RE: Level 3 blames Internet slowdowns on Technica

["Naslund, Steve" <SNaslund () medline com>]

Correct,  there is competition to them including the local cable company (if there is one).  You just cannot get 
competitive access to their infrastructure.  You have to pay at least the full wholesale rate.  That tends to make them 
the most cost effective choice for wireline services like DSL and local 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 because the cost of their 
infrastructure to serve these areas so they deserved some special consideration.  If these guys were put in a fully 
competitive situation that made them insolvent, who would step up to provide POTS service 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 subsidize 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 environment.  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] 
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 the 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 facilities based 
provider.  So, for example, in Alamo Tennessee or Northern Wisconsin you can get a T-1 from a competitive carrier that 
resells their services but you cannot get competitive POTS service.  You can buy DSL service from anyone but they are 
reselling the RLECs DSL access services not just running 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 since we know the characteristic of satellite service and WISPs have the same density 
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 effectively exempt from facilities-based (i.e. 
wireline) competition because it's unaffordable, without subsidy, to build a duplicate wireline infrastructure.  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 universal access charges came from and the reason 
that rural LECs are exempt from competition.  In return for building a network that is not profitable easily 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