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brooks7 4/1/2016 | 3:44:54 PM
Re: Flawed assumptions and false dichotomies lead to deeply flawed analysis "More importantly, she seems to think that arbitrary technical details of delivery should potentially bear on the question of whether a managed service is or isn't actually a managed service."

Actually, those are precisely the way things are regulated.  The arbitrary nature of regulation is a system imposed by man via government to try to obtain some end.  The physics and science involved is not determined by the same set of rules.  Some regulation makes sense, some does not.  Look at wireless spectrum allocation.  We choose to use some spectrum for a set of services.  There is no physics that says that this is what must be.  The same is true for how muddled services have gotten based on the advent of Internet Technology as it is used networks.  Services that used to be only available on dedicated technology are just as good (or better) delivered over the Internet.  Yet, we regulate some of these things differently.  Want an example that is non-video based?  How about this - Why does Skype not have to have a 911 function?  Is it not marketed as a replacement for wireline voice services?  See - arbitrary.

seven

 
jsgreenfield 4/1/2016 | 1:05:51 PM
Flawed assumptions and false dichotomies lead to deeply flawed analysis Ms. Silbey seems to be making a lot of assumptions about the delivery of Stream TV -- assumptions that are not well-founded -- for example, that Stream TV is delivered as a unicast IP service via the same DOCSIS QAMs used for general data service.  That may (or may not) be true now, and even if it is true now, it may or may not be true in the future (as penetration of a service increases, the optimal technical solution is liable to change).

More importantly, she seems to think that arbitrary technical details of delivery should potentially bear on the question of whether a managed service is or isn't actually a managed service.

That's a strange position.

She tells us "the bandwidth used for IP-video service and Internet service comes from the same overall pool of spectrum."

Sure, that's true, in the exact same sense that traditional analog or MPEG2-TS service comes from the same overall pool of spectrum as internet service.  Is that a fact that suggests that traditional cable television service should potentially be treated as a nothing more than another OTT internet service?

Is it the presumed use of IP encapsulation over the plant that makes Stream TV somehow different?

(Keep in mind that a modern D3.0 CM is capable os simultaneously tuning both Docsis and no-Docsis QAMs, and a service such as Stream TV could easily be implemented as an MPEG2-TS-delivered service, with IP encapsulation for home network delivery performed within the CPE device.)

If IP packaging is used, then the service should potentially be treated as another OTT internet service?

AT&T Uverse and Verizon FiOS both use IP delivery for some or all of their managed video services.  So should those managed video services of AT&T and FiOS be treated as OTT data services?

Is it the presumed use of common QAMs that make Stream TV somehow different?

(Keep in mind, a service such as Stream TV could easily be segregated onto separate QAMs from those used for internet service, even assuming DOCSIS delivery.)

If Stream TV happens to used shared QAMs, is that what makes it different?

Both Uverse and FiOS share a single transmission channel (a single DSL channel, in the case of Uverse, and a single fiber wavelength used for IP, in the case of FiOS) between their internet services and some or all of their managed video services.

Perhaps its the presumed use of unicast that makes Stream TV somehow different?

(Keep in mind, a service such as Stream TV could easily be implemented using multicast delivery.)

But then, both Uverse and FiOS use unicast for some or all of their managed video services, as do cable operators, for their traditional VOD services.

The reality is that this fundamental issue has already been addressed.  The FCC explicitly recognized so-called non-BIAS services (previously known as "managed services") as distinct from OTT internet services because they recognized that the alternative was for them to be regulating the technical details of delivery.

It makes absolutely no sense to tell an operator that if they deliver content without IP encapsulation, it will treated one way, but if they deliver it with IP encapsulation, it will be treated another, or that if it is delivered as multicast it will be treated differently than unicast, or that if they use one form of multiplexing it will be treated differently than another form of multiplexing.

It truly would be a horror show for regulators to dictate the technical details of how a provider delivers services over their facilities.  And make no mistake: the suggestion that a service like Stream TV should potentially be treated as just another OTT service is precisely a suggestion that, potentially, the technological details of service delivery should be dictated by regulators.
marjsdad 4/1/2016 | 12:54:41 PM
Cable Internet capacity Don't think you need to worry about allocating enough bandwidth to broadband. 10 years ago, DOCSIS 3.0 increased capacity from one 6 MHz channel to 8 channels. With DOCSIS 3.1, Comcast will increase that to 48 or more channels, meanwhile doubling the efficiency of those channels that are dedicated to D3.1 (16 to 32 of those 48+ channels). And they got there not just with new technology, but by investing big money to go to all-digital TV, increase total plant to 1 or 1.2 GHz, convert to MPEG 4 compression, next to IP Multicast. All of that cost big money and created fathomless bandwidth for broadband and nearly unlimited capacity for carrying linear channels.
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