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URGENT ALERT: Broadband = "Information Service" Nonsense -- Comments Needed

From: Seth Johnson <seth.johnson@realmeasures.dyndns.org>
Date: Thu, 02 May 2002 18:26:59 -0400
Message-ID: <3CD1BD33.6DD24DD8@RealMeasures.dyndns.org>
To: C-FIT_Community@realmeasures.dyndns.org, C-FIT_Release_Community@realmeasures.dyndns.org, fairuse-discuss@mrbrklyn.com, cyber-rights@cpsr.org
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Sorry, but this is really late notice.  Tomorrow is the last
day for comments on the FCC's proposal to call the Internet
an "information service" for the entrenched broadband
interests.  Ostensibly, this decision is being made in
preference over classifying broadband internet as a
"communications medium," which would place it under
regulations like those phone companies are subject to.  It
is therefore being characterized as a decision for
deregulation versus regulation.

Anybody who can, PLEASE send in a note saying this is not a
question of whether regulation or deregulation is better
policy (this is just a smokescreen) -- it's a question of
the nature of the online medium:  Is it a "content" delivery
system, or a communications medium characterized by its
fundamental two-way protocols, one which brings profound new
capabilities to all citizens?

*Please* send even just a short note to the FCC at

If you know any other constituencies that would want to put
a word in on this, please let them know.

From Dave Farber's Interesting People list,

Seth Johnson

-------- Original Message --------
Subject: IP: : Comment on NPRM 02-33
Date: Thu, 2 May 2002 15:32:22 -0500
From: "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


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

FCC comments should follow the form below.  Email them to
the FCC's Electronic Comment Filing System: ecfs@fcc.gov.

ECFS - E-mail Filing
<DATE>		5/2/02
<NAME>		David S. Isenberg
<ADDRESS1>	112 Orchard Street
<CITY>		Cos Cob
<ZIP>		06807
<LAW-FIRM>	none
<PHONE-NUMBER>	203-661-4798
<DESCRIPTION>  Email Comment

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

************      WE HAVE MOVED!      ***************
New Snail-Mail Address, effective March 1, 2002:
112 Orchard Street
Cos Cob CT 06807
New phone: 203-661-4798
David S. Isenberg         isen@isen.com 
isen.com, inc.            888-isen-com (inside US) 
http://isen.com/          203-661-4798 (direct line) 
      -- The brains behind The Stupid Network -- 

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Received on Thursday, 2 May 2002 18:50:09 UTC

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