Monday, January 31, 2011

Over 20% of Bandwidth Used for Digital Piracy-- Are You Surprised?

I'm not surprised, and I would bet that most rural ISPs aren't too shocked by that figure either. People love free stuff, and with the Internet it can be really tempting to illegally download a popular movie that hasn't come out on DVD yet or a digital copy of your favorite CD. This is probably not new information to anyone, I would imagine. Many people might feel like digital piracy is a victimless crime--nobody gets hurt and the content creator won't miss that half a cent of income from the song download anyway (presumably). Many people also probably never expect to get caught for downloading something that legally only costs a couple of dollars, and they also don't expect the punishment to be more than a slap on the wrist. I think of digital piracy just like I think of shoplifting (because they are essentially the same)--if you want it bad enough, just pay for it--and if you can't pay for it then either save the money or move on. Simple. Someone worked hard to create that content, and that someone deserves full compensation in return, I don't care if it is a starving artist or a multi-platinum songwriter. This is capitalism and human decency at its most primitive, yet we currently live in a world where over 20% of all Internet traffic is pirated content, digital theft, copyright violations, etc.

Today I attended a conference entitled:"How Much Bandwidth Is Used For Online Piracy?" hosted by the Information Technology & Information Foundation (ITIF). I knew the answer to this question was going to be "a lot of bandwidth" and the solution to this problem would not be straightforward or easy. Actually, there aren't any real comprehensive and totally effective solutions yet. Anyways, an expert on the subject reported that approximately 23.8% of global Internet traffic is infringing on a copyright, and the infamous BitTorrent is responsible for about half of this illegal traffic. In the U.S., the total figure is slightly lower than the global percentage, but at 17% it is still obviously a huge problem--that accounts for a massive amount of bandwidth. In the U.S. alone, the economic impact of digital piracy and copyright theft is over $20 billion annually, but it is the impact on networks--small ISPs in particular--that really concerns me. The easy nature of piracy combined with lack of consumer knowledge about what constitutes legal vs. illegal downloads is a recipe for disaster for ISPs. Furthermore, an ISP that attempts to block traffic or use deep packet inspection to detect and prevent peer-to-peer (P2P) or and other services that support digital theft can start to look like a glaring Net Neutrality violation, thanks to those "wonderful" (= NOT) new rules dictating how ISPs should behave in the Internet ecosystem. It actually brings up an ironic meaning to the purpose of the Net Neutrality rules--to keep the Internet "free and open." Yes, the Internet will be free and open--for anyone to take whatever they want for free, legal or not! One presenter at the conference said that it is often harder to find legal content than illegal content on major search engines because the legitimate sites are buried under a dozen illegitimate sites. This is quite similar to the correlated and horrendous crime of counterfeit merchandise--search for a designer label on eBay and chances are most of the search results will be for fake items that come from slave labor and organized crime. Digital theft of songs and movies might not have such obvious connections to traditional criminal activity, but there are strong associations between digital theft and online identity theft, viruses, malware, etc. There are plenty of legal options for acquiring digital content on the infinite Internet universe, and it should not take extra effort for consumers to locate and acquire it.

What does this mean for rural ISP's, and more importantly what can rural ISP's actually do to detect, prevent and stop digital piracy from hogging their precious bandwidth? Clearly, it means that a great deal of bandwidth is being used for digital theft--again, no surprises here. This reduces the amount of bandwidth available for home businesses, schools, medical centers, and other rural ISP customers. As for what can be done about the problem, there needs to be a balanced and comprehensive solution that involves enforcement, consumer education, and new business models for legal online content. Basically everyone in the Internet ecosystem needs to play a role in reducing digital piracy--I highly doubt it will ever be eliminated entirely. I would be wary of utilizing any deep packet inspection or technologies that restrict or block P2P and illegal file streaming so not to be slapped with a fine for violating Net Neutrality. Rural ISP's could provide some type of consumer education to help steer the traffic away from illegal downloads, but it is ultimately up to the end user to make the right decision. The government has to be careful not to restrict free speech in any legislation aimed at reducing online piracy, and the idea of enforcement mechanisms aimed at all Internet traffic at all times is actually pretty creepy. I think we are definitely at a crossroads right now where it is time for lawmakers to make some significant decisions about digital piracy, and ISP's should have the freedom to do what needs to be done in order to protect their bandwidth for legitimate, paying customers.

I would be really interested in hearing about any solutions that rural ISP's use to detect or prevent digital piracy, if these solutions are effective, and what the "perfect" solution might be.

If you are interested, here are some of the materials from today's ITIF conference:

Technical Report: An Estimate of Infringing Use of the Internet, Envisional (January 2011).

"Steal These Policies: Strategies for Reducing Digital Piracy," D. Castro, R. Bennett, S. Andes; ITIF (December 2009).

Hope everyone enjoys the ice and snow this week!
Cassandra Heyne
ruraltelecommentary@gmail.com

Thursday, January 27, 2011

A Quick Note on Broadband Speeds...


New NTCA report answers two of Blair Levin's three Universal Service questions (from Connected Planet)


If I learned anything in 2010, it was that Blair Levin is a true nemesis to rural phone companies and that the 4 Mbps target set forth in the National Broadband Plan is completely insufficient. I actually wrote a paper for a class last semester about how insufficient and insulting this "target" is compared to the broadband speeds targeted and achieved in other countries like South Korea, Japan and Sweden. If rural phone companies invest in broadband infrastructure to achieve 4 Mbps, they will not only be at a significant competitive advantage but the rural Digital Divide will actually increase because everyone else (i.e. urban/suburban citizens) will have truly high speed broadband at 10 Mbps - 100 Mbps or more. Although the National Broadband Plan was a positive step in the direction of successfully implementing a comprehensive broadband strategy--something that other countries who lead in broadband speed, penetration and deployment have also done successfully--it is imperative to set the same broadband targets for everyone. Thus, the fundamental failure of the NBP is that it separates rural/unserved areas and everyone else in terms of what broadband speeds should be deployed by a whopping 96 Mbps! Yes, funding is a serious issue and it obviously costs a lot more to deploy 100 Mbps service than it does to deploy 4 Mbps service. That is a problem that needs to be worked out in the upcoming USF rulemaking. But for now, I am very happy to see that rural phone companies are not settling for the 4 Mbps speed target, and they are speaking out on this issue through their advocacy associations. Rural phone companies should not have to settle for USF support for a broadband speed that was considered slow 5 years ago. And most importantly, rural customers absolutely do not deserve to be categorized as second class citizens in the realm of broadband speeds. Setting the rural broadband target at a minimum of 25 Mbps (preferably 100Mbps but I understand there are financial limitations here) will help attract new businesses and residents to rural areas, and can help revitalize communities and bring much needed economic relief to rural areas. Truly high-speed broadband can facilitate critical applications such as distance learning, tele-medicine, e-commerce, real-time video, and numerous other uses that are especially attractive for people who live in remote areas. We can't even being to imagine some of the life-changing applications that will be developed in the near future as a result of high and ultra-high speed broadband availability, and there is absolutely no logical reason why a significant portion of the U.S. population should be limited by broadband speed. Thankfully, many rural telecom providers are forging ahead with infrastructure investments despite the considerable financial and regulatory uncertainty because these companies are dedicated to providing their customers with service that is reasonably--or equally--comparable to service provided in urban areas. Hopefully there will be some resolution to USF uncertainty next month, I know I am keeping my fingers crossed and greatly anticipating the Feb. 8th FCC Open Meeting!

If anyone is interested in reading my paper on broadband speeds, entitled "Unreasonably Comparable Broadband Service: An Analysis of Leading International Broadband Plans and Accomplishments," please e-mail me and I will be happy to send you a copy.

Cassandra Heyne
ruraltelecommentary@gmail.com

Sunday, January 23, 2011

Must-Read: The Master Switch is a Masterpiece of Independent Spirit

Book Review
The Master Switch: The Rise and Fall of Information Empires, by Tim Wu

I am innately attracted to almost any book that has the phrase "The Rise and Fall of..." or the word "Empire" in the title, so naturally I was pretty excited about The Master Switch from the beginning. I also love reading detailed and multifaceted histories about virtually anything, from caviar to countries to Chanel No. 5. Basically, this book was right up my alley, being about the history of all different sectors of the telecommunications industry, especially the independent and entrepreneurial spirit that drove most telecom sectors from humble beginnings in garage workshops or on remote mountain top antennas to multi-billion dollar titans of industry. These telecom sectors (content, transmission, entertainment, etc.) are so intertwined in our lives today that we can hardly even imagine the days when cable TV and the Internet were no more than fringe ideas struggling to gain support from an industry and regulatory regime that strongly favors entrenched incumbents and monopolies. The Master Switch details plenty of dramatic rises and falls in telecommunications throughout the last century.

Being a history lover, I generally like any book about the great tales of trial and tribulation that occurred during the first 100 years of the telecommunications industry. What makes this book really special in my opinion is that it is literally an anthem of independent telecom entrepreneurs and innovators. Credit is rightly given to rural telecom pioneers--the farmers who strung up barbed wire out in the middle of the Great Plains in order to communicate with each other--as well as independent filmmakers, early radio mavericks, the cable TV crusaders, and of course the Internet and computer start-up geniuses (including the individuals who now basically rule the information empire--yes, even those guys had humble beginnings). My favorite story in the book was about how AT&T used to go into rural areas and literally pull out all the equipment and wires instilled by the rural telephone companies and burn or destroy the equipment in the town square for all to see. It really made me think that not much has changed in the last 100 years in terms of rural phone companies vs. The Big Guys. Even if AT&T doesn't go pull out wires and burn equipment anymore, the big companies certainly put the rural companies through the wringer with other forms  of attrition including USF funding, access revenue, and exclusive contracts with handset manufacturers. Sometimes it seems like they might as well just start pulling out wires and burning expensive digital switches in the town square. I recently uncovered some interesting history about my family's company, Walnut Communications, and its various conflicts with AT&T back in the old days (circa 1915). As the story goes, Walnut farmers were installing lines to reach the surrounding farm community and at one junction the Walnut line had to cross paths with an AT&T transcontinental circuit. The men were unable to install the Walnut line below the AT&T line, so they decided to quickly  toss the line over top of the AT&T line--big mistake! This actually shorted out the AT&T transcontinental line momentarily. Apparently it did not take AT&T very long to realize where and how the problem was caused, and the next day AT&T representatives showed up in Walnut to question my great-great-uncle Andy Schuttloffel about this little incident. Fortunately, the AT&T representatives determined that the AT&T line was actually too low to begin with, even though the Walnut crew should never have tried to put a line over top the AT&T line. Walnut was given a stern warning to never attempt such a feat again, and my great-great-uncle was actually invited to tour the AT&T facilities in Omaha, NE, where they were kindly shown that if their transcontinental line was ever shorted for even one minute, the cost would be hundreds of thousands of dollars. Some years later, there was another situation involving blocked long distance calls, where my great-great-uncle actually went to Chicago in desperation to literally beg to an AT&T executive that the good people of Walnut Iowa deserve quality telephone service and the right to be able to make long distance calls to anywhere, anytime. Apparently the AT&T executive was impressed with Andy's courage and convictions, and the long distance issue was resolved peacefully.

Back to the book... In addition to a nice overview of the history of all sectors of telecommunications, The Master Switch also features many other interesting and not commonly known anecdotes about some of my favorite characters in US telecom history, such as Theodore Vail, David Sarnoff and poor Edwin Armstrong, Henry Tuttle of Hush-a-Phone infamy, Lee De Forest, Philo Farnsworth, Judge Green, Ted Turner, and many more lesser-known but equally important telecom pioneers and inventors of various technologies. I strongly believe that it is critically important to understand the past if you want to have any hope whatsoever to not only comprehend what is going on right now, but to take a wild stab in the dark at foreseeing the future. Thus, "illuminating the past to anticipate the future" is one of the central themes of this book. The author does an exceptional job of walking the reader through the entire scope of the telecom and information industries, chronologically from humble beginning through (in some cases) devastating destruction and eventual rebirth and stabilization. Along the way, the connections between different industries are clearly drawn, until more recently when these lines became increasingly blurry to the point that now an average person could probably not tell the difference between wireless, cable and landlinetelecom industry--spanning multiple decades and multiple dominant corporations/technologies/etc. The Cycle is the industry's transition from open to closed , and it "is powered by disruptive innovations that upend once thriving industries, bankrupt the dominant powers, and change the world." Disruptive innovation, also called the "Kronos Effect" in the book, is an ongoing bee in the bonnet of the dominant empire-rulers in telecom. The book describes how AT&T was literally terrified of the answering machine, and RCA really did not want FM radio to take hold. Cable TV, the Internet, wireless...all disruptive technologies at one point and all very much despised by incumbents and monopolists at first. Why prevent people from enjoying a new technology? Disruptive innovations cost the incumbents money and can be really annoying to get rid of or delay indefinitely. The Kronos Effect basically means that the dominate company will devour a potential challenger before the challenger even gets a chance to show its true colors. This has happened over and over and over in the telecom industry, and it probably won't stop any time soon. It really makes you wonder how many potentially "killer apps" and whatnot were squashed in infancy before most people even had a chance to realize their benefits.

In light of some recent significant telecom events like the FCC's contradictory actions of first regulating the Internet to keep it "free" and "open" and then allowing two of biggest and most powerful players to merge (Comcast-NBCU) which practically gives Comcast-NBCU a golden ticket to violate alleged net neutrality rules, this book can offer a lot of insight with an eye towards what will happen in the future. I don't see any end to mega media conglomerates and the Googleization of everything, but hopefully there will still be room in this infinite empire for the small company to flourish. The lesson seems to be that if a small/new company tries to ruffle too many feathers, it will be devoured by the dominant company--either through unfavorable regulations, by being bled dry with legal fees, or through competitive inequality. But what is the point (or fun) of owning a small business if you are just going to be content with the status quo and mediocrity and not at least try to ruffle some feathers?

Existential questions aside, this book made me feel really proud to be part of the independent telecom industry. There is a lot of rich history to learn and discover from the independents, the mavericks, the crusaders, the entrepreneurs and the industry outcasts. My favorite line from this book was a quote from Austrian political scientist Leopold Kohr,

"...Whenever something is wrong, something is too big."

With that, I strongly encourage everyone to read this book. You will definitely spend a lot of time contemplating the stories told in this book and envisioning how the future of the telecom industry will unfold.

Cassandra Heyne
ruraltelecommentary@gmail.com

Monday, January 17, 2011

Objections to the Mobility Fund NPRM: Part 1

With the Mobility Fund reply comments coming out this week, I thought I would go back and review the NPRM and the initial comments before summarizing the reply comments. This should give readers a good overview of my personal telecom policy philosophies because the Mobility Fund NPRM contains a plethora of objectionable proposals for rural telecom advocates.

Background: The Mobility Fund NPRM (In The Matter of Universal Service Reform Mobility Fund, WT Docket No. 10-208) was adopted on October 14, 2010. Basically, the FCC is proposing to use excess USF reserves as a one-time investment in wireless infrastructure, particularly in areas that currently do not have wireless coverage. This means rural areas, low income areas, and areas where the major providers (Verizon, etc.) have determined to not be worth the investment. I won't go through every detail of the NPRM (you can read it here: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-182A1.pdf), but I do want point out some of the main components. The money will come from Verizon and Sprint-Nextel's surrendered universal service funds, it will be distributed via reverse auctions to the bidder who can do the job for the least amount of money, and the winner will be expected to provide at least 3G coverage in the areas identified as unserved. Simple, right? Sure, if you are Verizon, AT&T, Sprint-Nextel or T-Mobile. If you are a rural wireless carrier, don't get your hopes up. Not only are reverse auctions the absolute worst idea ever, but the money will basically just be transferred from Verizon back to Verizon. 3G service will probably be obsolete by the time the money has gone full circle. Finally, the amount of money for this one-time investment isn't even enough to provide coverage in a single state, and there is no plan for ongoing funding once the expensive wireless networks are actually constructed.

Arguments: My primary objections to this NPRM are the reverse auctions, the 3G requirement, and the lack of ongoing funding. I found other issue as well, but these three are especially unpleasant for rural providers.
 

  • Reverse Auctions: I could probably write about my complete disdain for reverse auctions all day, but I will try to keep it short. I strongly believe that reverse auctions will be an absolute disaster, as they have been in other countries that have tried to implement them for telecom systems (example: Chile, India). When you are dealing with a commodity, reverse auctions might make sense because obviously the government should try to keep costs as low as possible and reduce waste, etc. But when you are dealing with wireless infrastructure in an extremely diverse selection of geographies and demographics, you really don't want to go with a mechanism that only rewards low costs. It is also very difficult to compare two completely different wireless networks--such as a LTE and a WiMax network--on costs alone. The government will get what its paying for, as the saying goes. I find this analogy helpful:  I want to buy an airline ticket so I go to Travelocity (or wherever) and put in my dates and destinations. I get back a list of several different airlines, fares and flight choices and I pick the one that costs the least without looking at the details. I will most likely get stuck with several long and out-of-the-way connections, a middle seat in the back, and I won't get the full-fare frequent flier miles from the airline. It will be an unpleasant experience but I will get what I paid for by choosing the cheapest option. If the FCC picks the winner based only on the lowest cost, there are going to be a lot of unpleasant side effects throughout the trip to completing a quality wireless network in an unserved area. The reverse auction process does not identify the best provider for a particular area--which in many cases may be a rural provider. Reverse auctions provide no incentive for quality, which is not ideal for wireless networks. Rural providers do not have economies of scale for equipment that nationwide providers have, so it is highly likely that many rural providers won't even bother participating in the auction, as is often the case with wireless license auctions. I would like to know the cost ratio of wireless infrastructure equipment for a company like Verizon vs. a rural company that only serves a few thousand people, as I suspect it would probably cost the rural company many times more per customer to construct a network in an unserved area. Basically, these proposed reverse auctions will ultimately strengthen the market power of the Big 4, they will not help rural companies participate in the wireless industry, and the wireless networks that result from these auctions will be shoddy at best because the winning bidder will not bother investing in the best equipment for the area in question. The result will not close the Wireless Broadband Gap, nor will it really be beneficial for the customers that live in remote, low income, and rural areas. 
  • 3G Requirement: There has been so much buzz about 4G recently that it is hard to imagine any wireless company would actually want to take a step backwards and pour money into a 3G network. The NPRM proposes that the bidder must be able to build a 3G or better network, but if reverse auctions are used then 3G equipment is going to be much cheaper, and therefore the winners will probably be building 3G networks. Not that there is anything wrong with 3G, if you are just trying to get basic service in an unserved area then 3G is perfectly fine. The problem is that it is very costly to upgrade a network from 3G to 4G, so any company who is currently planning to build a wireless network in the near future should skip 3G altogether as to avoid two very costly investments--3G network operators are going to have to upgrade to 4G eventually to keep pace with innovation and customer demands. 3G networks will not be competitively sustainable in near future, and by the time the Mobility Fund money is actually distributed, the major providers will most likely have 4G (or not-really-but-kind-of-"4G") service in most major markets already. Once again, the rural folks will be stuck with sub-par service.
  •  Lack of Ongoing Funding: The money from the Mobility Fund will be a one-time investment, and it really is not much of an investment at that. There will potentially be $100-300 million available for the Mobility Fund, which may seem like a lot of money, but when you consider the vast Wireless Broadband Gap and how much the average wireless network costs, it is clear that this amount of money is a complete joke. One of the most significant costs for wireless operators is ongoing expenses, and the Mobility Fund will not cover anything except the initial capital expenditure. I did a little exercise in a wireless communications class I took last semester on wireless network costs, and the result was very interesting. For a small/medium sized city like Boulder, Colorado, it would probably cost at least $10 million to construct a citywide 4G WiMax network with approximately 20 towers, using 2.5 GHz spectrum. The ongoing expenses for maintenance, upgrades, tower land rent, etc. could run the network operator up to $1 million per year, or 10% of the initial cost. With only $100 million available, the Mobility Fund would only provide investment capital for 10 medium sized cities, and absolutely no ongoing support whatsoever. So I can't help but ask:
What is the point of even trying to distribute this money? Why not just let Verizon and Sprint-Nextel keep it with an agreement that it needs to be used for 4G investments in unserved areas? Will this money actually "close" the Wireless Broadband Gap? Will any rural provider actually benefit from the Mobility Fund?

I think I know the unfortunate answers to these questions. In Part 2 of this topic, I will review some of the especially interesting initial comments that address some of my fundamental issues with the Mobility Fund.

I would love to hear reader's thoughs on reverse auctions and ideas about how rural providers can effectively get a piece of the Mobility Fund pie--if it is even worth going after.

Cassandra Heyne
ruraltelecommentary@gmail.com

Wednesday, January 12, 2011

About Rural TeleCommentary and The Author

For my first official post, I would like to share my goals and objectives of starting Rural TeleCommentary. Additionally, I will include some slightly humorous/scary anecdotes that have inspired me to try harder to make my voice--and the voice of the rural telecom industry--heard loud and clear in an industry where "the little guy" is very often overlooked, or completely disregarded. Next, I will talk briefly about my background in telecommunications, my education and my career goals; and conclude with a preview of what's to come on Rural TeleCommentary in the near future.

Why Rural TeleCommentary?  It is no surprise that there hundreds--if not thousands--of telecommunications news websites, newsletters, blogs, etc. that already exist on the wonderful World Wide Web, in addition to FCC releases, state commission proceedings, association white papers, and so on. I understand the challenge ahead for me to promote this blog as something that should be frequently checked and read by people in the rural telecommunications industry. This is why I want to try to offer editorial perspectives on FCC decisions rather than just "straight news." I hope to make critical analysis, debate and intellectual discussion a unique and active aspect of this blog. I also want to try to provide useful information, such as comment summaries for relevant proceedings, that people in the industry may find valuable and worth reading.

Now for the background anecdote... Several months ago I attended a telecommunications conference and a reception for a highly respected individual in the telecommunications industry (my former teacher, Dale Hatfield). I had the pleasure of talking to a number of FCC staffers at these events, both socially and in a conference setting. I was completely alarmed by some of the responses I received by FCC staffers when I said that I worked in the rural telecommunications industry. Some looked at me like I was crazy. One made a snide remake about how the rurals have so much money they don't even know what to do with it, hence USF is being wasted by some guy sitting in a barn on a pile of fiber rings. The next day, at the conference, I got into a debate about the future of the rural telecommunications industry, re: funding. Someone from the FCC actually asked me:

        "Do you think all the rural telephone companies should just merge?"

I was appalled. I wanted to say some pretty mean things, but in fear of being blacklisted from future events I calmly explained that the logistics of trying to merge hundreds of small independent companies all across the country is literally enough to make your head explode simply because all of the independents have vastly different corporate structures (cooperative, private owned, family owned, shareholders, etc.) and serve vastly different populations, geographic locations, and demographics. I don't even want to think of what that merger review process would be like, much less how would hundreds of small companies--many of which have existed for over 100 years--decide on a fair and equitable corporate governance structure? So if we make all the independent telephone companies merge, why not make all the independent public utilities merge, then make all the independent grocery stores and gas stations merge, then all the clothing stores, restaurants and movie theaters. While we are at it, how about we have just one big farm owned by one corporation and get rid of those pesky small farmers once and for all. Oh wait, we just became communists. It is a slippery slope, and I was really scared by the fact that someone representing our telecom regulator had actually contemplated the idea of making all independent telephone companies merge. Not only did this person seem completely clueless about the nature of the rural telecom industry, but another also added this little gem:

       "Aren't there only like 1 or 2 rural telephone companies left in the U.S.?"

Once again, I reserved my anger towards this hysterical question and responded by saying no, there are hundreds of independent phone companies that provide vital and state-of-the-art services to rural and remote communities across the country. These companies do some truly amazing things for their communities and at least deserve to be recognized as EXISTING. I do take it a little personal when someone tells me that my family's 95 year old company doesn't exist...and if it does exist, it should probably merge.

The moral of these stories is that although there is an abundance of information available about the rural telecommunications industry, the people who make and contribute to regulatory decisions may not know beans about the rural telecommunications industry. It is therefore up to the rural telecom advocates to make our voices heard. Hopefully, to an audience that is willing to listen.

Cassandra Heyne, Rural Telecom Advocate: I have literally been in the rural telecom industry my entire life. My family has owned and operated Walnut Communications in Walnut, Iowa (population 800) since 1915, and I spent many days during my childhood watching my grandfather do business at the phone company, listening to conversations between my grandfather and father about company strategies, and basically soaking in all kinds of valuable knowledge about how a small phone company operates. My grandfather, Clifford Heyne, is my inspiration to continue the family tradition in this industry. When I was young, he constantly encouraged me to take my education as far as possible and do anything I could dream of doing in telecommunications--law, engineering, management, consulting--anything! After achieving a B.A. in History from the George Washington University, I decided to pursue a Master's in Telecommunications with a focus on telecom policy, law and regulation. I was briefly in the (no longer existing) Telecommunications master's program at GWU prior to transferring to the renowned Interdisciplinary Telecommunications Program at the University of Colorado. Additionally, I earned a Master's in Legal Administration from the University of Denver Sturm College of Law.  Now I am finally on the cusp of completing my Telecommunications degree, once my Master's thesis is complete (more on this topic in a few weeks). I also recently completed a very interesting and valuable internship at a small telecom law firm in Washington DC, where I was able to sharpen my research and writing skills and get into the habit of critically analyzing every proceeding the FCC released during the last few months, and analyzing rulemakings, inquiries and orders from the perspective of independent telecom companies.Prior to this, I worked for a major rural telecommunications advocacy association, and (though sometimes I don't want to admit it) for a "Big 4" wireless company. So now with some extra free time on my hands, I thought it would be an interesting project for me to start a blog on rural telecommunications issues. This blog is partially for me, so I can have a portfolio of written and "published" work to present as I begin the great search for a permanent job in the next few months; and this blog is for my audience--however large or small it may be. I am completely open to feedback, comments, critique, corrections and ideas from my audience, and I hope to eventually have some interesting debates and discussions about telecom policy!

What's Next? Next week reply comments are due in the Mobility Fund proceeding, so I plan to write a very short review of the initial comments that were submitted last month and a more detailed summary of the replies. I was really impressed with some of the initial comments because many respondents came out against the evil proposal known as reverse auctions. I will also provide my own critique of reverse auctions and the Mobility Fund proposal. I would like to tackle my favorite topic of late, Net Neutrality, but I'm still trying to simmer down from my frustration with that whole situation so that article may be a few weeks away. I am also hoping to look closely at some of the technologies presented at CES last week, and do some quick reviews on some of the ones that may be exciting for rural telecom companies.

Readers: Please feel free to submit requests or ideas for how I can reach wider audience! Please feel free to pass this link along to your colleagues! 

ruraltelecommenatry@gmail.com

Until next time,
Cassandra