It's time for the NOFA Awards!

No, not the actual giving out of money, silly. My snarky commentary on yesterday’s unveiling of

I’ll preface by saying I absolutely still love and respect the folks I know on the inside who struggled with this stuff for months. I know how hard it is to actually implement this stuff, especially with this kind of ridiculous schedule and no one appreciating what it takes to coordinate among this many agencies and how utterly devestated the federal workforce was following 8 years of the Bushies refusing to invest in information technology, outsourcing everything to contractor cronies, and elevating political loyalty over actual talent.

Nor do I have much patience with those who are all “they sold us out blah blah blah . . .” Engineers don’t whine about how unfair it is that trees bloom in the spring and screw up line of sight with their leaves. You deal with it. Same in politics. You want good policy? Then you roll up your sleeves and get ready to fight for it rather than whining like little babies about how Obama the Deliverer failed to smite our enemies for us or persuade incumbents to put the public interest over their corporate interests and magically made all the problems of getting human beings to cooperate with each other go away. Because unless you’re willing to make some actual phone calls to members of Congress like Dittoheads do when Rush gives them the word, then I don’t want to hear it.

And the fact that there are some real issues does not negate all the good this NOFA will do. Anyone who claims that getting a less than perfect result means we pissed this away and it’s just as bad as Bush and blah blah does not know what they are talking about. I’d rather have this than more hymn singing from the worshipers of the gods of the marketplace. The fact that this turns out to be incremental rather transformative, a stepping stone rather than the whole edifice, doesn’t make it crap.

And finally, I promise to do real deep policy analysis soon.

But my selfish indulgence in unfair snarkiness below . . . .

In the category of . . . .

Biggest Policy Win:
The return of Computer III interconnection requirements. Kevin Werbach is in the House Commerce Department! Will the FCC follow up and adopt the rules the countries that are kicking our ass on BB stole from us?

Biggest Policy Screw Up The introduction of “managed services.” In theory, allows services like telemedicine to get dedicated capacity without resorting to “tiering” that is anathema to network neutrality. In reality, is great new way for incumbents to privilege their own VOIP and video services over traffic of others.

Best Issue They Got Right That Everyone Else Thinks They got Wrong: Speed. I am in the minority in thinking they played this right. There are too many good projects potentially excluded by allowing only speeds of 45 mbps or better (what the House originally proposed). I dislike relying on advertised speed rather than actual speed, but that problem needs to be addressed globally because trying to enforce it here is too damn difficult.

Biggest Telco& Cableco Win Criteria that skew to rural. Sure, they did not totally screw over urban in the way NCTA and others urged by prioritizing “unserved.” But the fact that any last mile project can only serve “underserved” or “unserved” and the “underserved criteria” effectively eliminates any major project in a big city like San Francisco. They are not completely ignored, because they can get public computing center or digital inclusion crumbs. But the criteria as adopted ensure that there is no chance of a real competitor emerging to existing providers and no embarrassing pilot projects anywhere folks subscribing for $50/month for 7 mbps advertised can see.

Most Perverse Political Result Once again, this ends up being a Blue State to Red State subsidy. It’s also amusing to see the Administration with the “urban agenda” following in the footsteps of every other administration to suck up to dispropotionately important rural Senators. Urban League needs to get in line behind Lambda for a room at Heartbreak Hotel.

Best Aspect of Implementation Scoring system designed to encourage Applicants to put their best package forward, not just try to cover all the minimums.

Worst Screw Up In Implementation: The artifical break between last mile, middle mile, public computing, and innovative programs makes producing the integrated programs that Commerce say they want very difficult. Also, the documentation of underserved by census block will be a real bitch and a half for everyone but incumbents. More weighting against urban last mile projects.

Easiest Way To Correct Anti-Urban Bias: Don’t require fiber run to community anchor institutions to be in underserved areas. Any community anchor institution should be eligible without the need for census block data. Holy Cross hospital down the block from me could use a 1-gig fiber line.

Biggest Unknown: Who is the contractor from the mysterious solicitation a month and a half ago who will screen applicants? If it’s Halliburton, we are in real trouble.

Applicants Most Likely To Succeed: From my reading, the best applicant would be UTOPIA with a public safety element or projects such as Wally Bowen at MAIN. Go Wally!

Applicants Least Likely To Succeed who Should Succeed: City of San Francisco. So much for rivaling Japan and S. Korea.

Tea Leaf Award for Next Most Likely FCC Issue Based on The Priorities Here: Special access, roaming, and other “middle mile” issues.

Biggest Secret Winner: Big Cablecos. No possible competitors and never wanted to expand into low return areas anyway. On policy, if my prediction is right, they will benefit from special access reform but TV Anywhere is now a “managed service” they can prioritize over other video traffic. Unlikely to ever actually have to provide real interconnection, owing to Return of the Cable Lapdog now playing at FCC — which has given cable a series of wins in the last few weeks.

Stay tuned . . . .


  1. Harold, some of the provisions for which you are cheering — in particular, the overbroad “network neutrality” requirements — are very likely to make rural buildouts difficult or impossible. Users want reasonable prices, and these cannot be achieved unless usage of bandwidth is optimized. As a result of these ill-advised requirements, you’ll see 768K broadband for $76.80 to $100 per month — more than most rural residents can afford. I suppose the good news is that providers who don’t take the money for last mile infrastructure will be able to undercut this. The bad news is that the subsidized projects will be unsustainable and will fail.

  2. Harold, your comments are as close to the truth as any I have seen. I would only add that if you believe the maps that most of the states “Officially Designated Mapping Contractor” have been circulating, you would wonder if the US isn’t already the world leader in Broadband Services. “Three homes in a county can get 256 Kbps, well, color that whole county as Broadband Served” No matter that even the US definition of Broadband at 768 Kbps is fifty to two-hundred-fifty times slower than the rest of the world counts as minimal broadband.

    Everyone knows that the only rational way to build broadband networks is to orchestrate a quantum leap in broadband speeds, starting in the most dense urban areas which must serve as hubs for the “unserved and underserved” rural areas. Have we forgotten that this is called “The Internet” not “Connectivity Islands” scattered across a country whose connection speeds are the slowest and most expensive in the world.

  3. Harold – love your right on comments.

    The NOFA has plunged us into classic “perfect is enemy of the good” situation. Too many commentators are hung up on the fiber to home model. This won’t work in rural areas, so there has to be room for a wireless broadband option, and heaven knows, the experts do not have this figured out. We need patience. In Bell divestiture, how many years was it before we discovered that long distance was a broken business model? At least fifteen. Cable business model is going south minute by minute, so any joy they have over the NOFA is temporary respite.

  4. Harold –

    Appreciate your comments and analysis. And the comments from Mike regarding the perfect “being the enemy of the good.” So much to do now to use what is here and go on to lobby for something better in round two.

Comments are closed