***ISPCON 2003
By James Sneeringer
April 23-25

Baltimore, MD

ISPCON is the conference where independent ISPs get together and
work on their issues. This year the issue on everyone's lips was
UNE-P. The FCC decision, announced but not released, has spread
fear throughout the independent ISP industry. Some independent
ISPs are or are thinking about becoming a competitive local
broadband carrier, accessing the local RBOC network by way of the
FCC-mandated unbundled network elements (UNE). At the same time,
local ISPs not looking to become data carriers themselves, feel
that without strong competitive broadband access providers, they
will be dealt or priced out of the broadband access market. In
all cases, the announcement of the FCC that ILECs will no longer
be required to open their data networks to competitive access,
caused massive concern.

It is also the conference that any vendor wishing to sell to ISPs
must attend. This year we caught two threads of products that
ran through the expo floor. Spam control companies were there in
force, with at least two major efforts choosing the conference to
announce their commercial availability. Also intriguing were
several companies that offer dial-up accelerator software. This
is server/client set of software that can speed the Web browsing
and (in some cases) e-mail experience of the dial-up consumer.
Web pages are made to load up to 4 times faster through the use
of persistent sessions and compression.

What Now? ISPs Face the Regulatory Crisis

Kristopher Twomey, a telecommunications lawyer who works with
ISPs and CLECs, laid out the regulatory battlefield:

- The central damage is the announced FCC Triennial Review
ruling regarding unbundled network elements on the ILEC
networks. ILEC voice circuits remain under the compulsion
to remain open to competitor access, but the rates will now
be determined by the states. In contrast, the data networks
of the ILECs would be closed to competitive access if the
ruling stands. Kristopher stated:
The FCC does not care about ISPs. They are sacrificing
them so that AT&T can offer UNE voice.
- Like others, he emphasized that all is uncertain until the
printed decision is released.

- But, there have been rumors that Covad and others have
been talking to the FCC. There is a chance that data UNE
access would be preserved but placed under the dominion of
the states-just like voice. If this happens, ISPs will have
to become active advocates for themselves at the state
level.

- More and more, the FCC is betting that wireless will
provide a strong third competitor to cable and DSL-saving
them from having to manage or punish the ILECs.

- ISPs are poor at advocacy. Without a national coalition
to speak for all independent ISPs, it is difficult to get
bodies such as the FCC to listen. Even at the state levels,
ISPs do a poor job of making their importance known to
regulators or legislators. The number of subscribers is be
the key to gaining access and influence within the
government. ISPs must make their voices heard and defending
themselves in regulatory arenas, now more than ever.

- VoIP could prove to be a disruptive force among the ILECs.
The technology is beginning to be deployed that will allow
ISPs to offer pure VoIP to the home, bypassing the need for
a phone line. But, in most cases the ILECs control the
local backhaul, and regulatory issues such as universal
service and number portability need to be addressed.
Kristopher would be stunned if the FCC did not eventually
require universal service of VoIP.

- The question of whether or not to become a CLEC, as many
ISPs have done recently, is even more uncertain than ever.
Any attempt now would have to include co-locating a DSLAM.
The process is complex, and in response to a question,
Kristopher laid out the basic seven-step process. The crux
is the last step-implementation. It can be hard to actually
get into the ILEC CO once the ink has dried.

- There is no shame in dial-up; it is cheap and it makes
money. With ICNs (Internet call managers) that allow a
person to take a phone message without severing their
network connection, the dial-up experience could be greatly
improved.

Keynote -- The TeleTruth Crusade

Bruce Kushnik, Executive Director of New Networks and Chairman of
TeleTruth, delivered an impassioned keynote address on the last
day of the conference, in support of ISPs-and in condemnation of
the ILECs. He is a founder of TeleTruth, an advocacy group
formed in 2001 for competitive carriers, ISPs, and their
customers, and anyone else with grievances against the ILECs.

www.teletruth.com


TeleTruth currently has 400 members, with a 30 member board.
They have filed before the FCC and are preparing legal action to
preserve independent ISPs and CLECs. Bruce described the
organization as "an experiment in advocacy." A few more of his
statements:

- ISPs are innovation engines-small businesses delivering
innovative, valuable services to their customers.

- ISPs must let regulators know they exist, and that they
need to continue to exist. Right now the independent ISPs
as an industry are terrible advocates, and thus the FCC does
not accord them any value. They will seek to eliminate the
small ISPs, leaving only the major providers.

- ISPs can use their customers to advocate for them, by
contacting regulatory bodies directly in support of their
ISP. Bruce emphasized that this sort of grass-roots effort
can be very powerful with regulators, if enough contacts are
made.

- In response to a question as to whether this would work,
an ISP owner stood in the audience and reported that during
a recent FCC NPRM, he was able to generate 58,000 comments
to the FCC from this customers.

- TeleTruth has petitioned the SEC to investigate the
results of a failed FCC auditing procedure that was begun in
the late 1990s and came to a head during the CALLS deal-
making in early 2000. FCC auditors had visited ILEC COs
nationwide to check the equipment against the books, and
found billions of dollars worth of discrepancies between the
books (high) and the actual equipment (low). The ILECs
insisted that the error was in the books, but other believed
that they had knowingly left non-existent equipment on the
books to justify higher rates. Rather than punish or
publicize, the FCC, ILECs, and LD carriers incorporated the
issue into the dealing, and as part of the CALLS deal the
FCC audits ceased and the audit department was disbanded.
The issue received press in a recent issue of Forbes.

- TeleTruth has also filed complaints with the Senate
Commerce Committee and FCC concerning a law known as the
Regulatory Flexibility Act (RFA). This act, and a
subsequent, separate order from President Bush, demands that
federal regulatory agencies discover and take into account
the effect of their policies on any small businesses.
TeleTruth asserts that the FCC has taken no action to
understand the effect of their rulemakings on small ISPs and
CLECs-and are therefore in violation of the RFA. The Small
Business Administration (SBA) has filed at the FCC in
support of TeleTruth's assertions.

- Fifty percent of phone bills have errors on them. So,
TeleTruth offers to audit, for free, the Verizon bill of any
consumer, small business, or enterprise.

- TeleTruth is finding it hard to gain access to
politicians. The ILECs spend a lot of money on advocacy.
But, it is essential that ISPs and competitive carriers find
allies in Congress. The small business angle may help out.

Bruce ended with his hands out: "Let us pray." He received a
standing ovation.

On the Floor

The Rural Broadband Coalition

This is an advocacy and advisement group for rural broadband
deployments of any technology, motto: Leave No Town Behind. In
addition to advocating for government support for rural broadband
deployment, the RBC offers services to help member companies get
the most support possible from the government. In particular,
the RBC works closely with member companies to help them get
support from the Department of Agriculture's Rural Broadband
Loan/Grant program. In the most recent round of applications,
RBC member companies submitted 29 applications, 9 of which were
accepted for consideration by the program. The other 20 will
need to be re-worked and re-submitted. The Department of
Agriculture program has the goal of turning around application
approvals within 90 to 120 days, but the RBC suspects it could
take significantly longer.

Spam

There were several spam solutions on the floor, all targeted at
ISPs as customers. The pitch for each was the same-you can
charge your customers extra for our service. White-list
solutions depend primarily on matching the sender address against
a list of approved senders; if there is no match, the e-mail is
considered spam and separated. In contrast, black-list solutions
compare each e-mail against a list of known spam sender
addresses, and separate any matches.

TitanKey

This is a white-list based solution that seeks to use
confirmation e-mails to set up a network of approved senders for
each mailbox. It assumes all e-mail is spam unless otherwise
indicated. When an e-mail from an unknown person is received, a
hard bounce message is sent out (error 550-user unknown),
followed immediately by a confirmation message. The sender then
replies to the confirmation message, which adds their address to
the whitelist. They are then free to re-send their initial
message, and any further messages. For entering an e-mail
address on a form, the user is provided with a "virtual private
mailbox"-a proxy e-mail address that will accept a certain number
of unknown messages from a new domain.

TitanKey announced its commercial availability at the show. The
target market is large ISPs, for deployment as a value-add
service to their customers. TitanKey has approached large
enterprises as well, but apparently they are not sure they want a
system that hard-bounces all new incoming mail. This seeks to
solve spam by putting a burden on the sender.

Vanquish

This was another white-list system that announced their
commercial availability at the show. Vanquish is a system that
an ISP would run on their servers, and offer as a value-add to
customers. The key feature is a system for monetarily "bonding"
e-mails that are sent. In the initial release, each e-mail, for
instance, would carry a bond of 5 cents. If the recipient did
not want to receive that e-mail, they can choose to charge that
bond to the sender. For senders of millions of bulk e-mails, the
cost could add up fast. Vanquish, the company, provides all the
back-office billing to make the system work. Any bonds that are
charged would go to the ISP of the recipient.

If the sender is not a Vanquish user, they would simply receive a
bounce message asking them to sign up with Vanquish as a sender,
before they can reach those recipients. The effect is similar to
TitanKey, but the difference is that the sender authentication is
based on the monetary bond, and controlled by a third party
(Vanquish). Like TitanKey, the burden of the spam control is
placed on the sender. Vanquish has come out of beta, and has an
initial customer base of 10 ISPs using their product. A future
version of the product will allow recipients to set their own
bond level. Thus a celebrity or executive would be able to set a
$1000 bond (for example) per e-mail (to be charged if they did
not want to receive that e-mail).

Spam Trap

This Australian company is still in pre-launch stages with their
spam solution in the US, but it is fully available and functional
in Australia. The system works like an anti-virus solution, by
setting up target e-mail addresses to receive spam, then
developing a constantly-updated database of spam profiles that
are pushed out to the ISPs. As each e-mail comes into the ISP,
it is compared against the profiles, and any matches are diverted
to the junk folder. In Australia this system catches about 85%
of spam, but in the US right now it is only catching 60%. This
number has been going up continuously, though, and founder
pointed out that the nature of the solution takes time to
develop. The key advantage is that there is no additional burden
on either user or sender; unique personal messages will get
through because there is no match.

Dial-up Accelerators

These companies are based on the assumption that most consumers
don't care about broadband in and of itself; they just don't want
to wait for the network. One solution is to use compression and
session technology to speed up the most popular activities, web
browsing and e-mail, over the dial-up connection.

SlipStream

SlipStream uses a proprietary compression developed at the
University of Waterloo to reduce the file sizes of web pages and
e-mail. Text is compressed losslessly more than 10 times, and
images receive a 2 times lossy compression. In addition, the
client and server set up a persistent connection during file
transmission, which reduces IP packet overhead. The result is a
dial-up experience that seems as though the connection is 2 to 3
times faster. SlipStream has benchmarked their system up to a
simulated 125k connection. The theoretical maximum is 200k with
current computers, because of the additional processing load
involved. Customers include NetZero, which has over 120,000
customers so far for its NetZero High Speed service. At the
show, SlipStream released a new version, that will speed e-mail
transmission times as well.

Propel Software

Propel uses a proprietary combination of caching, compression and
connection management to speed the dial-up experience. As a
result, a web page will load two to three times faster than dial-
up with the first visit, but subsequent pages on the same site
can be up to five times faster, due to caching. The ISP can host
the acceleration server in-house on its own servers, or have
Propel or one of their service providers host it. The charge to
the ISP is on a per-user, per-month basis. Hosting in-house is
cheaper, but depends on the ISP to set-up and support the
service. Hosting by Propel or partner costs more, but the
service can be up and running in one week, with support provided.

At the show Propel announced version 3.0 of their Accelerator,
which adds pop-up blocking and file transfer acceleration to the
existing web page acceleration. The next version, in testing now,
will also provide POP e-mail acceleration. Propel claims that
they in use by 100 ISPs, and also announced at the show that the
client software will be bundled with all new U.S. Robotics analog
modems.

Wireless

WiFinder

This is a web search engine to find WLAN hot spots anywhere in
the world. Simply enter location information, and the search
tool returns a list of hot spots in that local area. The basic
listing is free forever on the site, so anyone can enter
information about their public hot spot. The company makes money
by offering premium listings, usually bought by the larger WISPs.
Unlike the recently released Wi-Fi Zones initiative from the Wi-
Fi Alliance, there are no equipment requirements to meet.

WiFinder is moving soon to incorporate all public broadband
access points into its database, not just wireless. This could
include hotels with Ethernet ports in their rooms, airport
business centers, etc.

The WAVE Report inquired for any progress on the roaming front-
allowing customers of one WISP to access the hot spots of
another, with the billing trail handled in the back end. Scott
Rafer, Chairman of the company, spend some time answering and
discussing the WLAN market. Some of the high points:

- There are no roaming agreements and no demand for it yet.
No one yet has a large-enough foot print for it to matter.

- Most public WLAN consumers use pre-paid access at each hot
spot-a single payment for a set block of time. Very few
people go with the subscriber model.

- Roaming is a chicken and egg problem. Roaming will not
happen without wide-spread demand, but the subscriber
business model will not succeed without wide-spread or
universal roaming agreements. The solution is totally
unclear.

- No one accepts that there will not be a roaming fee a la
cellular.

RadioLAN

This is a fixed wireless company that operates in the 5.8 GHz
spectrum. Its offering includes both point to point and point to
multipoint solutions, with ranges up to 32 miles at 10 Mb/s.
They also offer an 802.11a solution with a range of up to 5 miles
at about 30 Mb/s. The target customer at the conference was an
ISP wanting to extend their coverage without paying for new line
from the local network provider.

YDI Wireless

Another fixed wireless company, YDI operates in both the 2.4 and
5.8 unlicensed bands. There must be line of sight, and the range
can be up to 20 miles depending on equipment and conditions.
Most customers use their products for point to point bridging,
with some point to multipoint. They stated that a few customers
do use the 2.4 solution to provide last mile point to multipoint.
YDI operates in the US, but also gets a lot of work overseas, in
Africa and Asia. They do not work much in Europe because of the
stringent power restrictions. Like RadioLAN, they hoped to sell
to ISPs looking to extend their coverage.

Rapid DSL and Wireless

This was a local Maryland ISP using fixed wireless to deploy a
network without going through a telco. They hook into a long-
distance backbone provider at a peering site, then use wireless
to backhaul their network. As a side effect of their business,
they have developed a software router product, for multiple
customers in one building. There is a single piece of hardware
for the system, that runs the software, and each customer
connects to it with a radial line. The software creates a
virtual router for each customer, with all configuration and
management handled from the central computer. The company is
currently developing the software to sell as a stand-alone
product.



Wave Issue 0320 6/20/03 Article 2-01