single unitary rate.)

What would be interesting on a going-forward basis is to see what comes out on the wireline side, then examine this, the wireline piece, and your work, and others like it, including the stuff that Tim, Paul and others have come up with to see if from all of that we cannot craft a single, sensible, integrated picture of how this Internet machine should work for the next 20 years or so.  If that were possible, I think that seeing whether your list - . . . . - could come up with some consensus policy recommendations would be very powerful indeed.

There are, b/t/w, more surprises coming.  Cycles of consolidation will roll on for another year or so before private equity (as well as last century's subsidized cash-rich behemoths) have little left to consume but themselves.  Nevertheless there is still a zeitgeist out there that says companies can acquire their way to profitability, which, if we were to continue the deregulatory course may be true - VZW did hit nearly 50% margin in 2009 - after swallowing up every wireless network AT&T didn't gobble up - still, that kind of money is a strong incentive. 
Provided this is truly a sea change, provided we have new thinking and not old thinking warmed over, provided the administration is seeing just how pissed off every day Americans are about politicians being too close to corporations (something I wrote about more than a year ago), then we're headed in a better direction.  Meanwhile, keep your eyes open; we're navigating some very difficult national and global waters, but at least, finally, it appears that the FCC has found its rudder and is actually steering the ship.

Well, back to work; I'm swamped.

Thursday, April 15, 2010

The Myth of the Myth of Title II Reclassification

Well, finally, the telecom name game hits the big time. Having cross examined no end of Bell company witnesses, I'll examine George Ou's apparently pro-ILEC spin by juxtaposing his apparent "analysis" against the whole of the Internet. (I say "pro-ILEC" (aka pro-Bellco) because it appears Digital Society is a half-way house for Progress and Freedom Foundation (who routinely supports "deregulation" of the AT&T and Verizon variety) judging by their personnel:

Ou takes issue with the proposition the FCC should regulate the transport components of the Internet in a short article entitled "The Myth of Title II `reclassification'". He refers to some FCC orders without naming them and then sets up and proves a straw man argument. Setting aside a certain lack of legal depth, his analysis also fails to account for industry history, evolution of the networks, interconnection arrangements (uh, across every platform - cable, wireless, wireline, satellite, and so on), tariffs, facilities, towers, or money behind them, much less the practicalities of actually running these business or litigating the cases he seems to cite with such confidence. Rather than dive into briefing this - b/c thorough treatment would require briefing, why don't we just examine the facts. Secondly, he was a network engineer, now reporter, not a lawyer. So to keep this fair, I'll take off my lawyer hat - and go right into the deep end of the network stuff to illustrate how, on the facts alone, this kind of reasoning is ludicrous.

First, let's not get lost in the name game:

If we run it to the lowest common denominator – the signals travelling across coaxial cable, hybrid coax, copper, fiber optic, TDM, mobile wireless, fixed wireless, handsets of every stripe, CDMA, GSM, LTE, 4G, satellite, class V switches, class VI switches, cable head ends, CDNs, etc. – we know that electronic communications networks – however labeled (Internet, Public Switched Network, cable, broadcast, etc.) involve people using computers to communicate with each other. Computers process "information". Information, to a computer, exists in one of two states: on or off. Your 2 gigahertz computer processor, for example, is a switch that essentially turns on or off 2 billion times per second. So it all boils down to 010010001010100101010101010s (and programming and money, but hey, let's see what's really going on underneath the name game).

Setting aside gaping holes in the applicable legal history, which, again, we don't need to address here as the facts, I think, are delicious, let's just see how that plays out against all of the "transport" and "information" distinctions the article asserts are so utterly clear.

  • Some of the 010101010110110101s are "transport" and some of the 010101011101010101101s are "information" because some of the 010111010010101s ride "on top of" some of the other 101010101011011s.
  • Some of the 010101011010101s are "out of band" but part of "telecommunications" (SS7 is an IP network), but not exempted from Title II, but not quite Title II either (some tariffed SS7, others didn't tariff SS7; no one could decide).
  • Others 0101010101s through the air and are "local" (and no subject to state regulation) more often than ones that go through copper or coax, which are also "local" but subject to state regulation (and pricing inputs that on average are 20x higher than those that apply when they go through the air). This only happens, however, when those 01010101011s are "voice"; if not, then other rules may (or may not) apply, as demonstrated with pellucid clarity below.
  • Yet other 01010101001010s are on copper or coax but are not telecommunications (because not only to they ride over, but are "combined with" some 1010101010101110101s beneath them that results in the copper being not regulated). But, if you happen to be a 10101010101010 that is associated with "voice", you are subject to regulation (under Title I), including but not limited to USF and 911, when your 101010101010s ride "over" other 101010101s that were already combined with the lower layer 1010000010101s that resulted in the deregulated copper in the first place. This is entirely different than the problem mentioned above where certain 0101010101s were subject or not subject to state regulation when they carried voice. In this case the 1010101s were in "IP" format. Above, they were in CDMA or GSM (or LTE or 4G) or TDM or DOCSIS, but not necessarily in IP, though they might have been IP at some point, however, so long as it was something other than IP at the endpoints, the rules cited above would apply, not the rules referenced in the 10010101s mentioned in this paragraph.
  • The preceding paragraph was probably confusing; I'll clarify: 00101010110011s that originate in a form of 01010101011s known as time division multiplexing, are converted to other 0101010s that are known as IP, then back to 10110101011s known as time division multiplexing are regulated. This would also more or less be true if CDMA or GSM were on both ends, but no one has really fought that legal battle because the financial rules that apply to 0101010101s carrying voice to your CDMA, GSM, 4G or LTE handset are subject to financial rules (known as "intercarrier compensation") that make it silly to fight over whether or not the 1010101s really actually truly "originated" and "terminated" in something other than IP. The real battle over 101010101110s that ride inside of 1010101010 formatting known as CDMA, GSM, 4G or LTE comes not for rating reasons, but because either the handset vendor (e.g. Apple) or the entity that provides the CDMA, GSM, 4G or LTE signal (wireless "carrier") wants to prevent you, consumer, from using the Internet to carry some of your 1010100101 voice signals via cheaper providers available on the Internet.

We're not done yet; it gets better:

  • Certain 1010100101s ride inside waves, but only in one direction. They are neither telecom nor information service because they carry video and go only in one direction.
  • Other 10101010101s ride inside waves, generally in one direction (subject to error checking). They are not broadcast, could be telecom but are information service as they are inside of fiber optic glass, carry video, but come from web servers not broadcast studios.

Secondly, let's just take one real world example:

Somehow the incumbents, and apparently Mr. Ou say Title II never applied to the "Internet". Well maybe ... they are hyper-technically correct. But, again, to avoid confusion, recall that certain special rules apply to certain 1010101s that carry voice information. Sometimes people use the Internet to communicate by voice. Sometimes they talk to other people who use computers to connect to the Internet. Sometimes, however, their friends are away from their computers. So they call the telephones. In that case 1010010101s go from a computer to other computers that "convert" the 10101010s from IP to other formats - whether TDM, CDMA, GSM, etc. In some cases the 101010101s from your computer will have other numbers associated with them - a telephone number - let's say you buy Vonage in Washington, DC (202 area code). You move to San Francisco (415 area code). You take your vonage phone with you. You call your grandmother, across the street. Your grandmother buys old fashioned telephone service from AT&T. You buy DSL service from AT&T. AT&T will charge the carrier who takes your 101010101s from the "Internet" (IP format) and converts those to 101010101s that can talk to it's old fashioned telephone switches (TDM format - this is old copper landline) "long distance" fees. But you can only charge "long distance" if you apply a tariff (tariffs are creatures of Title II) to that call.

The money in these charges is several tens of billions of dollars per year. AT&T, Qwest, Verizon, Windstream, Embarq now CenturyLink, etc. has sued all kinds of carriers who convert 1010101s from IP format to 01010101s in TDM format to connect with their old fashioned switches and won hundreds of millions of dollars. At the same time these carriers use IP in their backbones, deploy all sorts of IP-enabled gear, but use their old TDM operations as cash registers to clean out everyone but themselves. Go figure.

So of course Title II has never been applied to the Internet. "Reclassification is a myth." OK. Sure. Clear as day.

Fortunately for us, AT&T, Verizon, Qwest, Windstream, CenturyLink, and apparently the good people at Digital Society, want to keep the system just the way it is right now. Mmmmm. Glad the "free market" guys are completely in alignment with all of the "free market" incumbents who want to make sure that selective deregulation stays in place.

Thursday, April 8, 2010

Flapping my wings hard to keep up with Doc Searls

I've said in other places that Doc Searls is one of the best lawyers I know. Likely because he's a philosopher who simply had no need of legal pedagogy. He, like the sacred Crane, flies right over the top of the Himalayas while the rest of us, lawyers in particular argue over routes, fight over which guides will take us, or just dig right into solid rock cursing the difficulty of it all the entire time.

So I called him late the other night all excited that the FCC was finally waking up to the fact that the entire world had changed and perhaps it needed to catch up. Doc, which characteristic honesty, said, Erik, explain this. I hear you, but make it real. In other words, "use your wings man."

So here goes:

What we need to help the FCC realize that the world has already transitioned to the Internet (they call it "IP-enabled" b/c hey, lawyers like me make up ridiculous names for simple stuff) from the "circuit switched" world (remember those telephones you used when a kid? Well, the phones changed, but neither the network nor the regulation caught up; we've been stuck for a good 75 years in the same legal echo chamber).

Help the FCC. They can do it, We can Help.

We need to harmonize the legal and monetary systems under which all of it interconnects. That's the real issue.

Anything that is connected matters.

At the physical layer ther are all sorts of miles but sitting here on my couch with my blackberry dogs and kids asleep on a frigid colorado night, it is a zero distance technology anyone may use. (I wrote this last night on my blackberry to a list of industry insiders, academics, regulators, all all other sorts of Pirate Radio types.)

What they - anyone - lacks are the practical legal means of making a difference. It costs way too much to really impact innovation at the physical layer. We must reduce those costs. Regulation drives about 90 percent of the costs, but that doesn't mean no regulation. It means fix it. We, the People, must fix it. Remember, its about the Internet, not about someone else's product.

1. Federalize all interconnection rights across any modality.

2. Quit pretending there is loop, middle or long mile. There is just network. Only regulation makes these distinctions into insurmountable financial hurdles.

3. Get geography out of rates. The world is very flat. Get over it. Billing systems waste enormous money as do disputes. Intercarrier compensation (i.e. "access charges" - those per minute rates carriers attach to voice telephone calls) is a slush fund that washes out of consumer pockets right past network and into executive and shareholder pockets.

4. There is no longer any such thing as telecom, cable or broadcast except in regulatory silos gamed by business-driven technology models whose resulting incentives are to prevent and stall evolutionary change while nations like China make fools of our incessant fighting over who subsidizes which buggy whip.

5. Fund infrastructure. Fund
Ambient connectivity
(Bob Frankston's term). Interconnect every other layer when that layer is used for transmission. Balance market power with antitrust - real antitrust- and at every layer ...

6. Jurisdiction based upon endpoints is a bygone and irrelevant distinction for purposes of pure network regulation.

(This is the concept that says when you call across the street the call is "local" and when you call "long distance" it costs more. This is an illusion. The costs are below millionths of a penny per minute.)

The internet is infinite. There is no telling how many endpoints any data may or may not have, voice or otherwise over the course of time. If, however, bad things happen then deal with jurisdiction using known jurisdictional and venue tests. They are in the FRCP (Federal Rules of Civil Procedure) and every state's rules of civil procedure. International Shoe still works because poeple, not bits, not software do stuff. You never sue a hammer. You sue the person who did (or did not) do something with it. Same is true of connunication networks.

7. Regulate market power but focus first on taking the political power out of owning the physical infrastructure over which the market rides. Flatten it, make it the commodity it wants to be, and unleash real innovation. We will know we are there when there is no need for 20 DC think tanks to tell us life is great. We will know when you don't need a team of lawyers to launch a WiFi network, build and operate an open data-only cellphone, or do 10,000 other things we can do with technology were the law not a minefield for any innovator.

Simplify, unify, homogenize, commoditize and prosper.

Monday, April 5, 2010

If only Nero could have tweeted while Rome burned ...


Various academic and industry pundits paint the FCC as facing "very difficult" decisions when it comes to regulating broadband.  On one side they say the FCC faces the prospect of seeing the DC Circuit overturn its authority to impose quasi regulation under its "ancillary authority" (commonly referred to as "Title I" of the 1934 Communications Act (hereinafter the "Act")) or face World War III if it chooses to determine that "broadband", which is transmission of bits is transmission (known in the law as "telecommunications" - i.e. the transmission of information from one point to another without change).  (see, e.g.


Today the FCC regulates "broadband" in nearly every relevant respect, from imposing wire tapping and related requirements via CALEA, to enforcing basic principles of nondiscrimination (whether in post-hac form against "bad" cable actors, "bad" ILECs, or a pirori in the form of various policy statements and other tweets that say "play nice" - e.g. the 4 (now 6) freedoms, all of which boil down to the quintessential ingredient of common carriage - nondiscrimination), require interconnection (thus "interconnected VoIP"), and 911 (thus VoIP 911 orders), or require such non-telecommunications services to support USF --- for "telecommunications", or, even impose intercarrier compensation requirements (technically speaking upon the "telecommunications" component of the "information service").  Interestingly, every one of the requirements the FCC has or could ever seek to impose upon "broadband" exist in ... Title II of the Communications Act of 1934.


Recall from my analysis in the December 2009 issue of the Cook Report, the notion that indeed the idea that "broadband" was different from "telecommunications" boiled down to some rather arbitrary factual distinctions.  As applied the distinctions in and of themselves still exist, but their purpose - preservation of an open and free Internet - has long since evaporated.  Only entrenched interests who benefit from stasis are in favor of Net Neutrality or its cousin, the Broadband Plan.

So, rather than define transport for what it is, subject that to Title II and then define information service as something not transport (actual processing and change of information), the FCC is going to continue to vacillate forcing the Agency and hordes of industry lawyers to spend fortunes of taxpayer and private money money fighting in the courts and then begging Congress for authority to regulate that for which they already have authority to regulate: namely telecommunications, which is the movement of information from one place to another unchanged. 


Worse yet, applying Title II is not only NOT heavy handed, it is actually LIGHTER regulation than the alternative.  Here's why:

Because the FCC has been dodging the "regulation" question since 1996, it has been repeatedly reversed by federal courts for failure to get even the basics required by statutory law correct.  Worse yet, one carrier spent 5 years appealing this only to have the DC Circuit in late 2008 issue a rare if not unprecedented mandamus order - they ordered the FCC to get it right and apply the law - that certain Internet traffic is "telecommunications" subject to federal jurisdiction.  As a result of the FCC's repeated and continuing failure to regulate with any semblance of clarity, state agencies and state courts have attempted to but failed to regulate all sorts of broadband services.  These decisions have resulted in needless confusion, delay, and, in some cases, state level penalties so severe that competitive network providers have been forcibly driven out of the market (and their customers into incumbent's hands). Worse yet these very decisions have left incumbent monopoly services free of regulatory discipline.  This has resulted in extensive court battles, the most recent of which came out of the DC Circuit today.  In that decision, the court determined that the FCC simply did not have authority to claim plenary authority over an entire class of Internet service providers under Title I (ancillary authority) of the Act.  (Comcast v. FCC, No. 08-1291, Fed. Ct. App. DC Cir. April 6, 2010).

Were the FCC to deem "broadband" to be a telecommunications service, however, they'd end these battles and free up all sorts of resources going into more legal battles to actually put money in the ground.

While Verizon's and AT&T's positions have been clear for a long time, most in the industry are still scratching their heads at Google's decision to back Verizon's version of Net Neutrality.


The FCC has authority under Title II of the Act to deem "broadband" (which in nearly every case is carriage of bits in Internet Protocol packets over the top of some transport layer service whether DWDM, SONET, GigE, Frame Relay, pure TDM, etc.) to be interstate telecommunications.  Bingo!  Right there they've lowered the regulatory burden by a factor of 50x because they've just removed 50 state regulatory agencies from the mix.   Secondly, they can deem such a Title II service to be competitive and subject to "light" regulation, not unlike how interstate interchange services are regulated today.   Thirdly, all of the regulatory requirements that the FCC continues to attempt to apply to voice and video services via Title II of the Act, would readily and immediately attach to broadband.  

5.  If only Nero tweeted while Rome burned ... 

So we could do this right.  We could have clarity, certainty, predictability, and finally, a chance to innovate rather than litigate.  The FCC could deem transport to be telecommunications, whether bits move across coper, coax, fiber optic, or radio spectrum (wireless, WiFi, WiMax) to your iPad, iPod, iPhone, Verizon or AT&T wireless "mobile hot spot" or some other device or service.

Or, the FCC could continue to refuse to define "broadband", pretend that there is such a thing as "net neutrality" while the networks that form the Internet's foundations burn up cash, resources, innovation and time fighting over whether the FCC has "ancillary authority" to impose upon "Title I" services requirements it already exports from Title II to "quasi regulate" under "ancillary authority" in Title I.  In other words, if the FCC seriously engages in an attempt to enforce Net Neutrality they will be fighting in the courts and in Congress for the right to pretend to "lightly" "regulate" that not only which they already regulate by exporting from Title II to Title I all sorts of standards today, but which they have the full authority to clearly and consistently regulate under the law as it exists today.   

If only Nero could have Tweeted while Rome burned.

Friday, March 12, 2010

Some quick thoughts on Broadband

People pay for intelligence.  Thing is, it grows all the time.  Used to be intelligence was very close to pipe and device.  It made sense to build regulatory models and business models around the two.  Intelligence these days, however is in 2 places: (a) software - how well does software get you what you want when you want it where you want it and for how much; and (b) a niche, but cool devices that make good use of (a), are very desirable from a consumer perspective (I for one, love my new iMac; 21" screen, terabyte hard drive and smokin' fast apple RAM), not to mention it is a work of art, sitting on my desktop.  I love it and was happy to pay top dollar for it.

So it is simple.  You can have customers lining up around the block to pay for intelligence or you can go to war with them by trying to keep it out of their hands.  One feels like surfing and the other feels like battling a tsunami with swords.  

The outcome it seems to me is certain.  The transition, however, remains in doubt.

Let us hope for superhuman perspicacity for those charged with making decisions critical to how the transition plays out.

Thursday, February 11, 2010

Google: Build fiber optic infrastructure, but do it right.

Google has announced they are building out fiber optic infrastructure.  This is a tremendous opportunity, but there are dangers.  Having spent careers helping competitive landline, wireless, cable, Internet backbones, and even satellite-based communications companies enable the best of what the Internet brings to us, I can tell you this is one of the single biggest opportunities to transform a moribund American telecommunications market & infrastructure into a vibrant engine of economic change. 

This is a detailed proposal.  It is a "how to" manual.  

Remember, the true purpose of communications networks, of the Internet, is to serve.  There are communities in this nation who are suffering badly.  If Google is motivated by compassion and guided by wisdom, the success of their venture is assured.

First, do not build triple play.  Build something new.  Start at the very base of the model.  When you do, the doubling rate will be incredible.  Ensure that you work closely with the city, understanding their infrastructure, ensuring that you don't go out and build triple play.  That would be an idiotic waste of time and money.  Be smart, build the new recipe.  Do it from the ground up.  Think creatively.  Use fiber optic for street light control (this gets you to both sides of every major intersection.  Slap cabinets up on schools and city buildings.   Build out to the emergency locations, to the PSAPs (and there are some legal issues that need to be though through there, but again, doable), run a wireless network, connect health care, libraries, but do the same for auto shops and bakeries.   Think of fiber optic not as telecom, but as a new sort of societal building block.  Think of it as an input.   Think of it as fertile soil.  Spread it around.  Do NOT hoard it.  Give it away as much as you possibly can.

Secondly, build smart.  Loma Linda, as Chris mentioned somewhere, but as many of us - Doc, JP, John, etc. saw with our own eyes was incredible.  It was among the smartest community builds I've seen anywhere.  I think one of the reasons is that when they built they really deeply understood communications networks; they really weren't interested in triple play as the primary achievement of the build.  

Third, and one of the harder jobs, is putting the legal infrastructures in place in ways that benefit everyone.  This requires deep thinking at a network, operational, billing, business and legal level.  This is where the cake is unbaked and rebaked.  If there is any one place where expenses explode and impasse met, it is here.  So long as no one gets too religious - and it will be incumbent upon Google to be the least religious and the most humble if what they want is success AND harmony - there are ways of creating peace.  What people forget is that every carrier - landline incumbent, mobile wireless, CLEC (what's left of them), rural, independent (think Windstream / CenturyLink), cable (Comcast, Cox, etc. - I've done their interconnection work too) - all are interconnected today. They find ways to get along.  I can say from experience that it is harder when you have to connect ALL of them, but it is doable.  Just drop the religion and think creatively.   

Fourth, provided the foregoing are done, Google could light that network and have it ad supported.  If they are smart, if they avoid all of the traps of copper/coax thinking, they can avoid giant cost items that are sinking most of these business models day over day.  If they deploy as infrastructure where they have community support, the actual cost will be suprisingly lower than most pundits say is possible (too many people stay stuck in the wrong framing; they are victims of their assumption sets and end up repeating assumption and proof again and again without ever freeing themselves from assumption).  This is the core economic value.   

If they get the recipe right, the value will be unlimited.  The only real question is first of courage, and then intelligence.  It takes courage to bake a new cake.  It takes deep intelligence (and humility) to perceive the only way to truly serve American communities in need is to start from scratch.  People are hurting.  The economy still sucks.  Google, with real courage, could transform communities and transform people's lives. Can anyone imagine a higher calling or more worthy pursuit?  

I'll pray for their courage.  Head bowed, I will pray.  Real people are suffering.  They need help.  Do it right, not for the money, not for the policy, not for the politics, not for the economic or intellectual ideals of it.  Do it right because some kid's mother needs a job, because some kid's father has nowhere to look, nowhere to go, is not employed by the government, doesn't have a tenured academic job, doesn't work for a think tank, is not a partner in a law firm, but is just a dad trying to make ends meet for his kids.  Do it right because it is our duty to serve each other.  

Do it right because what you really want is to go to bed at night with a full heart, not a full wallet.

Surse corde,