Subject: Lest We Forget Old Threads
John Schwartz (schwartz@usa.net)
Date: Tue, 11 Aug 1998 11:21:50 -0600
Message-Id: <3.0.3.32.19980811112150.007f3390@postoffice.att.net> Date: Tue, 11 Aug 1998 11:21:50 -0600 To: roundtable@cni.org From: John Schwartz <schwartz@usa.net> Subject: Lest We Forget Old Threads
I posted the following to roundtable on 7/3. Shortly thereafter,
Daniel del Solar posted a message saying he too was interested in an
answer from APT. To my knowledge, APT never responded (and, of course,
also had been dilatory in responding to prior questions).
I am losing track of the substance of the thread. But I don't think
I'll ever forget how APT has used roundtable to advance its positions,
yet failed to answer questions about them.
J.
_____________________________________________________________________________
John B. Schwartz
P.O. Box 6060 Telephone 303-442-2707
Boulder, CO 80306 FAX 303-442-6472
schwartz@usa.net
_____________________________________________________________________________
----- message forwarded from July 3, 1998 -----
>
> Maureen Lewis <mlewis@apt.org> posted the following reply written by Don
> Vial, APT's policy chair. I exerpt:
> >
> > "Your selective questioning of APT's recommendations to remove
> > barriers to advanced telecommunications infrastructure, such as ADSL,
> > has us somewhat puzzeled as our recommendations to remove those
> > barriers appear to be read by you in splended isolation of our
> > recommendations (p.28-41 of filing) to promote pro-actively
> > infrastructure investments for advanced capablilities, partilcular
> > to bring marginalized communities into the orbit of the digital age.
>
> Please keep in mind that my questions were in response to Maureen
> Lewis's posting of a summary of the APT's position. I do not pretend
> to have a full knowledge of APT's filings. One reason I value the
> roundtable list is that I often gain insights without having to plow
> through hundreds of pages of pleadings. I imagine that such also may
> have been part of Maureen's motive in making the posting.
>
> My questions were interspersed with portions of Maureen's message.
> Maureen's exposition contained elements that did not -- and do not --
> make sense to me.
>
> Don's reply was a good general account of a quandary in
> telecommunications regulation. If one opens telephone/telecom markets
> to competition, competitors will first try to "cream skim" the most
> attractive submarkets -- generally businesses customers in dense areas.
> CLECs are indeed unlikely to address the needs of low income
> communities. Yet ILECs without competition are horrendously inefficient
> and unresponsive, so it is difficult to argue that they should remain
> insulated from competitors.
>
> Apparently, the APT choice is to incent incumbents. I have doubts about
> this approach, but, even if one endourses it, one has to maintain close
> connections between the incentives offered and the results anticipated.
> (Monopoly incentives without results is a pretty terrible combination.)
>
> In his reply Don answered my question about colocation. But he did not
> address the other two questions I posed. While he may believe that
> these items have been taken out of context, they are APT's positions
> unless Maureen erred---and they are issues APT needs to confront. I
> repeat the unanswered questions below (for the fourth time).
>
> Taken from Maureen's posting:
> > >
> > > Suggestions about limiting Sec. 251 unbundling requirements relate
> > > solely to widely available elements like switches and transport and
> > > exclude the loop. APT Pet. at 20.
>
> Taken from my reply:
> >
> > Is it APT's view that such unbundling inhibits investment? If so, the
> > logic is not immediately obvious to me. If not, what is the rationale
> > for imposing such limits?
>
> My further observation: How does the limiting of unbundling assist low
> income communities?
>
> Maureen:
> > >
> > > --RBOC entry into long distance is not raised in these filings. The
> > > petition does, however, recognize that Sec. 10 of Telecom Act requires
> > > full implementation of Secs. 271 and 251 before FCC can forbear
> > > enforcement of 251(c).
>
> My reply:
> >
> > This appears circular to me. If Section 251 is implemented initially,
> > and then the FCC forbears from enforcing 251(c), and then ILECs cease
> > to comply with 251(c), the process of opening ILEC networks will be
> > frustrated.
>
> My further questions: do you agree that there is the potential to
> frustrate the opening of ILEC networks in this manner? If not, why not?
> If yes, what is the corresponding benefit to low income communities (or
> anyone else)?
>
> In conclusion, I do not like becoming strident over roundtable, as I
> recently did. But neither do I like it when it appears that APT is willing
> to promote its positions, but not answer questions about them. I hope I
> will not have to make three more postings before I get a responsive reply
> to the above.
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