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|Monday, June 9th, 2014|
|Policy, Anecdotes and the Problem of the Black Swan.
I run into the "you can't make policy by anecdotes" or "anecdotes aren't data" argument so many times I wrote a blog post explaining why individual incidents (e.g., the Comcast/Netflix thing) are important in policy and what the "no anecdotes" rule really means.
Short version: what we have is a failure to appreciate the Problem of the Black Swan -- which has nothing to do with either Nicholas Talibi or Natalie Portman.
|Friday, June 6th, 2014|
|Thursday, May 29th, 2014|
|Trying to get out for reunions, but had to smack a fool and do a filing
Stuck frantically trying to get stuff done so I can get on the road. I should have taken today off, but I agreed to be respondent for an academic paper at a conference put together by Penn State and hosted at the FCC. Because we were operating under 'Catham House Rules,' I cannot disclose who said what. But here are some of my pithier comments.
1. It is disingenuous in a paper where you go on at great length about agency capture rendering agencies inherently unreliable to fail to disclose that AT&T paid you as a consultant in this proceeding. Barring evidence that civil servants are either better rational actors than academic economists, and therefore better able to predict how their positions in regulatory proceedings yield personal rewards, or that academic economists are more virtuous than civil servants, and therefore even direct financial inducements will not sway them, we should assume that "academic capture" is as much a problem as "regulatory capture."
2. You claim that consumer adoption of services like Facebook indicates that consumers are not concerned about privacy and would tolerate elimination of existing regulations protecting the privacy of phone calls. You have taken the fact that many people will exchange some personal information under certain conditions in exchange for access to certain free services and generalized this to a broad conclusion about consumer behavior. This is not empirical evidence. This is a category error. By contrast, the surveys of consumer behavior indicating that consumers differentiate between means of communication based on privacy is
empirical evidence to the contrary.
3. Allow me to demonstrate with a real world example why delivery platform regulation (i.e., regulation of broadband access providers) remains relevant despite competition from over-the-top (OTT) services. In the town of Hopewell NJ, they have no cable provider and no wireless provider. Verizon is allowing the copper plant to age, so that they have no DSL and are rapidly losing even basic voice service. Reading your paper one would think "what morons! Why don't they just switch to Vonage or use Facebook messenger? Oh wait . . ."
4. When you make a general absolute categorical statement, you cannot dismiss evidence to the contrary as "anecdotal." This is known in logic as the case of the Black Swan. If you state "all swans are white," and you are presented with a single black swan, then the categorical rule is demonstrably false. You cannot dismiss the black swan as "anecdotal."
Here, we have a veritable flock of black swans.
5. You have proposed a general framework for regulation. Here are three pressing problems before the agency: How does your framework resolve the problem of rural call completion? How does your framework resolve the question of 9-1-1 geolocation accuracy? How does your framework resolve the question of how to allocate spectrum on an exclusive licensed or open unlicensed basis?
If your framework is only useful for interconnection, then please call it a "framework for interconnection" rather than a "general framework for regulation."
6. Ultimately, this paper is like the romance novels of which my wife is so fond. It contains stock characters following predictable patterns identical to all the other papers in the genre. As with romance novels, I understand that this repetition and predictability are what make it popular with its devoted fan base. Also as with romance novels, anyone foolish enough to model their real world behavior based on them will come to serious grief.
7. You assert that Title II common carrier regulation is what prevents traditional wireline service from competing with wireless, and that as a result 40% of the market has now 'cut the chord.' You are aware that wireless is a Title II service, yes? Does that in any way undercut your argument with regard to the relevance of Title II as a factor?
8. [presenter pointing to a chart showing that wireless prices for voice minutes have dropped since 2000, as graphed against industry concentration in the same period as measured by HHI] "As you can see from this graph, increased concentration in the wireless industry has not led to higher prices."
Me: Alternatively, the graph demonstrates that the DoJ and FCC are correct that an HHI of 2500 is the cut off point, and that the department acted properly in denying the AT&T/T-Mo merger.
It was a day . . .
|Tuesday, May 27th, 2014|
|Monday, May 26th, 2014|
|Back From Ruby Joust
Really want to do a longer write up.
Am annoyed that according to the kingdom calendar, there are virtually no events this summer that meet my criteria of attendability. *sigh* 'Cause every time I go to an event I'm always like 'yes, now I remember why I like the SCA and stuff.' And I think 'I'm totally going to get back into writing poetry and bardic arts and everything.' Then reality strikes.
More later, I hope.
|Monday, May 12th, 2014|
|Friday, May 9th, 2014|
|Well, that was an exciting week . . .
Man, it hasn't been this exciting on so many telecom fronts in years. But it gets pretty exhausting.
I should write more, but still too much to do and got a somewhat late start this morning. *sigh*
|Thursday, May 8th, 2014|
|Tuesday, May 6th, 2014|
|The Difference Between Stubborn Refusal To Quit and Stubborn Refusal to Learn
Am I the only one who thinks the itsy bitsy spider is a total moron? Dude, it's a friggin' drainpipe. You are going to get flooded out again. It is not noble to fail to learn from experience, and stubborn determination to build in a floodplain does not make you brave or noble or any other virtue. It makes you a stubborn idiot wasting your time and that of everyone else who supports you.
By contrast, the ant moving the rubber tree plant is an inspiration and a role model. Because the ant does move the rubber tree plant. It is one thing to dare impossible odds and overcome them by sheer stubborn determination and refusal to quit. It is another thing altogether to stubbornly refuse to learn from experience.
Someday, I'm hoping the itsy bitsy spider v. the rubber tree ant will appear on Epic Rap Battles History. Rubber tree ant
gonna kick some itsy bitsy butt.
|Monday, May 5th, 2014|
|Work has kept me pretty busy since Passover
I just realized I haven't posted here much of late. Been doing short updates on Facebook, but generally just been too tied up in work to post anything of significance. Which is rather a shame, as there is much to talk about.
The short version is, Becky and Aaron doing fine. I'm doing fine, if overwhelmed. Is gonna big a big FCC meeting for me May 15, with lots of important items representing years of work on the agenda
, and more stuff (like Comcast/TWC/Charter) in the background.
Longer version will have to wait a bit.
|Wednesday, April 30th, 2014|
|Friday, April 11th, 2014|
|Why Do We Help People?
Stephen Colbert, at the end of this clip from testifying at a 2010 Congressional Hearing, answers this rather interesting question: why does he take the time to highlight the plight of migrant workers?
This works for me sometimes, but I recently found myself asking that question when tackling a particular problem somewhat outside my usual range. It was not an issue on which I am usually active. I had not intended to address it. I mostly intended to pull together a briefing for some groups I thought would be interested primarily as a solidarity thing.
But now I've taken a bunch of time before disappearing for Passover (and you better believe it is otherwise overbooked) to do a couple of FCC meetings on this and try to straighten it out. So I asked myself, why was I doing this.
The answer I came up with actually comes from Lois McMaster Bujold's character Ivan. In learning the shape of the problem it just seemed so . . . . wrong. Worse, it was stupid wrong. There is no good reason for the people who are going to see their phone bills potentially double over 2 years to have that happen. And, with a modest amount of effort, I may be able to help correct that (or at least mitigate it).
With all the crap in the world, having a bunch of people steamrolled for no good reason just seemed, well, offensive. It annoyed me. To quote Ivan, "this is just . . . really wrong."
Useless bad crap happening to other people offends my aesthetic sense. Good things happening to people is aesthetically pleasing. It is worth some modest effort to create a happier world. Not for any noble reason, but from the purely selfish reason that it makes the world prettier for me.
|Thursday, April 10th, 2014|
|Tuesday, April 8th, 2014|
|Monday, April 7th, 2014|
|Sunday, April 6th, 2014|
|Thursday, April 3rd, 2014|
|Thursday, March 27th, 2014|
|It's a long way home
And I won't get there by running.
Which is a quote I always love, even if I am using it totally wrong.
Air travel in this country just keeps getting worse and worse. Am now stuck in a crappy hotel in Dallas due to equipment failure that prevented me from making my return flight to DCA.
Happily, I always carry an extra pair of undies and more kosher food than needed because it is hard to find.
Hopefully home tomorrow.
|Monday, March 24th, 2014|
|Need heraldry help
Someone asked me to blazon the Public Knowledge logo.