Tag Archives: broadband

One foot of sea level rise puts thousands of miles of fiber underwater

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Climate change poses a significant threat to telecommunications infrastructure. That’s the conclusion of a recently published paper by three researchers from the University of Oregon and the University of Wisconsin.

The authors took standard electronic map data – i.e. geographical information system/GIS files – showimg major fiber routes and overlayed it with coastal flooding predictions made by the National Oceanic and Atmospheric Administration. The data shows thousands of miles of long haul fiber at risk…

The results of our analysis show that climate change-related sea level incursions could have a devastating impact on Internet communication infrastructure even in the relatively short term. In particular, we find that 1,186 miles of long-haul fiber conduit and 2,429 miles of metro fiber conduit will be underwater in the next 15 years. Similarly, we find that 1,101 termination points will be surrounded by sea water in the next 15 years. Given the fact that most fiber conduit is underground, we expect the effects of sea level rise could be felt well before the 15 year horizon. Interestingly, we find that the risks over longer time scales do not increase significantly. Specifically, there is only a modest increase in the amount of additional Internet infrastructure that will be under water at the 6 ft. rise level (the 100 year projection) vs. the 1 ft. rise level (the 15 year prediction)…

Our results show that communication infrastructure in New York, Miami, and Seattle, respectively, are at highest risk. We also quantify the impact to individual service providers and find that CenturyLink, Intelliquent (formerly Tinet), and AT&T are at highest risk.

California also faces significant risk, according the authors. They list San Francisco, Palo Alto and Los Angeles in the top five of several risk categories, primarily because of the high concentration of telecoms assets.

It appears that the authors assumed that the fiber routes in their database are all underground. Some of that infrastructure is likely strung on utility pole routes, but the principle is pretty much the same: coastal flooding can disrupt fiber infrastructure, and it doesn’t matter much if it’s entire routes or just chunks.

The danger might not be as imminent as the authors assume – a one foot sea level rise in the next 15 years is a pretty aggressive forecast. Even so, it’s a factor that needs to be considered in planning new fiber construction, for redundancy as much as for additional capacity, and in maintenance budgets for existing routes.

Performance, not weasel words, should drive California broadband subsidies

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The reboot of the California Advanced Services Fund (CASF) broadband infrastructure subsidy program continues, with a new round of comments and suggestions landing at the California Public Utilities Commission.

I drafted the Central Coast Broadband Consortium’s filing. One issue that the CPUC should consider very carefully is what qualifies as a bona fide service offer.

When the California legislature allowed lobbyists for AT&T, Frontier Communications, Comcast and Charter Communications to rewrite the law and turn CASF into their own, private piggy bank, the minimum broadband standard was lowered to 6 Mbps download and 1 Mbps upload speeds. If an incumbent “offers” such service, then the area in question isn’t eligible for an infrastructure grant.

The point we made is that…

In order for such an offer to be valid, an incumbent provider must be capable of actually delivering service at 6 Mbps download and 1 Mbps upload speeds (hereinafter, “6/1 service”) consistently to any household that subscribes to it. Although it is common industry practice to advertise service at a certain level and then condition it with a long and difficult to parse list of exceptions, there are no such exceptions in the statute. An incumbent is either capable of delivering 6/1 service to every household that subscribes to at least that level of service at all times, or it is not. If an incumbent is not capable of fulfilling an offer of 6/1 service, or better, at all times in any given census block or to any given household, then that census block or household is unserved.

An offer that can’t be fulfilled is not a offer at all. Incumbents should not be allowed to block independent projects on the basis of marketing claims or service that meets the minimum standard only some of the time. The 6/1 standard is ridiculously low to begin with. The least the CPUC can do is require incumbents to actually meet it.

CPUC won’t kill SCE’s dark fiber business. Yet

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Southern California Edison fought its dark fiber battle to a draw, but all out war looms on the horizon. That’s my reading of a proposed decision by a California Public Utilties Commission administrative law judge that would end SCE’s quest for approval of a bulk fiber lease deal with Verizon, if the commission votes to approve it next month.

SCE, like other electric utilities in California, installed fiber optic cables on its pole routes, initially to monitor and operate its infrastructure. But one cable has dozens of fiber strands, and over the past 20 years SCE has leased out some of that surplus capacity, under terms approved by the CPUC that require it to rebate 10% of the gross revenue generated to electric customers.

Usually, the CPUC reviews SCE’s fiber leases one by one. But last year, SCE asked permission to sign a master lease with Verizon, and then add individual fiber routes to it over time.

That rational and reasonable approach was first accepted, then rejected after rookie commissioner Clifford Rechtschaffen stepped in. So-called consumer advocates, who don’t seem to understand that consumers need fast, affordable and competitive broadband service too, jumped in as well. The ultimate result was a proposed decision that would have split the gross revenue 50/50. SCE said that would kill its dark fiber business model – which is probably true – and that, in any event, the Verizon deal was dead because of the CPUC’s delays.

With the SCE decision looming, Pacific Gas and Electric also asked to cancel its request for CPUC permission to get into the telecoms business.

The proposed decision published yesterday would allow SCE to withdraw its application for approval of the now moot Verizon deal, but opens the door to a comprehensive, and potentially far more damaging, review of electric companies’ dark fiber leases…

The scope of the proceeding has raised broad policy issues that include identifying what policy frameworks promote the most effective utilization of ratepayer-funded dark fiber throughout California’s regulated electric utility infrastructure and assure safety, universal access to utility services, and non-discriminatory access to this infrastructure, especially amidst policy changes at the federal level. The Commission may consider opening a rulemaking to consider these and other broad policy issues and, in that broader context, reconsider the appropriate revenue sharing allocation for dark fiber route leases.

Electric companies are one of the few sources of independent dark fiber left in California. Killing their fiber business would harm consumers, both as electric customers, who would have no revenue to split at all, and as broadband customers, who pay high monopoly prices for low levels of service.

For now, we can only hope that “universal access to utility services” means all utilities, including broadband.

Caltrans backs off requiring extra conduit in highway projects, but broadband cooperation door still open

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Caltrans updated its “user guide” for installing broadband infrastructure into highway projects. The big change is the elimination of a shadow conduit requirement – telecoms companies that take advantage of opportunities to install facilities in highway projects are no longer obligated to install extra conduit and fiber for Caltrans, at their own expense.

On the whole, it’s not a killer change. The more independent broadband infrastructure in the ground – Caltrans is nothing if not independent – the better. But Caltrans still has the option to pay for any conduit and fiber it might want to add. Since it doesn’t typically make its telecoms facilities available to private companies, the impact on competition is nil. Except where municipal broadband is concerned. Caltrans will cooperate with local agencies, in its own way, and in theory the less inventory it has, the less there is that might be shared. As a practical matter, though, the impact isn’t significant.

The important thing this is that independent Internet service providers and local agencies still have a clearly defined onramp to Caltrans projects. It takes some initiative, though. Caltrans publishes an interactive map showing where it’s planning to do some work – there’s a link to the current version on Caltrans’ wired broadband page – but it’s up to ISPs and agencies to keep track of what’s going on in their areas. Once a likely project is identified, Caltrans says that “companies or organisations working on broadband deployment may collaborate with Caltrans to install a broadband conduit as part of a project”. The next step is to email the Caltrans single point of contact for the district that’s involved. A link to the current list of those contacts is also on the wired broadband page.

This is all the result of assembly bill 1549, passed in 2016. It didn’t put Caltrans in the broadband business as we originally hoped, but it did open a plainly marked door for cooperation. It’s up to ISPs and local agencies to walk through it.

I served on Caltrans’ conduit task force and I’ve advocated for and helped to draft AB 1549. I’m involved and proud of it. Take it for what it’s worth.

PG&E cancels competitive dark fiber business plan

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That didn’t take long.

Four days after informing the California Public Utilities Commission that it couldn’t reach agreement with a grab bag of protesting organisations, Pacific Gas and Electric threw in the towel. It’s ending its plan to become a competitive telecommunications company. It won’t put its extensive inventory of surplus dark fiber, and potentially other services, on the open market.

In its request to withdraw its application for certification as a competitive telecoms company, PG&E said the world has changed since it began the process more than a year ago…

Given PG&E’s present circumstances, it is in the public interest that PG&E make current informed decisions in light of the new environment before investing significant resources in launching the new [competitive telecoms] business. PG&E and parties have diligently engaged in settlement negotiations to expeditiously make progress towards full resolution of the issues in this proceeding. However, as more time passes, the uncertainties of PG&E’s current circumstances outweigh the potential economic and busines benefit of the proposed [competitive telecoms] business. Therefore, the public interest is protected by allowing PG&E to exercise its prudent business decision-making to not continue to pursue the [competitive telecoms] business, at this time, given the significant change in circumstances since the filing of the…Application in April of 2017.

PG&E didn’t say exactly which circumstances had changed, but top of the list has to be the estimated $12 billion in damages it might have to pay out as a result of last year’s wildfires. When a company faces an existential financial threat, it’s time to scrap diversification plans and focus on the core business.

But that’s not the only circumstance that’s changed. The CPUC seems to be intent on killing the competitive dark fiber business in California. Last year’s decision to wave through CenturyLink’s purchase of Level 3 Communications took the last major source of independent dark fiber in California off the market, and its savaging of Southern California Edison’s plan to do a bulk dark fiber deal with Verizon sent a clear message that electric companies that want to compete in the telecoms space need not apply.

When California’s utility regulator lines up – wittingly or not – on the same side as big, monopoly model telecoms companies like AT&T, Comcast and Charter Communications, it’s game over. Retreat was PG&E’s only option.

PG&E’s competitive dark fiber ambitions stall at CPUC

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Update: PG&E filed a request with the CPUC, asking to withdraw its application to become a certified, competitive telecoms company. More tomorrow.

It’s been more than 15 months since Pacific Gas and Electric asked for permission to get into the dark fiber business in a big way. In April 2017, it asked the California Public Utilities Commission to certify it as a telecoms company, which would allow it to lease its surplus dark fiber to commercial customers. It’s already in the dark fiber business, but it’s limited to leasing capacity to service providers that are already certified.

As is common practice, potential competitors and so-called consumer advocates jumped into the middle of the CPUC’s review – intervened, as its called. Instead of managing its own process, the CPUC was content to let these intervenors dicker with PG&E. It wasn’t productive. I attended a couple of those sessions as an observer – my clients include municipal electric utilities with fiber interests – and wasn’t impressed by the quality of the conversation. Now, those talks have broken down and everything was tossed back into the lap of the CPUC administrative law judge who currently has the ball (it’s been passed around a bit).

According to a joint update PG&E and the intervenors filed with the CPUC

Despite the good faith effort of the Parties, it became clear that an agreement would not be reached on any of the issues and all settlement discussions ended on July 30, 2018…the Parties no longer believe that settlement will be reached on any of the issues in this proceeding.

Now, the ALJ hearing the case is asking PG&E to answer several pertinent questions about its quest to add telecoms to its portfolio. That would have been a fine thing to do a year ago.

We’ve already seen Southern California Edison’s fiber deal with Verizon collapse this year, due to the CPUC’s needlessly complicated process, and the misguided efforts of competitors, advocates and a CPUC commissioner to extract benefits, public or otherwise, from it. It would be a tragedy for Californian consumers – who need affordable broadband access as much as they need electricity – if PG&E’s bid to make the northern California telecoms market more competitive also fails.

California net neutrality bills back on track

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The new versions of senate bills 822 and 460 were filed in Sacramento yesterday, and appear to once again be a legitimate revival of network neutrality, as promised last month.

SB 822, authored by senator Scott Weiner (D – San Francisco), is the big kahuna. The bill reinstates the three bright line rules first adopted by the Federal Communications Commission in 2015, when it had a democratic majority, and then repealed in 2017 after republicans took control: no blocking, throttling or paid prioritisation.

Zero rating – not counting certain content against subscribers’ monthly data caps – is also on the list of banned practices, unless its done across the board. It would be okay for AT&T to say all data used to watch video is zero rated, but not for it to limit the freebie to its own content, for example movies produced by Warner Brothers or distributed by DirecTv.

There’s language that attempts to close loopholes. ISPs couldn’t erect upstream toll gates for content or application providers, or deliver an in-house service over a subscriber’s connection and claim it wasn’t coming via the Internet. In other words, the bandwidth you buy is your bandwidth.

One change that’s been made is to draw a distinction between fixed – wireless or wireline – and mobile Internet service. At this point, the same rules would apply to both kinds of service. If it was done to limit the damage done by the inevitable court challenges, then it’s a good thing. It needs to be closely watched, though, to make sure that the change isn’t an invitation for the army of lobbyists fighting the bill to fiddle with it.

SB 460, by senator Kevin de Leon, would require state and local agencies to only buy Internet services from ISPs that abide by SB 822’s rules.

The bills are tied together. Both have to pass for either to take effect. There are some committee hurdles for the bills to get over, but that’s a formality so long as democratic leaders are on board. The legislature has until the end of the month to act.

Broadband service failed in 2017 California firestorm, mobile hit worst

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One of the big questions to answer about the mega fire still tearing through Shasta County this morning is how do you warn people? Broadband and other high tech tools failed in last year’s fires. Instead, people were saved the old fashioned way: a knock on the door or the smell of smoke.

Mobile service went down more often than any other kind of broadband service during 2017’s northern California firestorm, but cable, telco and fixed wireless systems also took a severe beating. Satellite Internet service had the highest survivability rate. That’s one conclusion drawn from a wide survey of people in and around Mendocino, Napa and Sonoma counties during an horrific wildfire in October 2017.

Mobile broadband carriers had an 88% failure rate – i.e. people “lost some to all service”. Broadband service from Comcast was down for 73% of customers, while 69% of AT&T and Frontier broadband subscribers experienced outages.

One caveat: the survey did not break AT&T subscribers out by type of service. Comparing total numbers, and also the voice telephone service data collected, it’s a fair conclusion that most of the 700 people who ticked the AT&T Internet service box are landline customers. So that’s how I categorised them, but I’m sure that some mobile customers are mixed in.

DSL resellers – companies that lease copper lines from AT&T or Frontier, add some equipment and provide semi-independent Internet access – only had a 43% failure rate. But that doesn’t mean they did better than the big guys – resellers concentrate their service in cities and towns, and most of the fire damage was in exurban and rural areas. If rural residents can’t buy the service, then they can’t lose it either.

One common problem that all the terrestrial companies in the counties have is that AT&T is pretty much the only middle mile game in town, according to the report. So if an AT&T inter-city line is damaged, all the ISPs using it suffer.

Satellite Internet service, which had a 26% failure rate, isn’t affected by AT&T’s backhaul outages. But it does share one weak link with all the others: electricity. If your power (or your provider’s) goes out and there’s no back up, you don’t have Internet service either. Smoke shouldn’t have been a problem for satellite or other wireless services – any smoke that’s thick enough to block signals is too thick to breath. No one should have been sitting at home trying to get on the Internet at that point.

The data was collected by the North Bay/North Coast Broadband Consortium. More than 3,700 people filled out an online survey. It wasn’t a scientifically selected sample, but just taken for what it is, it’s a significant number of responses.

North Bay/North Coast Broadband Consortium Telecommunications Outage Report: Northern California Firestorm 2017, released 10 May 2018.
Report Appendices, released 10 May 2018.
More information from the North Bay/North Coast Broadband Consortium.

CPUC and Frontier must put broadband upgrade cards on the table

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When the California Public Utilities Commission allowed Frontier Communications to buy Verizon’s wireline systems in California, it imposed a long list of conditions, including commitments made as part of settlements reached with organisations that objected to the deal. Some of those obligations required Frontier to upgrade broadband service to more than 800,000 homes.

One of those organisations is the California Emerging Technology Fund, which is embroiled in a dispute with Frontier over nearly every aspect of that settlement. CETF claimed in a complaint filed with the CPUC that Frontier “does not intend to honor” its commitments, including, among other things, the upgrade schedule it offered in 2016.

In its formal response to CETF’s allegations, Frontier never actually says that it kept to that timetable. All it says is that “Frontier sent a letter to the Communication Division dated March 8, 2018 on its commitments that includes a confidential attachment reflecting completed locations through December 31, 2017”. It sent a letter, but doesn’t say what’s in the letter or even claim that the letter documents fulfillment of its obligations.

It did include a table, shown above, which gives an overview of what it believes its obligations to be. It’s not a revelation. It simply repeats what’s in a similar table included in its 2016 settlement with consumer groups, plus a much smaller promise of 7,000 upgraded homes in northeastern California made to CETF, plus the households that the Federal Communications Commission is paying Frontier $228 million to upgrade via its Connect America Fund program.

One striking omission is how Frontier plans to meet its promises. In the course of winning the CPUC’s approval for the Verizon deal, Frontier promised specifically to upgrade wireline service, and claimed it “focused solely on wireline telecommunications”. Since then, it has publicly backtracked on that pledge.

Frontier’s obligations are to the people who live in the communities where it intends to upgrade broadband service. Both the CPUC and Frontier have a duty to let them know where, when and – particularly – how those upgrades will be made.

Zero understanding of dark fiber business means zero benefit to Californian consumers

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Southern California Edison is driving home the point that rebating half of its dark fiber leasing revenue to electric customers would kill its ability to compete in the telecoms market. A draft decision by CPUC commissioner Clifford Rechtschaffen would replace a nearly 20 year old gross revenue sharing formula – 90% to SCE, 10% to electric customers – with a 50/50 split.

In closed door meetings with top California Public Utilities Commission staff, an SCE executive and an in-house lobbyist said, in effect, that Rechtschaffen doesn’t understand the dark fiber business…

Contrary to unsupported statements in [Rechtschaffen’s draft decision], a 50/50 gross revenue sharing mechanism would not provide sufficient return to justify shareholder investment. The 50/50 gross revenue sharing implies equal sharing of benefits, but ignores the incremental costs, risks, and business liabilities incurred by shareholders…

Shareholders would have to recover all of their costs through the remaining 50%, if possible, resulting in disproportionally less or negative benefits for shareholders since customers do not incur any incremental costs. There is no evidence in the record that the 50/50 split is an economically viable mechanism to justify shareholder investment.

Both SCE and the Utility Reform Network (TURN), a non-profit organisation that claims to speak for consumers, filed longer written comments about Rechtschaffen’s draft.

TURN shows a similar lack of understanding about telecoms. It argues that SCE’s dark fiber business should micromanaged by the CPUC, similar to the way privately-owned electric utilities are regulated.

That’s nonsense. Electric utilities are monopolies that provide an essential service, and it is rational to regulate them as such. Independent dark fiber companies have to make their living competing against unregulated, monopoly business model telephone companies. Micromanaging one of the few remaining competitive sources of dark fiber in California, while ignoring, if not actively assisting, monopoly telcos is perverse.

Californian consumers need fast and affordable broadband service every bit as much as they need electricity. Thinking that cutting them in on more of SCE’s fiber revenue will be a benefit to them is pure fantasy. SCE put it correctly and succinctly in its comments: “the ‘interests of ratepayers’ are better served by 10% of gross revenues than by 50% of zero”.