February 5, 2007

 

Mayor Gavin Newsom

Members of the Board of Supervisors

Department of Telecommunications and Information Services (DTIS)
City and County of San Francisco
Room 244, City Hall
1 Dr. Carlton B. Goodlett Place
San Francisco, CA 94102-4689

Re:      San Francisco Municipal Communications Services Efforts

Dear Mayor Newsom, Members of the Board of Supervisors and DTIS:

This open letter is to provide respectful input into decision-making regarding the City and County of San Francisco's engagement in providing municipal communications service alternatives to the citizens and guests of San Francisco.

 

High-speed Communications Infrastructure is strategically important:

 

Most people now depend on communications technology for individual and organizational productivity.  Landline and mobile voice communications are working reasonably well.  However, we increasingly use computers and other networked devices to do work and access information and services to conduct our lives.  We need these devices to communicate with others efficiently, increasingly with rich media that require high-speed (multi-megabit per second) connections, and increasingly from locations other than our homes and/or offices.  Having high performance and affordable high-speed communications options is strategically important to individuals, businesses, and society - for productivity, competitiveness, education and economic performance, at the Federal, State and local levels.  Information and Communications Technologies enable contributions in all industry.

 

High-speed Communications Infrastructure Needs are Not Being Adequately Met:

 

Telecommunications in the United States is largely a broken industry. Industry consolidation and unfair competition have reduced choice in the marketplace, industry regulation has become lax, and marketing spin, litigation and legislation for marketplace advantage have largely replaced investment and innovation.  Despite myopia assuming the U.S. leads the world in communications technology, we are, in fact, far behind many other nations.  In recent studies, the U.S. is ranked something like 15^th in the world in penetration of advanced communications services to citizens.  Absent major changes, we can expect to fall even further behind.  Many applications of technology and productivity improvements are now constrained by lack of adequate first-mile/last mile bandwidth. 

 

This Problem is Not Being Solved at the Federal or State Levels:

 

The best way to deal with this issue is with coherent and competent national telecommunications policy.  However, there is no indication progress will be made in that arena soon.  On the contrary, at the Federal level the Telecom Act of 1996 has been a dismal failure, and, with some exceptions, Federal momentum has been primarily behind giving dominant monopolists/oligopolists more power and freedom to extract profit from our society with less insistence on serving public needs well. 

 

Similarly, it appears unlikely that comprehensive policy to correct this situation will happen at the State level any time soon.  Despite a 2004 study through the CENIC "Gigabit or Bust" initiative indicating 2 million new jobs and $376 billion in increased Gross State Product resulting from a comprehensive upgrade to high-speed communications infrastructure, so far California has done nothing, except make it easier for monopolists/oligopolists to execute their strategies for profit in the State.

 

Municipalities are Confronting These Issues by Default:

 

Because of failures at the Federal and State levels, municipal government is being confronted by complaints from citizens and requests for help in solving demands for:

 

• Simple, affordable, high-speed Internet connectivity everywhere
• Simple, affordable, high-speed connectivity between locations in a metro, including connections to ISPs, ASPs, content providers and data centers
• Assurances privacy is respected and personal information remains private
• Assurances access to the public Internet or other reasonable use of the network is not interfered with by government or profit-seeking enterprise
• Programs or policy to provide these essential services to people who can't afford them or to people and businesses ignored by phone and cable utilities
• Protection from intrusive advertisement
• Efficient management of telecom/cablecom construction to limit damage to public assets (eg streets) and interference with transportation and commerce
• Confidence our communications infrastructure is optimally implemented for the maximum benefit of society, rather than the enrichment of minorities
• Strong oversight on behalf of society, public and consumer interests
• Solutions that maximize benefit to local society and economy, by utilizing local labor and services, and keeping money and multiplier effects in local economies, rather than being taken out of our economy and sent elsewhere
• Solutions that work, because people who work on them are part of the public they serve, taking pride in their work, not outsourced, cheap labor abroad

 

Overarching Motivation and Guiding Principles:

 

Please keep these citizens' demands and interests in mind as you work toward a solution for what San Francisco will do to respond to them.  Take time to interview your public and hear their demands and desires.  Revise the list above or create another, but determine the problems you are trying to solve and the guiding principles you will adhere to in the process.  Understand why these demands are not being met by current profit-seeking market solutions and use that understanding to evaluate future solution proposals and their costs, benefits and risks.

 

Prioritize your goals and principles and make them known.  Understand when they conflict with each other and make choices between those (e.g. free and for public benefit versus at a profit to the City).  You represent the whole society of San Francisco.  Please view everything from the perspective of San Francisco society and work for optimal solutions for San Francisco society.

 

Problems With Current Market Solutions:

 

As we previously understood in developing our society's telecommunications infrastructure, the provision of local wire-line telecommunications services is a natural monopoly.  The needs of society for wire-line communications infrastructure are most efficiently provided with a comprehensive solution that provides for everyone's needs once.  It does not make any more sense to build multiple local communications transport networks than it does to provide multiple water, sewer or electrical networks in a city.  Do it once and do it right.

 

Nobody expects multiple water companies to compete for profit by bringing multiple water pipes into their homes and businesses when it is only necessary to bring in one water pipe to meet all of a family's or business's needs for water.  Nobody expects multiple sewer, electric or gas companies to compete for profit by bringing multiple sewer pipes, electrical or gas lines into their homes and businesses - especially bringing multiple pipes into some locations and leaving other locations un- or under-served.  Why would we expect to need multiple providers of converged communications pipes to each bring separate physical infrastructure into homes and businesses to provide for family's or business's converged communications needs?  Why would we accept multiple communications lines into some locations and none into others, in a gross misallocation of resources from the perspective of society?

 

Understanding that, our society previously, wisely decided to award exclusive rights and privileges to regulated utilities to provide essential public infrastructure to citizens.  Each of those industries is overseen by regulators, because a monopoly is inherently subject to abuse of monopoly power.  Profit-seeking monopolists have a natural incentive not to invest in innovation and improvements, charge higher prices than necessary to provide their essential services and play other games that benefit the monopolist but cost society.  It is the job of regulators to make sure utilities do a good job, serve everyone, don't abuse private information of citizens, upgrade their infrastructure and services to meet the evolving needs of society, and ensure utilities receive adequate and fair but not excessive compensation for doing so.

 

For some reason, our government decided to forget most of that in the telecom industry.  Emboldened by the emergence of competition in long-distance networks, which are not necessarily natural monopolies if local utilities provide local access to customers, they came to believe that it was possible to create competition in local telecommunications markets, despite being natural monopolies.  Unwisely, they largely deregulated local communications markets, based on the emergence of competitive local service providers, many of them long distance companies acting as incented to act by government. 

 

However, those competitive companies were mostly unable to overcome the natural barriers to entry of the enormous capital costs required to recreate networks which incumbents built over decades with the full cooperation of society, with guaranteed returns and no competition.  Other barriers to entry included being held up for use of public rights of way and being held up by building owners demanding exorbitant terms for entry into their buildings, which they did not charge the incumbents, delays and more difficult or expensive terms for permits for construction, and being upstarts against entrenched, established and respected "public utilities."

 

In its deregulation efforts, the government required telephone utilities to "share" their local communications access networks, offering to competitors at wholesale rates the same communications lines they used for retail services.  As soon as adequate competition in local markets was established, local phone utilities would be allowed to offer long-distance services, which had been off limits to them. 

 

Being a natural monopoly wholesaler and retailer is inherently conflicted.  Naturally, the natural monopolists abused (intentionally or unintentionally) their wholesale roles, delaying the provisioning of services, making it difficult to make deals for wholesale services, making special requirements of wholesale customers they did not require of themselves, demanding expensive and complicated systems integration efforts...  They played with being a wholesaler until government was satisfied that acceptable levels of local competition had been established.  Then, they were allowed to enter long-distance markets, where they decimated and took over most of the established long distance companies, which withdrew from local market competition.  They also became less cooperative with wholesale customers, which mostly went out of business.

 

Today, there are few long distance and few local service providers, other than the local telephone and cable monopolies.  There is also significantly less regulation, oversight of the monopolists, who are behaving or beginning to behave exactly as one would expect a natural monopolist to behave:  skimping on infrastructure and service improvements, raising prices, abusing customer information, engaging in predatory pricing, deploying services only to the most profitable areas, restricting uses of the network and outsourcing local jobs and customer services elsewhere to lower costs (damaging local economies). 

 

The new AT&T (SBC's purchase of the old AT&T and Bellsouth) basically reconstitutes the old Bell Company monopoly in roughly half the United States.  The rest of the US is shared by two other phone company monopolies.  Sprint is the only remaining major retail long-distance telephone service network operator that has not been consumed by a local monopoly, except Sprint is mostly a wireless company now.  A handful of cable TV companies cover most of the U.S.

 

Actually, in the residential market, we mostly have a duopoly, a cable TV company and a phone company.  Each has a natural monopoly on its physical wire network.  However, each is penetrating the other's markets, by offering competing services over its own infrastructure.  Cable companies are adding voice and other value added services.  Telephone companies are adding video content services.  Both are offering Internet access services. 

 

Some argue this duopoly structure is enough competition for free market forces to adequately provide for society.  Our standing in the global race for penetration of advanced communications services proves that wrong.  Each just has to provide services competitive with the other, not services adequate for society.  Consumers usually have almost no choice but to buy from one or the other, so they are stuck with one or the other, even if that is inadequate.  Both have so much market power they have their way with regulators and government, with little resistance.

 

The few competitive local service providers remaining are all profit-seeking enterprises.  Rationally, they don't try to provide service to everyone.  They cherry-pick the market, going after the most valuable customers, businesses and residences which consume lots of communications services.  Incumbents lose their most profitable customers, which makes it more difficult for them to justify serving their least profitable customers.  Incumbents try to do the same, going after the most valuable customers and abandoning others. 

 

The previous regulatory principle of "Universal Service," meaning everybody gets the same service at the same price, no matter where they are or what it costs to serve them, with less expensive locations subsidizing more expensive locations, is being ignorantly discarded, despite serving our society well.  Businesses able to pay typically have better services options, better performance, lower prices, more competition…  Consumers and businesses in the wrong locations or with little money have few, low performance choices.

 

Right now, San Francisco citizens are limited to a couple of megabits per second of bandwidth in their homes from wire-line connections and something like 300Kbps to 2Mbps for cellular data services.

 

There's more to the story, but the industry is broken, due to poor government decision-making and a collapse of regulatory oversight.  It's really not the phone or cable companies' fault.  They are just as confused and mis-served by broken telecom policy as the rest of society.  They are behaving the way they would be expected to if they were competitive, for profit enterprises.

 

State of the Art Communications Technology:

 

The best communications media today is optical fiber, when it is available.  By manipulating laser light through optical fiber, it is theoretically possible to carry every telephone conversation happening in the country right now on a single pair of optical fibers, each about the size of a human hair. 

 

Fiber is mostly immune to electromagnetic radiation effects that can interfere with communications over copper wires.  It is more difficult to tap undetected.  Out-of-the-box communications over fiber at 1 gigabit per second (Gbps), 1,000 times faster than the "premium service" proposed by Earthlink, are easy.  Communications carrying capacity on optical fiber can be radically increased by deploying more advanced electronics (10Gigabit Ethernet, xWDM, SONET), so it is a largely "future proof" media, lasting at least 20 years.  For example, it is feasible to carry forty,10-Gigabit per second wavelengths on a single pair of fiber right now.  That's 400 Gbps, 400,000 times faster than Earthlink's Premium service on a single fiber pair.

 

Really, we should be replacing all of the copper wires in San Francisco and in America between homes and businesses with fiber.  That's the critical infrastructure upgrade most appropriate for our society.  We should have a network operator responsible for local transport only (layers 1 and 2 of the OSI model), and we should allow as many service providers as want to compete (with content or layer 3-7 services) to provide advanced communications services over that transport network.  The transport network operator should not be able to provide any services to anybody other than transport, and as a natural monopolist, that transport network operator should be tightly regulated.  The City could be or hire that network operator.

 

Congratulations on finally getting a completed fiber study!  CTC did a good job.  That provides a great tool for the tool chest in planning and communicating what to do with high-speed municipal communications.  One suggestion:  become more aware of IPNetworks, a San Francisco based service provider with rights to use PG&E assets to deploy fiber infrastructure to deliver advanced communications services.  The City might consider partnering with IPN in a fiber network deployment, or for very reliable, high performance backhaul of wireless network services.

 

"Broadband" is a term that has no meaning, other than "faster than 56Kbps dial-up POTS modem service.  The FCC definition of symmetrical 200Kbps is meaningless.  Nothing less than 1Mbps is worth any planning or conversation whatsoever.  Drop the term broadband.  Describe the bandwidth (e.g. 100Mbps service).

 

A good measure of how much bandwidth a metro transport network should be able to deliver is the bandwidth of the standard Ethernet port on the back of any inexpensive computer.  Right now, that's 100Mbps.  That doesn't mean everybody needs 100Mbps, but there are rich media applications San Francisco would benefit hugely from that could consume 100Mbps, and some power users could use that bandwidth today.  By the time any municipal fiber network is completed, 100Mbps won't be too much.  100Mbps is available today in some other countries.  However, design for the future, not the present!  By the time anything gets done, the Ethernet port on the back of a cheap computer may be 1Gbps.  The same fiber carries 1Gbps as carries 100Mbps; just plan to home-run fiber into every home and business.

 

The problem with fiber, of course, is that it's a big, expensive job to replace all of the legacy copper plant with fiber, roughly half a billion dollars for San Francisco, though that cost might be lowered with a sharp team implementing the changes.  The time and money required are intimidating.  However, it's less than $1,400 per San Francisco household ($500,000,000/360,000 households) as an investment in the future that will lead to better lives, more and better jobs and a better economy!  Not so intimidating if viewed in that way, is it?

 

Use a fiber network for backhaul of wireless signals, so access speeds for wireless users are maximized.  Put wireless network radios everywhere they are needed, as densely as needed, to create the desired mobile network user experience, but do as much backhaul as possible via fiber to maximize wireless system performance.  (It is common for San Franciscans to own an 802.11g wireless router today, with 54Mbps of throughput between the computing device and the router.  However, the DSL or cable modem, through which traffic is backhauled to the public Internet, is typically only a couple of Mbps, so access radio capacity is wasted getting to the Internet.  Eliminate those chokepoints.)

 

At the very least, consider having the City provide fiber connectivity for City institutions and services, schools and hospitals and non-profit enterprises that promote high-technology industries in the City.  The City should be able to use "conditioned" and previously installed fiber for those purposes very cost effectively, lowering costs for those services and keeping the money expended for those purposes in the City, for the public benefit of San Francisco.

 

If Fiber Is So Great, Why Are We Talking About (802.11) WiFi?:

 

The U.S. government regulates the use of the electromagnetic spectrum, selling rights to most of it to the highest bidder.  WiFi uses pieces of that spectrum that are available to the public for unregulated use.  WiFi is cheap and it uses available spectrum.  For that reason, people are flocking to it as the only tool they think they can afford to solve problems not solved by coherent communications policy at the Federal and State levels. 

 

What's Wrong With WiFi?

 

Nothing is wrong with WiFi.  However, because it is not regulated, and because it is the only option for so many, there is contention for use of WiFi spectrum.  San Francisco is already one of the most unwired cities in America.  According to Civitium's report to the City, there are already almost 30,000 WiFi access points available in the City, about 550 per square mile, each already using the spectrum the City would use for WiFi service.  Multiple users of that spectrum create contention and collisions of signals in that spectrum, creating interference and performance degradation problems. 

 

Other forms of electromagnetic interference also affect radio performance.  Everyone experiences problems with reception of radio and television broadcasts.  Radio communications are subject to natural and manmade interference and are much less reliable than fiber optic communications, for example. 

 

Those issues can be mitigated by efforts to coordinate use of WiFi spectrum and utilizing licensed spectrum for backhaul in San Francisco.  However, the City cannot prevent users from jamming WiFi signals, intentionally or unintentionally, and it cannot prevent other service providers from also trying to use the same spectrum to provide competing services, which could degrade performance for all.

 

WiFi is a low-power solution designed for access in relatively short ranges.  That's good from a health perspective.  Electromagnetic radiation levels are low, limiting health risks.  However, it means signals degrade quickly, making it difficult to assure signal strength and quality of service.  (Most users have probably experienced already how signal strength varies just by moving their laptops from room to room in WiFi enabled buildings.  WiFi signals have trouble penetrating walls, and it is therefore difficult to get signals from outdoors to indoors without a bridging device.

 

Wireless technologies are a bit of a dark art.  Everyone knows radio signals vary in strength as they drive around in cars.  (Signals lost in tunnels, near electromagnetic radiation sources, or in coverage "holes)  It's hard to make a wireless solution work well everywhere, and it will not work as well as a wire-line solution everywhere.

 

San Francisco could quickly and cheaply provide a good enough, ubiquitous outdoor WiFi network solution to help with digital divide issues and other unmet citizens' demands and desires, though.

 

Is the Earthlink-Google Deal a Good One for San Francisco?:

 

The Earthlink-Google deal has several things going for it:

 

• It has been negotiated and could be implemented fairly quickly if approved
• The City does not have to spend any money for it
• The City would probably realize some revenue from it
• Both Google and Earthlink are well-funded, so they can pay for the network
• There is a 300Kbps free level of service available to everyone
• Both Google and Earthlink have experience with WiFi networks
• The Tropos and Motorola equipment solutions are proven

 

The Earthlink-Google deal has several issues:

 

• The process of selecting and negotiating the deal has been tainted by not completing fiber or wireless feasibility studies and adequately analyzing all alternatives before issuing the RFP, by unproven perceptions of behind closed door dealings, and by inadequately engaging the community to gather its needs and desires and its buy-in on the process and solution.
• The deal sets Earthlink up as both the wholesale and a retail operator of the network, the same natural monopoly conflict that was so disastrous in local telephone company de-regulation.
• Users of the service are still justifiably concerned about the privacy of their personal information.
• Users of the service may be subjected to unwanted advertisement.
• 300Kbps of free service is still very slow.
• The costs of providing and managing subscription services on the network add very significantly to the overall costs of the solution to San Francisco society and degrade solution performance.
• As a profit-seeking enterprise, Earthlink is motivated to seek paid subscribers and deployment of services in areas already well-served by incumbents before serving areas where the public is un- or under-served.
• As a profit-seeking enterprise, Earthlink may be motivated to make money misusing the personal information of San Francisco citizens and guests.
• Earthlink may well be beaten up in the marketplace (by wire-line, cellular, competitive WiFi, emerging WiMax, like Clearwire, or other service providers) and rationally decide to pull out of San Francisco, leaving the City stranded.
• Earthlink management may change, or it may be taken over (as so many are) by others less motivated to serve San Francisco well, resulting in issues.
• It will be difficult for Earthlink to adhere to Service Level Agreements (SLAs) with a WiFi based service.
• 1Mbps Premium services for San Francisco only are already inferior to wire-line and many cellular alternatives for the price suggested.
• San Francisco appears to be as motivated by trying to make money on the deal as Earthlink, so it may inadequately regulate Earthlink and allow Earthlink to act in profit-maximizing ways that do not optimally serve San Francisco society, citizens and guests.
• Minimum average speed language in the agreement makes it possible for the user experience to be far worse than the paltry 300Kbps promised.  (Usage in the middle of the night skews the average, where performance during peak periods may be much less.)
• By the time the agreement gets ratified, the proof of concept is complete and the network is implemented it may already be technically obsolete.
• Earthlink is not required to wholesale service for less than a month in term, meaning there is no competition for hourly, daily, weekly users.
• There is no assurance that the wholesale prices Earthlink would charge would be low enough to enable a wholesale customer of Earthlink to complete with Earthlink in the retail market.
• The agreement requires paying customers to opt out of marketing and sales pitches and of allowing Earthlink to sell or share their personal information.
• The agreement does nothing to protect the personal information of non-paying users of the free level of service.
• The City offers Earthlink absolutely nothing in terms of commitment to use the network and be a paying customer itself, increasing risk to Earthlink and risk of failure of the overall venture, and reducing the overall public benefit.
• The overall solution isn't particularly progressive or interesting, which the world expects of San Francisco, with its progressive, tech-savvy reputation.

 

Are There Alternatives To The Earthlink Agreement?:

 

If the City decides it wants to pursue a paid subscription model to finance a WiFi network, consider participating in Wireless Silicon Valley.  Wireless Silicon Valley proposes to cover some 42 communities and 1,500 square miles of the South Bay and peninsula with WiFi.  Cisco, IBM, Intel and San Francisco based SeaKay are among the parties involved.  Subscribers to the service would then have a coverage area much broader and more useful than coverage for San Francisco alone.

 

Are There Other Models Worth Considering?:

 

It is very encouraging to see the Board of Supervisors Budget Analyst report on the fiscal feasibility of a City-owned wireless network.  Too bad it wasn't done before the RFP.  It provides another excellent tool to use in planning, decision-making and communications for City telecom services solutions.

 

The budget analyst estimates a ubiquitous WiFi network could be built and operated for a year for a one time cost of $6-$10 million.  Ongoing maintenance and operation of the network might cost $2 million.  Budgeting for equipment/technology replacement might add another $1.5 million annually.  That's about $28 per household one time ($10,000,000/360,000 households) and less than $10 per year per household for ongoing operations, maintenance and technology upgrades.  That's cheap.

 

A serious flaw in San Francisco's process to date is that it has pre-supposed that a subscription model is best, that the best way to pay for the network is to have individual subscribers pay for service, and that somebody should have a shot at getting rich on the deal.  A subscription service model adds serious cost to the overall solution from the perspective of San Francisco society.  It requires the set up and operation of systems and organizations to manage commercial customer relationships, do customer billing, do collections, do complicated accounting, track service level agreements, market and sell services, manage and provide benefits for additional personnel… 

 

Multiple level of service subscription services also degrade network performance.  Technical solutions have to be layered onto the network to segment traffic, rate limit users according to their paid tier of service, monitor service level agreement performance…  Those elements add complexity and cost and degrade the overall performance of the network from the perspective of society. 

 

The wholesale model also adds complexity and costs to the network, for staff to negotiate and manage wholesale customer relationships, for interconnections with wholesale customer service provider networks, for systems integration between the network provider and its wholesale customers, for wholesale billing, collections, accounting, audit, service level agreement enforcement…  From the perspective of society, that makes it more expensive than just putting it out there for free.

 

All of those additional elements add unnecessary complexity and cost to the overall network from the perspective of San Francisco society, and much of the additional money taken from subscribers in San Francisco for those purposes goes elsewhere, to Earthlink operations, staff and investors elsewhere, rather than staying in San Francisco for the benefit of the San Francisco economy.

 

From the perspective of society, profit is also an unnecessary expense with a subscription-based solution provided by a for-profit enterprise.  Profits are money spent on the solution that are unnecessary to provide the overall solution to society, and that money also leaves and does not benefit the San Francisco economy.

 

Even the budget analyst's report assumes a need for subscription services.  Free is free!  Just put the network out there as an amenity to citizens and guests of the City on a best efforts basis.  Don't rate limit anybody.  Let IP share bandwidth between users on the network at any given time.  If there are few users of the network in a given location, a user will get better performance than the limited bandwidth of a rate-limited subscription service.  If there are lots of users in a given location, performance is shared between those users.  With no performance guarantees and appropriate communications and setting of expectations, that's OK.  It makes the network simpler and less expensive.

 

There are individual citizens in San Francisco who could just write checks for the whole network and its operations.  There are certainly corporate citizens who could simply pay for the whole thing.  So could the City.  Give San Franciscans an opportunity to say whether they are willing to pay for the solution, via general funds, property assessments or bond financing.  San Francisco government could just pay for the system, with less than 1% of its overall budget.  Offer the service free as a City amenity to all citizens and guests of the City.  The stimulus to the economy should more than make up for the costs.  San Francisco would be a more appealing tourist, convention and business location, attracting new hotel, convention and service revenue.  Telecommuting and mobile work would be enabled, reducing traffic and traffic related expenses and inefficiencies, benefiting the economy. 

 

An appropriate model for such a free network is the public library.  Libraries give citizens an ability to access books, magazines and information, even if they cannot afford to purchase them individually.  They allow users to share costs for books, magazines and information, rather than inefficiently each having to purchase everything and then leaving those assets dormant or discarded with they've been used, rather than reusing them.  Libraries don't put bookstores out of business any more than a free WiFi network would put commercial network service providers out of business.  The message to industry is "We welcome you to come provide advanced communications services in our city.  However, to be commercially successful, the services should be better than what our citizens already get for free." 

 

Business users would continue to purchase services from communications service providers, because they require or desire better performance than what would be provided by a free network and because they have plenty of alternatives.  Business travelers would continue to purchase mobile data and voice services, because they already purchase those services and need them to work in other cities, where free service is not available.  Many households would continue to purchase services from AT&T and Comcast, because those services perform better and more reliably than the free service would.  Citizens and guests would always have an ability to get on the Internet, though, anywhere in the City.

 

Are There Other Advantages to a Free, City-Owned WiFi Solution?:

 

If the solution is offered for free to everyone, the City could then utilize "conditioned" conduit, fiber and copper infrastructure assets to provide backhaul services, improving overall solution performance.  The City has many rights to assets such as these that are restricted to City or non-commercial uses.  If the network is installed and operated as a free City service, those assets could be relatively inexpensively used.  For example, extra fibers on the entire 36 mile fiber ring installed for City College of San Francisco could be used for WiFi backhaul.

 

In a City-owned model, revenues demanded of Earthlink for pole attachment and other use of asset rights could be eliminated from the overall cost of the solution.  San Francisco already owns those assets, and it would cost the City little to nothing to utilize them for a free WiFi network.  Eliminating City use of asset revenue and profit sharing costs would further reduce the overall cost from the perspective of San Francisco society.

 

As the Budget Analyst Report indicates, if the City owns its WiFi network, there are significant opportunities to reduce City operating expenses paid to outside service providers for T-1s and other data and voice transport services.  Over time, those cost savings could cover perhaps half of the total operating costs of the network.  Regardless what it does, the City should look for these cost avoidance opportunities.

 

City-ownership would create additional possible efficiencies, such as sharing costs for installations, power supplies and battery backups for collocated equipment used by SF TechConnect and for equipment used for City emergency services or Homeland Security.  San Francisco already operates a Network Operations Center (NOC) which could be used for the WiFi network.  The City already has staff which could be utilized to install, operate and manage the network… - all reducing costs.

 

With a City-owned model, it would be extremely cost effective for the City to make use of the network to improve its delivery of City services. Such applications might include e-government services, realizing efficiencies with its mobile workforce, emergency communications services in the event of an earthquake, traffic management and enforcement, public transportation improvement, bus and Muni service information kiosks, automated meter reading solutions, improved tourist services, video surveillance for high-crime areas, and streamlined, anywhere-anytime access to information services.  San Francisco would benefit immensely from having a vehicle in place which City departments could use to effectively deploy advanced public service applications at small incremental costs.

 

As a true public-interest, public network, the City would not have to collect, disseminate, sell or use any personally identifiable data about any individual network users for any purpose, unless required by law.  There should be at least one network alternative in the City that adamantly supports a user's right to privacy.  As a public, not-for-profit government, the City would have no perverse motivations to collect and sell such information for profit or to conceal user data collection and dissemination practices from the public. 

 

A City-owned network would promote job creation, business growth and economic development in many ways.  First of all, it could hire and train local staff and contractors for the installation, maintenance and operation of the network.  It could utilize students in that effort, so they could obtain real world work experience that turns into jobs for them.  It could stimulate businesses and jobs for the business need of creating transitions from outdoor to indoor network coverage.  Enhancing high-speed communications options in the city is a direct stimulus to the economy, because that enables job functions and reduces the need for travel to work.  It would be an incredible amenity to visitors to the city, stimulating travel and events in the city.  It would encourage businesses to locate and/or continue to operate in San Francisco, because of increased, affordable communications technology.  It would enable productivity in transit and while waiting for many.  It would stimulate electronic commerce because of the extremely high level of connectivity…

 

By covering all of San Francisco with free wireless communications, the City would cover all of the schools and educational institutions in San Francisco, as well as all the resident faculty, staff and student homes in San Francisco and everywhere anyone associated with an educational institution would be in San Francisco.  By making the service truly free to everyone, connectivity would be affordable for many who would not otherwise be able to pay for it.  There are many, many applications that could be developed to take advantage of that vast improvement in connectivity, including online access to classroom instruction for students at home (sick), an ability to review electronically anywhere recorded classroom instruction, remote/distance learning, distributed classrooms, online access to electronic content, online language laboratories…  Avoided costs to outside communications service providers would help strained education institution budgets.

 

Ubiquitous network connectivity would allow healthcare workers to interact electronically between any locations in the City at any time.  That would enable home healthcare workers to quickly transfer information to administrators and other experts not available in patient homes.  It would create the possibility of online submission of patient orders and prescriptions by authorized healthcare personnel at any time and from any location (the golf course ;-).  It would make possible the transfer of medical records to specialists for assistance in real time, regardless of that healthcare worker's location in the city.  It would enable telecommuting for many more healthcare workers.  It would enable doctors to oversee remote healthcare operations in mobile units and ambulances.  The City could participate more actively in the development and successful delivery of such applications than for-profit enterprise is likely to do.

 

A City-owned WiFi network would create a new communications infrastructure independent of the existing telecom and cable TV networks, increasing the likelihood of at least one infrastructure remaining useful in a given area in the event of a disaster.  The self-healing nature of the network would allow it to reroute in the event of loss of individual nodes.  Collocation of City 4.9Ghz systems (sharing certain elements like power and UPS) would also increase the likelihood of communication system availability.  The City would create the possibility for instantly or quickly deployable backup communications paths for wire-line services, in the event they experience failures.  Interconnecting with multiple IP Transit providers, would increase network performance and the likelihood of Internet backbone access survivability in the event of disaster.  Networked remote monitoring systems also could aid in identification of issues and improved response times to emergencies.

 

Rather than create complex and expensive roaming relationships with commercial service providers in other cities, a City-owned inbound roaming relationship would be pretty simple.  Anyone who comes here is welcome to use the network for free.  There are no complex roaming relationships to negotiate and manage, and there are no associated customer service complexities and costs adding to the expense of the network.  We would hope that other communities follow San Francisco's great lead and offer free networks also.  If so, there are no outbound roaming issues there.  Otherwise, consumers would be on their own to determine and procure communications services in other cities.

 

A truly free network would not require cumbersome, irritating one-time subscription fees and sign-on processes that exclude or alienate many short-term users from the network and productivity it enables.

 

Ever since Mayor Gavin Newsom challenged the San Francisco community to develop a solution to provide free wireless Internet service for every San Franciscan in his October 2004 State of the City address, the world has been watching to see what San Francisco would do about it.  With its reputation as one of the world's most progressive cities and one of the world's most tech savvy populations, with the ascendance of San Francisco in the national political arena by hosting the first female Speaker of the House, people are looking hopefully to San Francisco to show progressive leadership, to provide an example of how others could best solve the issues we all face.

 

The Earthlink-Google deal is not a particularly progressive model worthy of worldwide emulation.  A truly public network free to all residents and guests is. 

 

Are There Other Models or Examples the City Should Be Aware Of?:

 

Check out the Corporation for Educational Network Initiatives in California (CENIC).  CENIC provides production Internet access, high-performance and research networks for all K-20 public and many private educational institutions in California.  With a staff of some 35 people, it provides better services than available through retail markets, and it serves as many subscribers as many of the top commercial ISPs in the U.S.  It does so at a much lower cost to society than commercial alternatives; it has no profit-seeking motive that causes it to misuse personal information; it has much lower overhead; it is a progressive model to the world; and it actively promotes the evolution and use of technology for the betterment of society.  CENIC's "Gigabit or Bust" initiative generated a great body of work worthy of study in these efforts.

 

Holland's municipal fiber project is an inspiration worthy of study.

 

Google's Mountain View WiFi network is worth studying.  Google simply got permission and built a ubiquitous WiFi network covering Mountain View that is free to all users.  Its costs are low, and the benefit to Mountain View society is significant.

 

Are There Other Funding Strategies The City Could Entertain?:

 

It would be possible to fund TechConnect through naming rights.  The contributions for naming rights of Pacific Bell Park (or whatever it's called now) would largely fund TechConnect.  We could have "SF TechConnect, by Levi's" for example.  Somewhat lower key, we could profile key network sponsors by publishing a key donors list on the splash page users encounter when accessing the network.  That philanthropic exposure may be valuable to some. 

 

The City may be able to charge service providers for network interconnections and specialized peering arrangements, in which they connect directly to the City network in order to improve the performance of their services delivered over the public Internet by reducing the number of hops between their servers and users. 

 

The City could certainly pursue grant funding.  The City could assess property owners for the network, or it could ask voters whether they are willing to fund the network in a special bond.  It could do private fundraising.  There are many possibilities for raising the relatively limited funds required for this network.  The community would be willing to support a public data network in the same way they support public television and radio.

 

Is It Really Necessary to provide wireless network coverage inside all businesses and residences in San Francisco?:

 

Other than in Digital Inclusion programs, SF TechConnect could focus on developing and operating a network to provide outdoor coverage throughout San Francisco and providing guidelines and tutorials for how others can extend that network coverage indoors.  Allowing others to solve the problems of transferring outdoor coverage indoors would provide many business opportunities in San Francisco that should stimulate the economy.  It's an ideal small business proposition to teach people how to extend outdoor coverage indoors and then let them go to work providing those services to others in San Francisco. 

 

It would be an outstanding achievement for City digital inclusion efforts if we could bring network connectivity and computers to underprivileged areas of the city, teach people how to use them, and teach them how to provide paid services to others in bringing network connectivity indoors.  That keeps the City's expenses low while providing an outstanding economic stimulus to various and targeted areas of the San Francisco economy.  City College of San Francisco would be an excellent collaboration partner in those efforts.

 

Is It Really Enough to Offer All Service on a Best-Efforts Basis?:

 

If there is legitimate reason for giving certain traffic prioritization over other traffic, that can absolutely be done.  Some people's ability and willingness to pay more is not necessarily such a reason.  If the City wants to prioritize use of the network for public safety, traffic management, city service or other public benefit applications, make that work.  Otherwise, let the performance of the network be determined simply by the demand at individual access radios.

 

If 100 people step out of a conference doorway and all log on at once, each user's performance would ideally and theoretically be (54Mbps/100 users) 540Kbps.  Should the 50 users who pay get most of that bandwidth, and 50 other users (including honored guests of the City) share 4Mbps if they can get on at all?  In a neighborhood at 3am with nobody else on the network an individual user may ideally get a full 54Mbps.  Fine.

 

The RFP specified mobile services support, so, for example, someone in a car driving 30 mph could continuously operate over the network.  Is that feasible?

 

WiFi technology is really not ready to support that with many users on the network.  As soon as it is, and the public is willing to support it, upgrades could support it.

 

What's Wrong With Advertisement to Fund the Network?:

 

Many citizens and guests of San Francisco would simply prefer not to have to be exposed to unwanted advertisement.  Some citizens and guests view advertisement as a form of pollution, not unlike ugly garbage strewn on city streets.  Advertisement is offensive to some and is avoidable.  This network option is cheap.  Why pervert it?

 

How Would a City-Owned Model Promote the City's Brand/Image?:

 

Ever since Mayor Gavin Newsom challenged the San Francisco community to develop a solution to provide free wireless Internet service for every San Franciscan in his October 2004 State of the City address, the world has been watching to see what San Francisco would do about it. 

 

San Francisco is an extremely progressive, open and technologically savvy community.  The world expects it to offer innovative and novel leadership in how to address the shortage in modern communications service options for citizens, the growing "Digital Divide" between people making good use of communications technology and those who don't, and state of the art city service delivery.

 

A City-owned, totally free network offers the Community of the City and County of San Francisco an opportunity to define, develop and lead the municipal network revolution in a new, unique and compelling way. 

 

So far, most models for municipal wireless networks providing service to citizens have involved allowing profit-seeking commercial interests a new monopoly on new city-wide wireless communications infrastructure, and then trying to force that monopoly to provide open access to other service providers - to maintain some level of commercial fairness.  However, all commercial service providers are motivated to exploit the network for profit, raising citizen concerns about invasive advertisement, collection and sale of personal information, corruption and other prospects for abuse or degraded user experience.  The wholesaler/retailer inherent conflict is avoidable.

 

A totally free City-owned network would be a new and alternative model, a community funded, community service network in which a public service network operator is motivated to maximize the user experience, maximize network performance, minimize commercial intrusiveness, optimize city service delivery and optimize public policy goals of overcoming the digital divide in San Francisco.  By having a non-profit, fully-transparent entity operate the network, there are no profit-maximizing motives to lead to abuse of monopoly power, such as providing inferior service to non-affiliated service providers trying to use the network, collecting and abusing customer information, or bombarding users with unsolicited advertisement. 

 

The City could finance the network out of its operational budget, via a combination of favorable vendor commercial and financing terms, grant funding, property assessments, voter bonds, sponsor naming and association rights and community fundraising.  Rather than a new commercial operation, it would be a new public service - financed and operated much like public libraries, television or radio stations - purely for the benefit of its users and community.

 

This compelling model could provide San Francisco an opportunity to show very strong progressive leadership in municipal communications services.  It would also present a very hospitable face to all guests and visitors in the city by making this state-of-the-art network available to all at no cost as an amenity. 

 

Do something with fiber and you'll really impress everybody and provide a great service to society.

 

Conclusion:

 

These are simply comments of an unpaid individual interested in seeing San Francisco make the best possible decisions from the perspective of San Francisco society in how to engage in provisioning or enabling solutions to citizen demands and desires for advanced communications technologies.  They were compiled in two days with little research, so I do not warrant their accuracy.  I submit them in good spirit and with good intentions, not to be critical, but to contribute to social benefit.  Feel free to ignore them, but I hope some are helpful.

 

Good luck!

 

Sincerely,

 

 

 

James B. Jones

Photisis Consulting

931 Modoc Street

Berkeley, CA 94707

james@...

 

(I'm an MBA who has been a telecom optimization consultant to Bay Area enterprises, a financial planning manager for all Pacific Bell wire-line operations, an SBC custom contract manager, a key contributor to Metro Ethernet pioneer Yipes, and a consultant who helped City College of San Francisco partner with DTIS to expand their public benefit fiber networks.)