Comcast Comments on FCC's Proposed Rules(corporate.comcast.com)
corporate.comcast.com
Comcast Comments on FCC's Proposed Rules
http://corporate.comcast.com/comcast-voices/comcast-comments-on-fccs-proposed-rules-to-protect-and-promote-the-open-internet
66 comments
I work for a company that is deeply rooted in the Energy sector in ND. The reason that rural areas in ND are getting access to fiber is because the oil/natural gas companies need it. Trust me it's not out of the kindest of their hearts. They have most of the Bakken shale covered. You can even tell that from the map.
The entire state is covered because the coops made a deal with the state and each other decades ago.
The communication co-ops have a responsibility to one group: Their co-op members. If they bitch, that's a really bad thing because then the state will start to scrutinize, and if that happens, their funding gets put in jeopardy.
The end result of that relationship is that it's in the best interests of the co-ops to keep their members extremely content. If you turn back time to the mid 90s, you will see that a lot of the state was offered DSL in a pretty timely manner despite being sparsely populated. Our communication services have always been at least a step or two ahead of the curve and priced pretty competitively even in places where there is literally no competition.
This isn't a result of the Bakken either. This has been an ongoing thing that has existed since the co-ops have been established. The system ends up working really well, and the irony is that in competitive areas, the service is generally worse and more expensive because the small co-ops don't have the cash to lay down the 9 figures of infrastructure it'd take to wire up all of Fargo.
The communication co-ops have a responsibility to one group: Their co-op members. If they bitch, that's a really bad thing because then the state will start to scrutinize, and if that happens, their funding gets put in jeopardy.
The end result of that relationship is that it's in the best interests of the co-ops to keep their members extremely content. If you turn back time to the mid 90s, you will see that a lot of the state was offered DSL in a pretty timely manner despite being sparsely populated. Our communication services have always been at least a step or two ahead of the curve and priced pretty competitively even in places where there is literally no competition.
This isn't a result of the Bakken either. This has been an ongoing thing that has existed since the co-ops have been established. The system ends up working really well, and the irony is that in competitive areas, the service is generally worse and more expensive because the small co-ops don't have the cash to lay down the 9 figures of infrastructure it'd take to wire up all of Fargo.
In the major metros Comcast has increased speeds regularly and also offers hundreds of wifi hotspots that customers can use. In many of these areas they also compete with Fios of course.
> Comcast has increased speeds
This is sort of a half truth. Comcast has increased some speeds a little bit. But most of those speed increases are lies.
For instance, Comcast claims it's moving to deliver 500mbps service ("half-gigabit") in this letter. You might assume this is meant to be comparable with Google Fiber and other local Fiber initiatives. It's not.
Google Fiber is $70/month. Most local gigabit providers are $50-$100/month. Comcast's "half fiber" is $400/month. (see http://www.comcast.com/505). Half the speed at 400+% higher cost.
This isn't competition, this is Comcast lying about availability. It lets them claim that they deliver fast service, but that "the market doesn't want it".
This is sort of a half truth. Comcast has increased some speeds a little bit. But most of those speed increases are lies.
For instance, Comcast claims it's moving to deliver 500mbps service ("half-gigabit") in this letter. You might assume this is meant to be comparable with Google Fiber and other local Fiber initiatives. It's not.
Google Fiber is $70/month. Most local gigabit providers are $50-$100/month. Comcast's "half fiber" is $400/month. (see http://www.comcast.com/505). Half the speed at 400+% higher cost.
This isn't competition, this is Comcast lying about availability. It lets them claim that they deliver fast service, but that "the market doesn't want it".
Google fiber does not provide universal access. Even in the communities they service they are very selective about which areas are included.
Lat time I checked Google was not an ISP for consumers. They do this to generate more competition against the ISPs forming a trust against competition.
Example:
"The Justice Department has reached out to the companies as it investigates whether the cable-industry merger (CMCSA:US) is anticompetitive, said the people, who asked not to be named because the review isn’t public."
http://www.businessweek.com/news/2014-07-11/disney-cbs-said-...
Thanks to Goole Comcast started to do higher speed internet, it was shocking to me how customers were not interested in it but right after the Google offering the very same customers went totally mad and they suddenly needed faster internet. Who understands these very complicated matters anyways?!?!
Example:
"The Justice Department has reached out to the companies as it investigates whether the cable-industry merger (CMCSA:US) is anticompetitive, said the people, who asked not to be named because the review isn’t public."
http://www.businessweek.com/news/2014-07-11/disney-cbs-said-...
Thanks to Goole Comcast started to do higher speed internet, it was shocking to me how customers were not interested in it but right after the Google offering the very same customers went totally mad and they suddenly needed faster internet. Who understands these very complicated matters anyways?!?!
[deleted](1)
OK, but talk is cheap. You offer 100Mb service* for $115/month. Google is offering 1Gb for less than that. My local ISPs that operate on just over $10,000,000 annually are offering double that for less than half the price to people that live in areas with population densities that'd rival the most desolate parts of Siberia.
Talk is cheap. Start actually doing something. Either offer copper at prices that can compete or better yet, put your money where your mouth is. If Comcast is worried that Title II is going to decentatvie infrastructure spending, prove me wrong and actually build out a fiber infrastructure while Title II isn't a thing. Use some of that 7 billion[1] a year you see in the black and start building some real infrastructure instead of just sitting on copper for as long as you possibly can.
*When it's convenient. God only knows how oversold Comcast's service is.
[1]http://en.wikipedia.org/wiki/Comcast
Talk is cheap. Start actually doing something. Either offer copper at prices that can compete or better yet, put your money where your mouth is. If Comcast is worried that Title II is going to decentatvie infrastructure spending, prove me wrong and actually build out a fiber infrastructure while Title II isn't a thing. Use some of that 7 billion[1] a year you see in the black and start building some real infrastructure instead of just sitting on copper for as long as you possibly can.
*When it's convenient. God only knows how oversold Comcast's service is.
[1]http://en.wikipedia.org/wiki/Comcast
Holding up Google as a reference point is really disingenuous. It's not clear Google is making any money on Google Fiber, and so far they've only decided to enter a few municipalities where they've refused to agree to the sorts of regulatory constraints that Comcast is subject to in those same places. There's a real question here: could Google keep shareholders happy if Fiber was a standalone business?
> There's a real question here: could Google keep shareholders happy if Fiber was a standalone business?
This right here is a really good reason why Internet service needs to be Title II'd.
If the primary concern surrounding what is now an incredibly vital piece of the communications infrastructure is, 'how do we keep shareholders happy', then our priorities are fucked.
This right here is a really good reason why Internet service needs to be Title II'd.
If the primary concern surrounding what is now an incredibly vital piece of the communications infrastructure is, 'how do we keep shareholders happy', then our priorities are fucked.
The primary concern of trucking and air transport concerns are also shareholder welfare. Should we nationalize transportation?
The same could also be said of just about every grocery store. Even small mom-and-pop stores (or perhaps especially them) are concerned with shareholder welfare, more so than "What will happen if Ted runs out of pickles this week?".
Regional pickle shortages probably aren't going to have the same effect on the economy as a nationwide trucking strike. :)
Well, food in general. It doesn't get much more basic need than food, but there's not much government regulation guaranteeing my right to buy food.
Or highways?
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Not really. Your question is reasonable, but the real point here is that Comcast is not remotely competitive with Google Fiber. If Google Fiber were a loss leader or otherwise levitated by Google, then this would be a disingenuous comparison. But we know that Fiber is not operated at a loss [http://gigaom.com/2012/07/26/the-economics-of-google-fiber-a...].
So it may be the most profitable part of Google's business, or it may earn as little as $0 profit, which is roughly what you'd expect in a perfectly competitive commodity market. In any case, we can clearly see that Comcast is not serving consumers as well as possible.
So it may be the most profitable part of Google's business, or it may earn as little as $0 profit, which is roughly what you'd expect in a perfectly competitive commodity market. In any case, we can clearly see that Comcast is not serving consumers as well as possible.
Having a profitability above zero doesn't mean much. Nobody is going to invest billions a year in a telecom network to not make any money on it. The fact that Google can do it in a handful of markets selected for their willingness to grant massive regulatory concessions,[1] doesn't meant that they could deliver that service at that price if they had to operate at the scale Comcast does, with the regulatory constraints Comcast is subject to, and with the need to please shareholders without leaning on cloud services synergy.
[1] This issue is important but underappreciated here on HN. Uptake rate is a key driver for the cost/benefit analysis of investing in telecom infrastructure. The cost of building out to a neighborhood dominates the cost term. So how many people in each neighborhood sign up has a huge impact on your per user cost. Google only builds out to fiberhoods with demonstrated interest. In most cities, Comcast is legally prevented from doing this.
[1] This issue is important but underappreciated here on HN. Uptake rate is a key driver for the cost/benefit analysis of investing in telecom infrastructure. The cost of building out to a neighborhood dominates the cost term. So how many people in each neighborhood sign up has a huge impact on your per user cost. Google only builds out to fiberhoods with demonstrated interest. In most cities, Comcast is legally prevented from doing this.
[deleted]
I'm reminded of some dialog from an old TV show. I think it was "I Love Lucy", but I'm not sure. It went something like this:
(Lucy is buying a pound of steak from the butcher shop. Note this was set in the 1950's, so food is considerably cheaper than it is now)
Butcher: that will be $0.85, please
Lucy: $0.85!? Bob's Butcher down the street sells steak for $0.55 per pound!
Butcher: then go buy your steak from Bob's.
Lucy: I would, but Bob's is out of steak.
Butcher: Lady, when I'm out of steak, I'll sell it for $0.50 per pound!
For all but less than a handful of places, Google Fiber is Bob's Butcher.
(Lucy is buying a pound of steak from the butcher shop. Note this was set in the 1950's, so food is considerably cheaper than it is now)
Butcher: that will be $0.85, please
Lucy: $0.85!? Bob's Butcher down the street sells steak for $0.55 per pound!
Butcher: then go buy your steak from Bob's.
Lucy: I would, but Bob's is out of steak.
Butcher: Lady, when I'm out of steak, I'll sell it for $0.50 per pound!
For all but less than a handful of places, Google Fiber is Bob's Butcher.
>In the major metros Comcast has increased speeds
They've certainly added higher tiers. I saw their 105mbps product was available in my neighborhood and called. The non-promotional price just for internet floats around $180 a month. That's a far cry from these municipal fiber shops that deliver that speed or higher AND television for less cost.
This is an easy way for ISPs to say to regulators, "Look we offered it but no one ordered it." Of course, no one wants to pay $180 for internet, especially when google fiber goes for $70 or so. I think their 400mbps product is around $400, which is insane.
They've certainly added higher tiers. I saw their 105mbps product was available in my neighborhood and called. The non-promotional price just for internet floats around $180 a month. That's a far cry from these municipal fiber shops that deliver that speed or higher AND television for less cost.
This is an easy way for ISPs to say to regulators, "Look we offered it but no one ordered it." Of course, no one wants to pay $180 for internet, especially when google fiber goes for $70 or so. I think their 400mbps product is around $400, which is insane.
Can't help but think you are a shill. This is obviously corpratized fluff, and you have only commented on two threads, both of which deal with Comcast.
[deleted]
You're obviously new on the job so I'll just tell you what your incompetent trainers should have taught you:
No human being not under the employ of Comcast know what Comcast is doing "in the major metros". People who use Comcast only know of their little neck of the woods, so when you go out to do your astroturfing campaign you need to make sure that you appear to be a real human being by talking about a specific location which you personally have experience with.
No human being not under the employ of Comcast know what Comcast is doing "in the major metros". People who use Comcast only know of their little neck of the woods, so when you go out to do your astroturfing campaign you need to make sure that you appear to be a real human being by talking about a specific location which you personally have experience with.
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Comcast, most cable companies have DOCSIS 3 infrastructure, and depending upon network layout can increase speed by merely "flipping a switch". They protect profits by metering bandwitdh to the minimum possible units, and they protect themselves from competition by offering better service only when competition arrives in a market.
[deleted]
I live outside of Nashville and they are now offering me 109mb for about $90 a month. My current speed has continued to increase as well, about 2 smaller MP3 songs per second.
In my neck of the woods is 105mbps for $90 as PROMOTIONAL pricing. The real price is almost twice that. Is $90 your real price?
Well I suppose it is a promotion, a 1 year deal for $90.
I smell an astroturf
Comcast is supporting having their competitors being bound by net neutrality. Comcast already is, due to the terms of the NBC merger. So they want their competitors to “suffer” similarly.
And they don’t want mobile to impinge on the fixed-line market, so they support NN in mobile, too.
A good analogy is WalMart supporting a minimum wage. They support it because it hurts their competitors (local Mom & Pops) more. [1]
Remember regulation isn’t “rules of the road”. It’s an input into a complex system.
[1] http://clipperhouse.com/2010/02/22/net-neutrality-and-preser...
And they don’t want mobile to impinge on the fixed-line market, so they support NN in mobile, too.
A good analogy is WalMart supporting a minimum wage. They support it because it hurts their competitors (local Mom & Pops) more. [1]
Remember regulation isn’t “rules of the road”. It’s an input into a complex system.
[1] http://clipperhouse.com/2010/02/22/net-neutrality-and-preser...
Comcast simultaneously claims that some of their own VoD services -- services delivered via your cable modem, through your router and home wifi network -- don't count, because they're part of your cable service, not the internet, so they're allowed to treat them differently.
http://corporate.comcast.com/comcast-voices/the-facts-about-...
http://corporate.comcast.com/comcast-voices/the-facts-about-...
I thought the VoD services were implemented by having a bunch of HD channels reserved as VoD stations. Then when you order something, the system tells your cable box to change to X channel, where the VoD stream plays. So it's not actually using the same system as your internet service.
I could be totally wrong on this, though.
I could be totally wrong on this, though.
> Our support of the 2010 Open Internet Order was so strong that we voluntarily agreed in our NBCUniversal transaction to be bound by those rules even if they were struck down by the courts. As a result of the DC Circuit decision and our commitment, we are now the only ISP in the country legally bound by the entire set of Open Internet rules.
Interesting fact I wasn't aware of.
Interesting fact I wasn't aware of.
It wasn't so "voluntary" when you are doing it to get FCC/ Justice Department approval for a 6 billion dollar merger.
I think the interesting point is that they are now bound by it, one way or another.
Given that, it makes sense that they'd support the notion that all other competitors be required to do the same. I don't think this is particularly altruistic in that light.
Given that, it makes sense that they'd support the notion that all other competitors be required to do the same. I don't think this is particularly altruistic in that light.
I would agree if it were not for the fact that they are only bound to the Open Internet Order until 2018.
They also did this while fighting it in court. The Verizon suit which struck down the Open Internet Rules only came as a result of a previous Comcast suit.
They also did this while fighting it in court. The Verizon suit which struck down the Open Internet Rules only came as a result of a previous Comcast suit.
This is pretty easy to say for Comcast because their television services won't be bound by net neutrality, but competing television services from other ISPs delivered over IP wouldn't be able to make quality of service guarantees for their own offerings. Am I reading this wrong?
No, you are not.
Is it phone carriers that are really on board with making fast lanes? I'm pretty sure Verizon paints it's red signs with the blood of innocent children.
any comments from netflix on this?
Gosh I love that 2/3 of this post is legalese. This is blogging in 2014.
The reclassification of broadband services is primarily a legal issue. The activists promoted this Title II "common carrier" classification and many people just parroted that without asking what that really meant. Nothing is simple when it comes down to USA spanning policy. The scope creep has introduced a number of bugs in the system over the years.
They support an open internet and the ideals of innovation.
They do not like the solution proposed (Title II reclassification)
Here's an abbreviated list that they pose at the bottom
> We do not support reclassification of broadband as a telecommunications service under Title II for at least four reasons:
> 1. Title II is unnecessary
> 2. Title II poses significant legal risks
> 3. Title II has proved to be a failure
> 4. reclassification .. will create a huge cloud of uncertainty over the entire broadband industry, thereby retarding investment and innovation.
They do not like the solution proposed (Title II reclassification)
Here's an abbreviated list that they pose at the bottom
> We do not support reclassification of broadband as a telecommunications service under Title II for at least four reasons:
> 1. Title II is unnecessary
> 2. Title II poses significant legal risks
> 3. Title II has proved to be a failure
> 4. reclassification .. will create a huge cloud of uncertainty over the entire broadband industry, thereby retarding investment and innovation.
I realize this is a tl;dr summary, but none of these points are very strong, particularly the last one:
> 4. reclassification .. will create a huge cloud of uncertainty over the entire broadband industry, thereby retarding investment and innovation.
There is a huge cloud of uncertainty over the entire internet NOW because the one government body tasked with keeping the internet free lacks the power to do so. THAT is the reasoning behind Title II: giving the FCC the power to actually do something.
> 4. reclassification .. will create a huge cloud of uncertainty over the entire broadband industry, thereby retarding investment and innovation.
There is a huge cloud of uncertainty over the entire internet NOW because the one government body tasked with keeping the internet free lacks the power to do so. THAT is the reasoning behind Title II: giving the FCC the power to actually do something.
> They do not like the solution proposed (Title II reclassification)
Title II is not the solution proposed by the FCC, its an alternative to Title I (Section 706) regulation on which the FCC asked for comment. FCCs proposed solution in the NPRM is revising its approach to Section 706 regulation in a way which it hopes will survive court review better than the last attempt at this, rather than resorting to Title II.
Title II is not the solution proposed by the FCC, its an alternative to Title I (Section 706) regulation on which the FCC asked for comment. FCCs proposed solution in the NPRM is revising its approach to Section 706 regulation in a way which it hopes will survive court review better than the last attempt at this, rather than resorting to Title II.
Title II is not "the solution proposed," it is one possible way to implement net neutrality.
The whole "Fast Lanes" argument is really just imposing "Slow Lanes." It feels like the ISP claiming its not their fault they don't have the capacity to provide the service they already sold to the customer.
I think people want TItle II partially as retaliation for the ISPs being as terrible as they are. Price/MBit hasn't gone down much(any) for me over the past 10 years. If Google can have 0 infrastructure in a town and wire it up at gigabit speeds, why is it so hard for the ISPs to improve? Its because they don't care have 0 incentive.
Maybe we set a moving limit. Internet connection under 50Mbit /down or < 10 Megabit up is classified as title II. Maybe then they'll have incentive to innovate. 2 years down the line its 50/15... I don't know.
I think people want TItle II partially as retaliation for the ISPs being as terrible as they are. Price/MBit hasn't gone down much(any) for me over the past 10 years. If Google can have 0 infrastructure in a town and wire it up at gigabit speeds, why is it so hard for the ISPs to improve? Its because they don't care have 0 incentive.
Maybe we set a moving limit. Internet connection under 50Mbit /down or < 10 Megabit up is classified as title II. Maybe then they'll have incentive to innovate. 2 years down the line its 50/15... I don't know.
> I think people want TItle II partially as retaliation for the ISPs being as terrible as they are.
I think people want Title II because they support the general direction of the 2010 FCC regulations, and recognize that those are very much common-carrier style regulations and that there is significant doubt that they can both pass legal muster under Title I and retain their substance
I think people want Title II because they support the general direction of the 2010 FCC regulations, and recognize that those are very much common-carrier style regulations and that there is significant doubt that they can both pass legal muster under Title I and retain their substance
Can you elaborate on other possible plans?
The problem is that the FCC is bounded by the authority given to it by the Telecommunications Act of 1996. The Act was passed about 5 years before the Internet became a ubiquitous service unto itself (as opposed to a healthy selection of cheap dialup providers) and wasn't written with today's realities in mind.
What really needs to happen IMO is "none of the above" - Congress needs to get its act together and pass a revised Telecommunications Act that reflects reality, so that the FCC has more flexibility to regulate beyond choosing a regulatory box to fit ISPs in ("information service" and the weak regulation that entails, vs. "telecommunications service" and the common carrier overhead that entails).
What really needs to happen IMO is "none of the above" - Congress needs to get its act together and pass a revised Telecommunications Act that reflects reality, so that the FCC has more flexibility to regulate beyond choosing a regulatory box to fit ISPs in ("information service" and the weak regulation that entails, vs. "telecommunications service" and the common carrier overhead that entails).
>Congress needs to get its act together and pass a revised Telecommunications Act that reflects reality
That's a more proper solution, but it is pretty clear that this Congress isn't able to do anything of the sort, and IMO we can't wait for another one to come along.
That's a more proper solution, but it is pretty clear that this Congress isn't able to do anything of the sort, and IMO we can't wait for another one to come along.
I fear that congress would just pass whatever lobbyists hand them.
Well, I think simply granting the FCC the authority to bring back the "open internet" rules that were in place until a court struck them down early this year.
It seems to be the way that freedom activists are pushing for. I am not aware of other formally proposed plans.
The fact is that there are two ways to go about this: Allow fast lanes or do not allow fast lanes. If you do not want to allow fast lanes then there are two routes to go about this: section 706 of telecom act or title ii of telecom act.
The route via 706 was just struck down in court. Hence the next routes available are a) allow fast lanes or b) do not allow fast lanes via title II.
The route via 706 was just struck down in court. Hence the next routes available are a) allow fast lanes or b) do not allow fast lanes via title II.
Or Congress could simply grant the FCC explicit authority to regulate network neutrality without title II reclassification. I believe there's already at least one bill to do this.
Congress did grant the FCC explicit authority to regulate. It was the Telecom Act. What the FCC has to decide on its own is what part of the Telecom Act to use in enforcing. This is not a Congressional issue. And the Court made that very clear. The FCC currently has everything it needs.
edit: I think that the bill you are referring to is Leahy's which would only give political support and not really give it new authority.
edit: I think that the bill you are referring to is Leahy's which would only give political support and not really give it new authority.
Potentially a better (or maybe potentially worse) solution, but it simply isn't going to happen with the Congress we have right now.
I would be willing to buy this if there was actually reasonable investment to begin with.
I'm from ND, and we have about 15~ rural cooperative telecom companies. If you take a look at this map: http://www.dakotacarrier.com/network.asp
You can see their respective boundaries. The white area is the major cities. Bismarck, Fargo, Grand Forks, etc. Guess who has fiber? Not the major cities! BEK is offering 200Mb fiber AND cable TV for 65 dollars a month in a lot of their coop zone, and it continues to expand. Fargo, the largest metro area has Cable One, which offers 50/10 connections for 70 dollars a month and has a bandwidth cap of 50GB.
Now, a lot of that infrastructure has come on the back of free money from the federal government, but major ISPs got that too.
If major ISPs actually used their pools of cash to build out infrastructure instead of actively trying to remove fiber from their competition, then I'd be more inclined to believe this.
As I see it, major ISPs have completely mismanaged their position in the market and instead of making a reasonable best effort to keep people happy, they've done the bare minimum and have abused the technical ignorance of most residential customers for their benefit. It's for reasons like that that I support Title II reclassification.