Ex Parte frenzy

With all these ex parte conferences, does anyone at the FCC have time to get any work done? For a while there, we saw a Web hosting flurry, but the blizzard these days is all about dark fiber.

As one might expect, the phone companies are coming down hard against dark fiber. Reading between the lines, it looks to me like the phone companies realize they're fighting a rear guard action, and are looking to limit what kind of dark fiber is allowed. Of course they're still saying, "Dark fiber shouldn't be allowed," but lately the main arguments seems to be, "the FCC should study this matter further." (Any time anyone asks the government for further study, I know they're on the losing side of whatever issue, and are just trying to delay.)

I was curious to see what the Communications Workers of America would say, so I actually read all of that one. They had four points, which I would summarize thus:

1. Don't allow dark fiber. Managing a broadband network is too complicated for the amateurs in school districts and should be left to CWA professionals.
2. Be sure that applicants include the extra costs to provide broadband over dark fiber as opposed to a managed service.
3. Protect workers rights and labor standards.
4. Ensure adequate funding. Increase the cap.

My reaction:

1. Whoever wrote this point has not sat in the seat of a school tech director. At best, a broadband connection from a telecom company is transparent. You plug your switch into the provider's Ethernet ports at both ends, and away you go. But in reality, the packets you send into that port are wrapped in an MPLS envelope so that they can be shifted to whatever transport protocol the carrier is using, routed over the carrier network, then reconverted to Ethernet at the other end. There's a lot that can go wrong in the carrier network, though I have to say that other than physical failure (a telephone pole going down or an underground cable meeting a backhoe), carrier networks are pretty bulletproof. But with a dark fiber connection, I'm plugging a dark fiber directly into my switch. No protocol conversion, no routing. The only thing that can go wrong is physical. In addition to being cheaper, dark fiber is easier.
2. Extra cost? What, the cost difference between a 1000BaseT GBIC and an 1000BaseLX GBIC? There is no extra equipment for dark fiber. For a carrier, there is a *lot* that goes into converting a piece of dark fiber into a broadband network. For a school district, the only difference between dark fiber and a managed service is whether the port is copper or fiber.
3. Now this is the kind of argument a union should be making. However, the political power of unions really seems to be on the wane, so I don't think we'll see any labor protections in the E-rate program.
4. Hear, hear.