Triennial Treatment of ISPs.

[Dave Farber <dave () farber net>]

> From: Bruce Kushnick <bruce () NEWNETWORKS COM>
> Subject: Triennial  Treatment of ISPs.
> To: CYBERTELECOM-L () LISTSERV AOL COM
>
> Here's why the Triennial Review is a terrible ruling ----
>
> "Internet Service Providers. While internet service providers (ISPs) are 
> only indirectly affected by our present actions, and ISPs are therefore 
> not formally included within this present FRFA, we have addressed them 
> informally to create a fuller record and to recognize their participation 
> in this proceeding."
>
> The FCC doesn't understand the role of ISPs or how lhe removal of line 
> sharing will harm broadband and hundreds of remaining ISPs. It makes a 
> totally ridiculous statement that the ISPs are only "indirectly affected 
> by the ruling --- Duh....
>
> The FCC has neglected to understand that ISPs were the connection between 
> the Internet and the Customer --- It was the ISPs who brought the US 
> Dialup and this group has been ignored by the FCC. The FCC doesn't 
> understand that customers call the ISP and wanted their service upgraded 
> to broadband. Instead, the FCC says --- Who needs ISPs, we'll let the 
> cable and telco be the ISP, the broadband provider, and who needs anyone 
> else?  In fact, the FCC has neglected to examine the ISP issues for years 
> and has helped in the collapse of this market. And now, instead of fixing 
> their mistakes, the FCC says "let them eat cake' and refuses to examine 
> the role of the ISP in the future of broadband.
>
> And how bad does it get? Teletruth will be doing a more formal description 
> of just how bad this ruling is in the next week. However, in our Comments 
> we spoke of ISPs, not simply the needs of "small business customers of 
> competitive LECs". It is clear that the FCC doesn't want to deal with ISPs 
> but would rather make some bland statement that doesn't address the issues 
> we raised -- and there are no proposed alternatives that will keep these 
> companies in business.
>
> "733. As an initial matter, we reject the contention that the Commission 
> failed to consider the needs of small business customers of competitive 
> LECs in fashioning the analysis set forth in this Order. We have grappled, 
> throughout this proceeding and throughout this Order, with the 
> consequences our determinations will have on all market participants, 
> including small business providers and the small business end users about 
> which TeleTruth, NFIB, SBA Advocacy, and Senator Talent express 
> concern.  We have also considered various alternatives to the rules we 
> adopt, and have stated the reasons for rejecting these alternative rules, 
> as commenters have urged. A summary of our analysis regarding small 
> business concerns, and of alternative rules that we considered in light of 
> those concerns, is presented in subsection"
>
> Line sharing has been 'transitioned out" meaning, who cares about the ISP 
> or their customers, or even the CLECs. The alternative the FCC has planned 
> for competitors is line-splitting, meaning that someone like Covad has to 
> also find another voice CLEC to partner with. The Bell doesn't have to 
> share their current voice line. --- So what's going to happen to the 
> hundreds of small ISPs who's customer just wants DSL.
>
> In  short, the FCC has left the ISPs in a no-man's land. It has stuck an 
> entire class of competitive telecom service providers  in a place where 
> they get thrown out of business because the FCC hasn't bothered to do 
> their job and  come up with workable alternatives.
>
> Bruce Kushnick, Teletruth

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