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easier to find reasons for rejecting than embracing."
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Wednesday, July 20, 2005

Some initial questions: The Framework
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For starters, let me offer some initial questions that I have found myself answering since the report came out:

1. Why is there a separate interconnection standard? Why can't it just be left to a general "unfair competition" standard?

2. The Internet backbone interconnects without any special interconnection mandate through privately negotiated agreements, does the DACA interconnection standard inhibit this private deal-making?

3. Does your model allow the FCC to continue its practice of rate-setting -- particularly as to interconnection -- and thus continue the time-worn hazards of rent-seeking and industrial policy shenanigans?

4. Does this Model allow for regulation of the higher layers of the Internet protocol stack, thus isn't it more regulatory?

5. Why do you use the phrase "public networks" in your draft statutory language? Doesn't that create problems in defining what is, and isn't subject to your general standard of "unfair competition"?

6. What is wrong with the IP Migration model?

I have some tentative -- and even some good! -- answers to many of these questions, but I'll turn it over to my fellow working group members first. Specifically, I look forward to the Gattuso/Speta/Shelanski discussion on the interconnection standard, and the Sicker disquisition on the limits of the IP Migration model. Plus, it is my hope we get some cross-pollinization between working groups, as folks cross-comment on their colleagues' work.

posted by Ray Gifford @ 2:48 PM | Regulatory Framework

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