IP: : Comment on NPRM 02-33

[David Farber <dfarber () earthlink net>]

-----Original Message-----
From: "David S. Isenberg" <isen () isen com>
Date: Thu, 02 May 2002 16:13:48 
To: dave () farber net
Subject: Comment on NPRM 02-33

Dave,

This is the comment opposing FCC Notice of Proposed Rulemaking (NPRM) 02-33 that
I told you I'd write.  NPRM 02-33 threatens to turn back the network architecture 
clock to pre-Internet days.  Please distribute it via IP as soon as you can -- the 
deadline for comments is tomorrow, and I'd like as many IPers as possible to comment.

IPers -- You can read the original NPRM at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-02-42A1.doc
FCC comments should follow the form below.  Email them to the FCC's
Electronic Comment Filing System: ecfs () fcc gov.


ECFS - E-mail Filing
<PROCEEDING>    02-33
<DATE>          5/2/02
<NAME>          David S. Isenberg
<ADDRESS1>      112 Orchard Street
<ADDRESS2>
<CITY>          Cos Cob
<STATE> CT
<ZIP>           06807
<LAW-FIRM>      none
<ATTORNEY>      none
<DOCUMENT-TYPE>CO
<PHONE-NUMBER>  203-661-4798
<DESCRIPTION>  Email Comment
<CONTACT-EMAIL>isen () isen com
<TEXT> 
I am writing to oppose the reasoning behind NPRM 02-33, "Appropriate Framework for Broadband Access to the Internet 
over Wireline Facilities", because I am afraid that treating broadband Internet access as an information service (as 
proposed by NPRM 02-33) would deprive United States citizens of the single most important feature of the Internet that 
has made it such a runaway success over the last decade.

Let me introduce myself.  I have a Ph.D. in Biology from the California Institute of Technology, where I studied human 
speech.  I spent 12 years, 1985-1998, at AT&T Bell Labs, where I served as Distinguished Member of Technical Staff.  
Today, I make my living as an independent commentator on telecommunications.  While I serve on numerous advisory boards 
and have numerous clients, I am beholden to no commercial interests.  I am writing as a concerned citizen of the United 
States, and I am writing with hope that recent great advances in communications technology -- and, more importantly, in 
network architecture -- will become available to all.

In my understanding, "access" involves connecting my computer (and other digital communications devices) to the 
Internet.  "Information" is quite different -- information is in the ones and zeros that enter my computer to be 
processed by it.  Information can flow into my devices over a variety of "access" -- over a wire, over a cable, over an 
optical fiber, or through the air (either as radio-frequency energy, or as light-wave energy).  That is, the same 
sequence of ones and zeros can enter my computer by any of these access methods.  So to equate "access" with 
"information", as does NPRM 02-33, is simply incorrect.

It was not always so.  The telephone network was developed to deliver one kind of information -- the human voice.  It 
was engineered for voice, and it gave access to voice.  Everything else that it carried (e.g., touch tones, modem 
signals, signalling information to set up telephone calls) was either an exception, or an adjunct to voice telephony.  
The wire that came into the house could not be distinguished from the service it provided.  It was the same for 
television and radio -- each had its own dedicated infrastructure (be it a wire or a frequency band) to carry a 
specific type of information.

The great advance of the Internet was that its fundamental architecture separated "access" from "information".  Any one 
of the various forms of access to the Internet puts one in touch with an infinite array of information.  Furthermore, 
providers of this information (information service providers) do not own special infrastructure -- all they need is a 
server and any of the several methods of Internet access.  As a result, the Internet is wide-open to innovation, and we 
have applications and services like email, Web browsing (in all its manifestations), ecommerce, Internet telephony, 
streaming audio and video, chat and instant messaging.  

Not a single one of these information (and communications) services was brought to market by a telephone company or a 
television company or a cable operator or a broadcast radio network.  No, access is a fundamentally different business 
from "information service".  To equate "broadband access" and "information service" -- as NPRM 02-33 proposes -- would 
be a horrendous step backwards.

Without separation, "broadband access" as an "information service" is likely to resemble the failed Interactive TV 
experiments of the early 1990s.  TV-on-speed is not "the Internet" -- and vice versa.

David I
-------


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