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Earl Comstock

Explore the evolving landscape of internet regulation, including FCC actions, net neutrality views, choke points, and potential future scenarios. Understand the implications for competition, consumer access, and content providers in the digital era.

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Earl Comstock

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  1. Earl Comstock President and CEO COMPTEL

  2. The World Has Changed • FCC adopts Cable Modem Order and Supreme Court upholds FCC in Brand X • FCC adopts Wireline Broadband Order • FCC allows Verizon Petition to take effect by operation of law • FCC has eliminated common carrier rules

  3. Common Carrier Regulation • Title II and Computer II regulation is what made the Internet possible • Service upon request, non-discrimination, interconnection and no control of content • Common carriers also get liability protection and tariff benefits

  4. Rules are Required • Cable, wireless, CLECs all depend on interconnection to provide service • Special access also is critical input for competition • Congress needs to adopt new law to overturn FCC actions

  5. Legislation May Favor Bells • The Bells have co-opted messages • “Don’t Regulate the Internet” • “Facilities Based Competition” • The result is Congress thinks no regulation is needed

  6. Net Neutrality FCC View • Four principles • Consumers can access lawful content • Consumers can attach devices • Consumers can run applications • Consumers are entitled to competition among providers

  7. Net Neutrality -- Neutral Net View • The FCC’s principles are too narrow • They don’t address rights of content and service providers • Key elements are missing -- interconnection, service upon request, attachment of devices, collocation for interconnection and caching • The FCC assumes common carriage, but has removed the legal obligation in its orders

  8. The Internet2 Vision of the Future Cable network CLEC network A B DSL to home 3 2 4 5 ILEC network 1 Fiber to home 1 and 5 are ILEC neighborhood nodes (fiber to DSL) 2 and 4 are ILEC central offices (local caching allowed) 3 is an interconnection point with the ILEC network A is the CLEC switch and B is the cable headend (both allow local caching) Public Internet with 1+ gigabit fiber to the home 100+ megabit on cable, and 20+ megabit on DSL Content provider Home

  9. Net Neutrality Choke Points in Red (note that NID at home is one too) Cable network CLEC network A B DSL to home 3 2 4 5 ILEC network 1 Fiber to home 1 and 5 are ILEC neighborhood nodes (fiber to DSL) 2 and 4 are ILEC central offices (local caching for ILEC only) 3 is an interconnection point with the ILEC network A is CLEC switch (local caching); B is cable headend (caching for cable only) ILEC “Fast” Internet Content provider Non-ILEC networks ILEC “public” Internet Home

  10. Internet2 Model ILEC Central Office Fiber Home Fiber ILEC Central Office Home DSLAM DSL All bandwidth available for transport of voice, video, and data. Customer pays for bandwidth and may access any content.

  11. Verizon model ILEC Central Office Fiber Home AT&T model Fiber ILEC Central Office Home DSLAM DSL In AT&T model ILEC fast Internet Is also used for ILEC video services ILEC cable channels ILEC Fast Internet ILEC “Public” Internet

  12. What Will the Future Bring • The key question is whether Congress will adopt the cable model or the common carrier model • Cable model means Bells win • Common carrier model preserves the Internet and competition

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