Blair Levin's "broadband competition" fantasy

Achieving Bandwidth Abundance: The Three Policy Levers for Intensifying Broadband Competition | ISOC-DC: The trial and many errors of my own work have led me to believe in the following bottom line: that the highest priority for government broadband competition policy ought to be to lower input costs for adjacent market competition and network upgrades. Today I will make the case for that bottom line and illustrate where I think the greatest opportunity is; to create a virtuous cycle of upgraded mobile stimulating low-end broadband to upgrade, which in turn causes an upgrade of high-end broadband which, by using its assets to enter mobile, accelerates the need for mobile to accelerate its upgrade further.

Blair Levin, a Brookings Institution fellow who drafted the U.S. Federal Communications Commission's National Broadband Plan issued in 2010, somehow believes boosting mobile wireless "competition" to offer greater bandwidth will generate synergistic "competition" among landline premise Internet service providers and result in "bandwidth abundance." 

It's utter hogwash for the simple fact that telecommunications infrastructure -- regardless of whether it supports mobile or premise service -- is not a competitive market. Never has been and never will be due to high cost barriers to entry and uncertain return on investment as a mathematical expression in Levin's presentation illustrates. 

Levin's fantasy scenario would have us believe that if Verizon deploys next generation 5G mobile service, that would somehow spur Comcast or AT&T, for example, to upgrade and build out fiber to the premise (FTTP) infrastructure in areas where Verizon has rolled out 5G mobile. It's wishful economic sophistry. Levin offers no explanation as to how or why that would occur.

Hyper local view of Internet telecom infrastructure misguided, reinforces network access disparities

City Broadband Plans: One Vision, Four Markets, Four Issues | Benton Foundation: My message today is simple: every city needs its own broadband plan.

At one time, I would have agreed with this statement by Blair Levin, who wrote the 2010 U.S. "National Broadband Plan" while serving on the staff of the Federal Communications Commission. I even went as far as paraphrasing the late House Speaker Tip O'Neill by declaring "all broadband is local" on this blog.

I no longer hold that view. It's not just about "broadband" in a given municipality or as is more often the case, a particular neighborhood. Instead, the truly important issue is ubiquitous Internet telecommunications infrastructure in keeping with the FCC's recent reclassification of Internet service as a common carrier utility. And that infrastructure is fundamentally interstate -- much like the federally funded interstate highway system -- and global. In that regard, it's not directly comparable to the municipal and cooperative electric power systems created in the early 20th century that generated and distributed power consumed locally. The Internet is a telecommunications network that reaches far beyond the borders of a given city or town and whose true value is recognized by Metcalfe's Law, which holds a network increases in utility as more users are added to it. In short, it's all about the network and not "broadband" or discrete "gigabit cities."

The hyper-local focus on this essential infrastructure for the 21st century is well meaning and understandable in the absence of strong federal leadership and support. But it's also misguided and dangerous because it serves to reinforce incremental thinking and Internet infrastructure disparities that have plagued the nation for a generation. It's also unrealistic to expect local governments to shoulder the financial burden as they continue to deal with the adverse impacts of the 2008 economic downturn and are strapped to fix crumbling roads, schools, sewer and water infrastructure and fund enormous public pension obligations.

If it is to realize the full value of the Internet, the United States should instead adopt a bold, wholistic and robustly funded national Internet infrastructure initiative to bring fiber infrastructure to all homes, businesses and institutions.

New Homeowner Has To Sell House Because Of Comcast’s Incompetence, Lack Of Competition – Consumerist

New Homeowner Has To Sell House Because Of Comcast’s Incompetence, Lack Of Competition – Consumerist

A sad tale of a consumer jerked around by incumbents and misled by the U.S. government's "broadband map" -- a major and useless component of the Federal Communications Commission's 2010 "National Broadband Plan."

And the consumer might find it hard to sell his home since not having an Internet connection is increasingly becoming like living off the grid.

Let's hope the FCC's recent policy deeming Internet as a common carrier telecommunications service requiring providers to universally serve all premises can help avoid these kinds of unfortunate circumstances that leave consumers high and dry.

Broadband faces a fork in the road - Computerworld

Broadband faces a fork in the road - Computerworld: Experts who worked on the National Broadband Plan approved in 2010 recently warned that there is still a great need for connecting unserved homes, libraries and schools with even basic broadband at less than 4 Mbps. Most of these unconnected homes are in poor inner city neighborhoods and rural areas.

Not an unexpected outcome when a "plan" is essentially an aspirational expression rather than a concrete project plan to deploy Internet infrastructure. Also, it should be noted there are plenty of unconnected homes that aren't in inner city neighborhoods and rural areas. They can be found anywhere in the United States where residential density is non-contiguous, leaving gaps and pockets of homes redlined by incumbent telcos and cable companies.

The U.S. Needs A Federal-Aid Highway Act For Affordable Broadband -- Now - Forbes

The U.S. Needs A Federal-Aid Highway Act For Affordable Broadband -- Now - Forbes

Digital media veteran Gary Myer urges a massive Internet stimulus program that goes far beyond the $4.5 billion allocated for Internet infrastructure in the American Investment and Recovery Act of 2009.  (Most of that money went toward middle mile infrastructure that typically left residences and small businesses off the net).

Myer as well as some of the commentators on his Forbes piece point out getting fiber to every U.S. doorstep not only would create a lot of jobs since a large majority of the cost is labor.  It would also make the U.S. network more valuable since more would be connected to it, replacing the current dysfunctional, hodge podge of disparate legacy cable television and telephone company networks whose high cost business models fail outside of densely populated areas.

Myer also puts to rest the fanciful, wishful thinking that cell phone networks obviate the need for premises Internet connections.  Those networks are designed for lower bandwidth mobile voice and data and lack the capacity and reliability to serve as primary premises connections. Those bandwidth caps on mobile service exist for a reason.

Australians Without Broadband Call For Changes To NBN | Internet

Australians Without Broadband Call For Changes To NBN | Internet: Experts have blamed Telstra for failing to upgrade creaking infrastructure because the NBN will limit the return it can get on its investment. Meanwhile many of those without broadband face over three years on dialup or expensive and patchy wireless plans as they are not part of the early NBN rollout.

At least the Aussies can claim they have active construction underway to build fiber to the premise infrastructure -- albeit not fast enough for areas that must still rely on early 1990s era dial up over twisted copper pair and data capped mobile wireless service.  The United States does not: only the travesty of a "national broadband plan" that exists on paper only.  There, the wait to get off dial up may take even longer than for the folks down under unless American communities take the initiative to build their own community fiber networks.

Big Bandwidth Can Unlock a New Competitive Advantage - Blair Levin - Voices - AllThingsD

Big Bandwidth Can Unlock a New Competitive Advantage - Blair Levin - Voices - AllThingsD

I haven't always seen eye to eye with Blair Levin, lead author of the Federal Communications Commission's National Broadband Plan issued in 2010 shortly before he joined the Aspen Institute think tank that year.  However, the above linked opinion article by Levin recently published in All Things D includes a number of statements with which I heartily agree.

First, Levin seems to be abandoning his prior stance that the private sector alone must invest in the massive, multi-billion dollar build of the necessary telecommunications infrastructure America needs to be competitive in an information based economy.  Levin now shares my view that incumbent, investor owned incumbent providers aren't in a position to do so because of their need to pay large dividends in the case of telcos and service high debt loads in the case of cable companies. "When it comes to wireline access to the Internet, instead of discussing upgrades, we are discussing bandwidth caps, tiers and rising prices. Instead of witnessing investment for growth, we are witnessing harvesting for dividends," Levin observes.
 
Levin also appears to have had an epiphany on what premises telecommunications service should be capable of delivering. Two years ago, Levin advocated for the subsidization of infrastructure than could deliver the FCC's minimum throughput standard of 4 Mbs down and 1 Mbs up to nearly all premises by 2020.  Levin now advocates what Andrew Cohill and others have dubbed "big broadband" (I prefer Levin's term, "big bandwidth"), perhaps not surprisingly since Levin also recently founded Gig U, an organization that Levin writes will build "gigabit hubs in nearly a dozen communities across the country, as well as a project to bring a 25X+ upgrade to hundreds of communities in rural America."  As to the latter project, this is the first I've heard of it and will be watching closely since it is these communities and not the university towns prioritized by Gig U that have the greatest need, being effectively disconnected from the Internet and relegated to substandard dialup and satellite connections.

I also found myself in strong agreement with Levin's call for a massive attitudinal shift away from the current mindset of bandwidth poverty fostered by incumbent providers who want to create the impression that more bandwidth cannot be created and therefore must be rationed and assessed a price premium.  Levin instead calls for a  “psychology of bandwidth abundance:” 

This psychology is what has fueled the uniquely American spirit of experimentation and innovation — from the first wave of European immigrants to the post-World War II America that helped rebuild Europe and Asia and created our modern economy and unleashed huge new industries from transportation to telecommunications. Unfortunately, however, the current environment suggests that we aren’t building that foundation. International studies on wireline bandwidth use differ, but all suggest we are mid-tier at best, and declining. 

Lest anyone doubt that the United States stands at a policy crossroads when it comes to upgrading its outdated telecommunications infrastructure, Levin notes that "[f]or the first time since American ingenuity birthed the commercial Internet, we do not have a single national wireline provider with plans to deploy a better network. For most Americans, five years from now, the best network available to them will be the same network they have today."  Levin's absolutely right on this point.

Finally, Levin notes this dismal state of affairs where accessing the Internet in 2017 will for many Americans be much like it was three decades before is not inevitable.  Levin is correct when he suggests that we must find ways to lower the cost of building needed infrastructure rather than shrugging and claiming it is simply out of reach:

We can regain leadership by improving the math for wireline investment through policy choices that have the effect of lowering capital or operating expenses or by raising the potential revenues or competitive threat to incumbents or new entrants. We have done this before. In fact, every new communications network deployment or upgrade has been preceded by a policy change that had one or more of these impacts. 

Blair Levin perpetuates false distinction among IP-based services

Blair Levin, in another recent interview looking back on the U.S. National Broadband Plan he lead authored for the Federal Communications Commission before becoming an Aspen Institute fellow this summer, perpetuates a false distinction among Internet Protocol (IP)-based telecommunications services. IP-based services include Internet applications such as web browsing, email and e-commerce as well as Voice Over Internet Protocol (VOIP) and video, also known as Internet Protocol TV (IPTV).

In an interview with Marguerite Reardon of cnet news, Levin does so by differentiating VOIP and IPTV from Internet applications. Levin -- as do many incumbent legacy phone and cable companies -- continues to describe the latter as "broadband." That term was appropriate in the mid-1990s when "broadband" denoted a premium service offered by telephone companies over their single purpose, proprietary copper cable plants. But as fiber optic cable technology increasingly obsoletes metal wire for delivering multiple IP-based services, the term is no longer relevant.

Levin reinforces this artificial split by talking about "broadband adoption." That too was relevant in the 1990s when broadband was being offered as a premium service, requiring customers to sign up for or "adopt" it. Today, it no longer is when Internet applications, voice and video can be delivered to consumers over a single fiber "pipe."

Further reinforcing the bogus notion of "broadband adoption," Levin elaborates that "broadband" requires consumers to be literate whereas voice and video do not. Therefore, Levin implies, we first need to improve the literacy of Americans to drive "broadband adoption" before the nation revamps its outmoded telecom infrastructure with fiber. Here's what he told Reardon:

Even though there are a lot of low-income people who may not be able to afford multi-channel video (cable TV), there is still a high proportion of people subscribing to the service. And people are not leaving in huge numbers. The big difference between TV and broadband is that to watch TV, you don't have to be literate. The same is true of phone service. You don't need to be literate to use a cell phone, so penetration of those services is higher. But to use broadband for things, such as getting access to public services, health care, job training, etc., a basic level of literacy is necessary. It requires a skill set. And teaching people those skills is a serious effort. So price is a piece of it, but literacy and relevance are also aspects too.

This is so much sophistry. Moreover, even if one accepts Levin's false dichotomy between Internet applications on one hand and voice and video on the other, it would argue for a bigger push to deploy fiber optic telecom infrastructure since video requires the "fat pipe" bandwidth fiber can provide.

National Broadband Plan overly reliant on wireline, author says

Blair Levin, the Aspen Institute fellow who served as lead author of the U.S. Federal Communications Commission's National Broadband Plan before leaving the FCC this summer, told PCWorld last week the plan is flawed because it places too much emphasis on making landline Internet protocol-based telecommunications service accessible to all Americans.

"One of the problems we were running up against and that we should've been clearer about is that the conventional wisdom says the primary metric for measuring the validity or power of a national broadband plan is the speed of the wireline network to the most rural of residents," Levin is quoted as saying. "That way of looking at the problem is entirely wrong, is profoundly wrong -- almost every word in the sentence I just uttered is wrong. And we should've done a better job of explaining that."

If Levin could go back and rewrite the plan, landline and wireless technology would be framed synergistically, working in conjunction with each other to make a more complete telecommunications infrastructure that meets the National Broadband Plan's objective of expanding service availability to all Americans.

On this point, I agree with Levin. Until the last and middle miles of the U.S. telecommunications infrastructure can be fully upgraded to fiber, wireless has an important but interim role to play since it can be deployed more quickly than wireline plant. That's a very important consideration given that the FCC reported in late July that between 14 and 24 million Americans "still lack access to broadband, and the immediate prospects for deployment to them are bleak."

However, if Levin sees wireless connectivity as a replacement for fiber, I disagree. Wireless telecommunications is largely designed for mobile use and not to serve premises. Wireless also lacks fiber's ability to handle the exploding demand for bandwidth. There is no field-proven wireless technology that matches fiber's capacity to accommodate that growth.

As Tim Nulty, who believes fiber to the premises can pencil out even in rural areas, put it in a 2008 interview, fiber optic plant is to wireless as jumbo jets are to helicopters. "Think about 747s and helicopters,” Nulty told The Progressive magazine. “Helicopters are marvelous when they’re used for what they’re good at. But you don’t use them to fly thousands of people between Boston and Chicago. For that you need 747s.”

America's badly needed revamp of its telecommunications infrastructure should not be based on the expectation that wireless technology will overtake and render fiber wireline plant obsolete and cost ineffective. Hope is a good attitude, but does not a plan make.

FCC National Broadband Plan lacks sense of urgency

Senate Commerce Committee Chairman Jay Rockefeller (D-W.Va.) today gave voice to my own concern that the Federal Communications Commission's National Broadband Plan mandated by the American Recovery and Reinvestment Act of 2009 is more of a wish list than an action plan.

Particularly considering that according to an FCC estimate released when the plan was unveiled last month, 7 million U.S. homes are offline because they are located outside cable company footprints or unable to subscribe to DSL due to distance limitations. Last October, the Yankee Group estimated about 12 percent of U.S. households, including those in some major metropolitan areas, have no access to broadband service.

That's a big infrastructure problem reflecting the fact that the United States is easily a decade behind where it should be considering the rapid growth of the Internet and next generation, Internet-protocol based telecommunications.

Rockefeller's message to the FCC is a problem of this magnitude requires a sense of urgency to bridge the digital divide. I agree with him. As a representative of a state with sizable rural areas, Rockefeller wants the FCC to focus its plan on rural America where IP-based telecom infrastructure is the weakest and least developed.

I would include many metro areas as well, particularly neighborhoods where housing density and topography don't allow legacy wireline cable and telcos to profitably build out their systems. As I have stated repeatedly, the FCC's plan should help alternative entities such as nonprofit coops start up to rapidly construct this critical infrastructure where the legacy providers cannot afford to do so.

FCC's National Broadband Plan needs bottom up incentives to bridge last mile

America's telecommunications infrastructure is least complete along the so-called last mile (referred to by some as the "first mile") that bridges middle mile distribution backhaul to homes and businesses. The U.S. Federal Communications recognized this in a footnote in a chapter addressing broadband availability in its recently released National Broadband Plan, noting 7 million housing units lie outside cable company networks or more than approximately 11,000-12,000 feet from telco distribution equipment providing DSL service. Six million housing units lack access to terrestrial broadband capable of providing downloads at speeds the FCC minimally defines as broadband because they are situated more than 16,000 feet from the nearest DSLAM.

The FCC's plan sets a goal of providing at least 100 million homes access with download speeds of at least 100 Mbs per second and upload speeds of at least 50 Mbs per second by 2020. In an interim report released in September, the FCC estimated reaching the "100/100" goal would cost as much as $350 billion.

The "100/100" goal is laudable. But a more pressing infrastructure shortfall now mires millions in the early 1990s with dialup access or subpar satellite Internet access that's a national embarrassment that should only be offered in Alaska or the north woods of Maine. The FCC report estimates bridging that gap would require existing providers to spend $24 billion on upgraded and expanded infrastructure. Investor-owned legacy providers aren't going to spend that kind of money. So the FCC proposes remaking the Universal Service Fund and other programs designed to subsidize legacy voice telephone service in high cost areas into the Connect America Fund (CAF). Recognizing this would yield just $15.5 billion over the next decade, the FCC's plan also calls on Congress to appropriate additional subsidies of a "few billion dollars" annually over the next 2-3 years to accelerate construction of advanced telecommunications infrastructure.

The weakness of the FCC's plan is that it relies too much on investor-owned telco and cable providers already burdened with outdated, legacy wire plant and the inherent limitations of their for-profit business models. These providers must naturally place their proprietary business interests ahead of any national goal for transitioning the nation's currently outmoded telecommunications infrastructure to one that delivers a range of Internet-protocol based services via fiber over the last mile. Consider, for example, that neither of the nation's largest telcos are currently expanding their own plants to bring fiber to customer premises. AT&T has except for some greenfield developments chosen to build out fiber only to neighborhood nodes, relying on legacy copper wire connections to reach customers. Verizon recently called a halt to further expansion of its FiOS fiber to the premises plant.

While the FCC's plan urges Congress to boost funding of the Rural Utilities Service's Community Connect program intended to provide funding for broadband to communities that are otherwise unserved, it doesn't go far enough. Instead of largely relying legacy providers to build out advanced telecom infrastructure from the top down to reach the last mile, it really needs to provide incentives that work from the bottom up.

One that holds promise is giving home and small business owners tax breaks to build their own last mile fiber much like current tax law provides incentives for solar power generation equipment. Tax breaks for properties with fiber "tails" as they were described in a November 2008 paper issued by the New America Foundation would help local governments and telecom cooperatives build fiber infrastructure since the tax savings would make it easier for property owners to pay fees for connection costs or fund coop memberships. Building out broadband infrastructure is primarily a business model problem. Providing tax credits for fiber "tails" would provide impetus to urgently needed alternative business models for modernizing America's telecom infrastructure.

Alternative telecom business models urgently needed

Fundamentally, America's outmoded and incomplete telecommunications infrastructure isn't solely an infrastructure issue. Rather, it's a business model challenge caused by market failure that discourages the build out of this vital infrastructure to allow all homes and businesses access to the Internet protocol based telecommunications technology that is today's standard for Internet access, video and voice communications. 

As such, the market failure that has brought about the current travesty of the world's most advanced economy dotted with broadband black holes demands alternative business models to fill in the gaps. It also requires a paradigm shift in thinking away from the proprietary, investor owned telco and cable infrastructure that's based on a business model suited to the 20th century and not the 21st. Bob Frankston and Andrew Cohill of Design Nine note the 20th Century telecommunications business model provides services similar to other utilities such as water and electricity. The more you use, the more you pay. As Cohill puts it, it's about selling "bandwidth by the bucket." 

As Internet era dawned with dial up access in the early 1990s, telcos simply sold and billed Internet access like an additional voice calling feature. They have continued to do so with DSL and ISDN before it. In Cohill's view, this business model to use a military acronym is FUBAR. "This business model is fundamentally broken," Cohill declared in a recently issued white paper. "There is no way to fix it." Why? Because building advanced telecommunications infrastructure cannot pencil out for telcos and cable companies based on a business model of selling an incremental, usage-based menu of services over their proprietary cable plant. It simply doesn't generate enough revenue to be profitable. That's why they have adopted an ultra conservative posture when it comes to expanding their infrastructures, leaving millions of would be customers in their so-called "service areas" unable to access services they could otherwise sell to them. So conservative, in fact, that telcos and cable companies will parse a single road or street providing some residents and businesses with broadband access while their neighbors go without, making lack of broadband access a problem that occurs in non-rural as well as rural areas. 

As previously noted on this blog, the search term that brings the largest volume of visits is "my neighbor can get broadband but I can't." As U.S. policymakers are about to consider a framework for a national broadband plan to be issued this month by the Federal Communications Commission, Cohill has proposed an alternative business model that probably won't be in the FCC's plan but deserves to be. It calls for a public private partnership between regional and local governments and private sector Internet Service providers (ISPs). Local governments sell bonds to finance the construction of fiber optic-based infrastructure and then service the bond debt by selling access to ISPs. Federal and state government can help defray construction costs with grants and loans. Telecommunications infrastructure under Cohill's "Third Way" isn't owned by a telco or cable company but instead is public infrastructure like roads and highways.

In effect, Cohill and others who support this alternative business model propose the deprivatization of telecommunications infrastructure while retaining a private market of competitors who wish to sell various communication and entertainment services. It's called an "open access" network. Cohill"s "Third Way" provides a solution to those who believe more competition is needed for telecommunications services. Since telecommunications infrastructure is itself a natural monopoly due to the high cost of constructing it, an open access network puts in place the framework for a competitive market for telecommunications services sold to homes and businesses. Cohill argues that the United States can no longer wait for telcos and cable companies to build out their infrastructures -- and he's right. Moreover, he asserts, in a weak economy where business and job creation are desperately needed, retaining a failed business model of telco and cable owned infrastructure in areas that lack adequate broadband access is "disastrous" from an economic development perspective. 

Critics will likely argue that the open access model is too radical and hasn't been sufficiently tested in the real world to ensure it pencils out where a proprietary, investor owned closed network cannot. Cohill would point to three open access networks his company orchestrated in Virginia and Florida to show that it can. Given studies linking expanded broadband access with economic growth, the open access business model, regional and local governments should not look to solely the feds for solutions. Since they stand to benefit from increased per capita incomes (and by extension, higher tax revenues), they should take their telecommunications -- and their economic destinies -- into their own hands and explore this much needed alternative business model to the dysfunctional, failed market of the status quo. The current privately-owned telecommunications "ecosystem" as some in the FCC have termed it isn't sustainable and cannot be expected to accommodate the burgeoning growth of digital telecommunications services and the concomitant demand for bandwidth. New business models such as proposed by Cohill and others are urgently needed now.

Shifting telecom paradigm poses challenge as FCC crafts broadband plan

The U.S. Federal Communications Commission is drafting recommendations due to Congress in a little more than three month's time on a national policy to ensure universal broadband access.

It's no easy task. The reason? We're in the midst of a paradigm shift away from yesterday's proprietary, closed single purpose telephone and cable systems to an open Internet-based system that can deliver everything these systems provided and so much more.

In fact, yesterday's closed telco/cable paradigm is itself the major impediment to universal broadband because its business model cannot easily accommodate that goal. Subsidizing it to expand broadband access using old models designed to expand access to the basic telephone service of yesteryear isn't likely to accomplish the goal of universal broadband access. The subsidies will prove to be too little, too late (such as this legislative proposal to expand the Universal Service Fund to include broadband defined as the soon to be obsolete speed of 1.5 Mbs), unable to keep up with the rapid advance of IP-based applications and their accompanying demand for ever greater speeds and bandwidth. It's like like subsidizing mainframe computing and keypunch machines in a new distributed computing age of powerful servers and microcomputers.

It is therefore essential that the FCC think outside of the box of the legacy telco/cable duopoly and look to innovative approaches and alternative business models as it prepares its recommendations. At the top of the list should be locally owned and operated open access fiber to the premises infrastructure. Whether these systems are operated by local governments, cooperatives or public/private partnerships, they can be more rapidly deployed and are thus more likely to expediently meet the goal of expanding broadband access to all Americans while simultaneously providing protection against technological obsolescence.

Why the incumbents prefer a sub 1 MBs broadband standard

Some are scratching their heads at recent comments submitted by large telcos and cable companies to the Federal Communications Commission recommending that broadband be defined at speeds of under 1 Mbs in the national broadband plan the FCC is due to present to Congress by February.

Why would they set the bar so low, observers rightfully wonder, particularly since such a low standard is already becoming obsolete given the explosive growth in bandwidth demand and video content.

It's clearly incongruous that Comcast, for example, would urge the FCC define broadband at circa 1998 levels of 256 Kbs at the same time it rolls out its DOCSIS 3.0 software upgrade providing downloads of 50 Mbs and potentially higher. Or for Verizon to suggest broadband be deemed 768 Kbs down and 200 Kbs up (the current FCC definition of "basic" broadband service) when its own fiber to the premises offering, FiOS, offers throughput on a par with that of Comcast.

Here's the explanation: These sub 1 Mbs standards are based not on what the providers are technologically capable of delivering today but instead on their business models. They have built out their proprietary infrastructures to the extent these models allow while providing a reasonable return and dividends for their shareholders.

By advising the FCC to define broadband on such obsolete and arguably bogus terms, the providers are essentially telling the feds they aren't serious about the issue. It's a frivolous, throwaway position that summed up says "forget about any national broadband plan and leave us the hell alone." It's reminiscent of the scene in the 1980s film Tin Men where a car salesman asks a tin man played by Danny DeVito what he's willing to pay for a Cadillac and DeVito answers "Five dollars."

That stance is likely to lead to more complaints from top FCC brass that the FCC's call for input on a national broadband plan is producing self serving and unconstructive comment that doesn't provide any illumination or guidance.