Open letter to Los Angeles City’s Information Technology Agency

In response to the City of Los Angeles Community Broadband Network (LACBN)
Initiative and related Request for Information (RFI)

An open letter to:
Steve Reneker
General Manager
Information Technology Agency
200 N. Main St. 14th Floor
Los Angeles, CA 90012
[email protected]

On behalf of:
Data Roads Foundation
1793 Northwood Ct.
Oakland, CA. 94611

Data Roads Foundation is responding to this City of Los Angeles Community Broadband Network (LACBN) Initiative and the related Request for Information (RFI), despite the fact it asks the all wrong questions based on a nonsensical approach to infrastructure investment, as defined here:

‘The City recognizes that it is not simple to build out broadband infrastructure throughout the City, or to achieve the other goals outlined above. Broadly speaking, there are at least three ways that communities have pursued broadband deployment. One way is for the municipality itself to build a broadband network that competes with private enterprise. The second is by seeking to attract entry of a new competitor that is willing to build a new “Google type” model to service the city or parts of it. The third is by seeking to encourage one or more incumbents to expand their existing networks.

At this stage, the City is seeking to achieve its goals through the second and third options…’

There are two obvious flaws with this list of “three ways”:

1. The phrase “competes with private enterprise” presumes broadband Internet access market competition which does not actually exist today — definitely not anywhere within the city of Los Angeles, California.

At best, we have a market duopoly or trust for all residential Internet access, which is able to coordinate all trust-member pricing by advertising their current lowest rates publicly. At worst, we have a set of complementary services for residential and small business Internet access, which never actually compete at all because they never really serve as market substitutes for each other. Due to properties inherent to all communications networks, like Metcalfe’s Law, they can probably never be considered market substitutes even when they offer equivalent services. They merely complement each other by offering aggregatable or redundant Internet access channels. The most any municipal network could achieve is providing another complementary option, never single-handedly providing any real form of open market competition. In the text below, we will show better options for creating (or at least connecting to) real market competition.

2. The “second and third options” posited here have absolutely no relation to the first.
Any possible method to “attract entry” or “encourage one or two incumbents” to build a new residential and small business network, with Internet access to all customers within LA city borders, amounts to a promise of market favoritism. Such blatant favoritism should never again be tolerated in our public infrastructure by our representatives or their voting public. The decision to build, buy, or rent a municipal internal network is entirely separate from these two false “options”.

The central question of this RFI — only to be answered in the later Request For Proposals (RFP) process — should be the same as in any financial consideration of core business or municipal internal operational infrastructure:

Do we build it or buy it?

For a successful answer to this question, just look at the Santa Monica City Net. Assuming the “build it” option (which has been successfully implemented by the cities of Santa Monica, California, and Chattanooga, Tennessee) has been eliminated by the stated scope of this RFI, the financial question that follows the answer to “buy it” is:

Do we pay for ownership up front, debt finance it, lease it, or pay rents on it forever?

In this case, the choice presupposed in the text above (“second and third options”) is to rent network access from some third party, who builds their own network based on promises of immediate “anchor tenant” rental contracts. This choice might make a lot of sense for a business that intends to move its office once the minimum rental contract term ends (e.g. changes from annual to month-to-month), or at least has business leaders who desire the option of moving offices after that time. A city’s municipal government never has any similar option, as it is a geographically bound institution that can never merely serve as a local infrastructure tenant rather than its ultimate steward.

The predetermined choice stated here, to rent this core municipal infrastructure perpetually, is completely nonsensical and uneconomic. It is as if a homeowner decides to retain ownership of their non-mobile home, yet sells off the land and pipes beneath it, so that they must forever after rent access to their own home from the land’s latest purchaser. No matter how difficult the land around and underneath the home might be to manage, this separation of geographically bound permanent and durable structures never makes any fiscal or structural sense. Such action may not be prevented by current law or statute, but it should always be prevented by financial sanity and ethics.

The only honest recommendation left for this information request is an answer to this question:

How do we finance the Los Angeles City municipal internal network — a network which already extracts about $10 million of the city’s taxpayer budget every year — into the future?

Should the local voters allow the city to continue renting this basic functional communications infrastructure in perpetuity, at the behest of local cable and telephone company lobbyists within City Hall? Hopefully any suggestion of that option being viable in the long-term is obviously false, by now. The financial options remaining are to use those same $10 million annual budgets to build out a municipally owned network, to either internalize or contract out operation and maintenance on an open competitive basis, to finance its construction (perhaps via municipal bond), or to lease it from a third-party builder (with an option to buy it out at end of lease term). Lease agreements for fixed and durable assets only make sense when the combined lease term and the buyout price at the end of the lease is less than the gross principal, fees, and interest costs of a loan. The bank loan (or municipal bond) financing option is usually the most fiscally sound funding method in the long term, and geographically fixed resource stewards should always plan for the long term.

Now that the financial questions behind this network construction are out of the way, we can describe how Los Angeles city residents can gain the open access network described by the LACBN goals, without giving away any more infrastructure monopolies to incumbent selfish anti-competitive interests or other lobbyists. We can do this by encouraging neighborhoods to form member-owned or nonprofit cooperatives, to build their own neighborhood networks out to municipal institution connection points. Los Angeles ITA can form peering and transit agreements with these local community networks directly. Rather than offering global Internet transit services directly, perhaps our city government can just offer its unused excess fiber and transit capacity for free instead, to connect neighborhood networks back to competitive carrier neutral hotel facilities where global transit providers already compete for broadband traffic demand.

Due to the bursty and rarely peaking nature of all Internet traffic, any fixed node traffic network (including municipal internal networks) will always have capacity to spare. Internal traffic can be secured via end-to-end encryption and quality of service (QoS) policies, both which can be automated entirely within the network’s router infrastructure. With municipal and safety department traffic thus protected, it will always be safe to provide any spare capacity to adjacent residential and small business networks of any size.

In addition, bulk cable installation is usually more cost effective at industry standardized wire counts per bundle. For example, a bundle of 8 optical fibers is likely composed of 2x 4-fiber cables taped together, which actually costs more to procure and install an equivalent length of pre-bundled 12-fiber cable. This means any installed fibers or other wire bundles in the city’s municipal network are likely to have spare unconnected lines, which can be offered to all adjacent networks just like any other dark fiber service at negligible to zero additional cost to the municipal network construction.

One problem remains:

How do we encourage and assist Los Angeles neighborhoods to build their own locally operated and self-determined networks, to connect them with the closest adjacent municipal institution network nodes?

The core mission of Data Roads Foundation is to encourage and assist neighbors to build their own locally self-determined networks all over the world, and to openly peer with each other until we have one giant global mesh, which will operate in parallel the multinational corporate network we call “the Internet” today. We have a few development methods that seem appropriate to share with you here:

1. Build on the concepts Homes With Tails and Neighbors With Meshes.

Homes With Tails is a network infrastructure development concept put forward by Tim Wu and Derek Slater in 2008. Their proposal described a system of homeowner procured optical fiber “tails” which connect them to competitive Internet transit provider hub stations directly.
A local Data Roads Foundation supported network project, Northeast Los Angeles Infrastructure Service Cooperative (NELA-ISC.Net), was founded in 2010 with a similar concept in mind: Neighbors With Meshes. Mesh topology networks are completely channel medium agnostic. They can utilize long distance fiber, medium distance copper, and multi-band wireless connections — all connecting simultaneously to the same router hardware at each node. They can be installed and connected over each home and land owners’ resources without any additional rights-of-way impacts.
Both concepts posit a community network construction option which obviates the Big Telco myth of “the last mile problem”, by allowing home and land owners also own and maintain their community’s first mile of network infrastructure. This community infrastructure would eventually allow residents and small businesses to connect with competitive Internet carrier offices directly, where an open and competitive market between Internet transit services already exists today. This eliminates the biggest cost problem with current US residential networks: the lines connecting landowners to competitive transit providers are all monopolized and rented out by local channel operators. One monopoly provider per wire type or radio frequency channel exists in nearly 100% of North American Internet access markets today. Each of these wires or broadband channels can be multiplexed or load-balanced into a single virtual connection, so they never serve as competitive market substitutes — only as complementary or redundant interconnected services.

Everyone within these first mile networks saves Internet access costs overall, by accessing the competitive global transit and peering market directly, and bypassing all local wire or radio frequency (RF) monopolist rentiers. Monopoly rent extraction only drives up everyone’s access costs, and little to none of those rent profits are ever reinvested into service improvements.

2. Encourage, federate, and peer with adjacent government facility networks — including nearby municipal utilities, CalTrans, MTA, LAUSD, colleges, Los Angeles County, US Federal, and California State assets.

Rather than providing the whole of a municipal network directly, local municipal utilities can offer spare network capacity from their own internal operational networks, on a peer or federated basis with the city government’s municipal network. All this collective spare capacity can then be offered to local communities adjacent to all these buildings, meters, poles, conduits, and other local fixed assets.

Power, water, waste management, and gas utilities all benefit from modern smart-meters and other sensor networks for their operational security and efficiency. Power line broadband and optical fiber network technologies can coexist on high-power transit infrastructure without any form of interference. Exposed or worn optical fibers will not react with passing water or sewage inside the same conduits or pipes. Pole attached networks can coexist with small-node wireless infrastructure at different heights on the same poles, which would provide secure redundancy and emergency reliability in cases such as falling poles or cut lines. Municipal utility, emergency, and government office networks can each be managed separately; yet also federate or peer to share excess transit capacity at all gateway router interconnection points.

Local transit services can better coordinate their vehicles, secure their assets, and serve their customers with a wired mesh of nodes at every station, and with wireless mesh networks wherever their vehicles frequently stop or roam. These wireless transit service networks can offer spare WiFi capacity to all riders, to increase the consumer-perceived value of all their services. Further spare capacity and unused lines can be shared with the communities adjacent to each transit hub or stop.

Local county, state, federal, and university system offices and land assets (e.g. security cameras at parks) always need to connect back to their home offices eventually. They each need to consider similar issues with their core operational infrastructure as the questions posed above. University systems already operate a hybrid of public and private ownership networks, including an experimental high-speed global network called Internet2. These are also each geographically bound government or public entities, so their decision to own (not rent) their core operational infrastructure should be equally obvious. Federating or peering local municipal networks with these larger-footprint networks will thus grow the settlement-free capacity of all networks involved.

3. Utilize free and open wireless mesh network standards to leverage all nodes into low-cost growth assets.

Calculating the total value of communications networks is an odd task, due to mathematical peculiarities like Metcalfe’s Law. Each consumer of network resources actually increases the value of that network overall. So if every new network subscriber is actually adding more value than they use up, why should we charge them for access at all? Calculations are even more difficult when free and natural in situ media is utilized as communications conduit (e.g. air, as in free-space optical, sonar, or radio beams). In these cases, all so-called consumer router nodes provide their interconnection infrastructure directly, without any real installation costs other than hardware and power provision. Existing grid or renewable+battery power are usable by most available wireless technologies.

Mesh topology networks create a very unusual market dynamic, where every so-called consumer of network resources also becomes a producer of net routing capacity whenever they join a mesh network and connect to at least two existing nodes. Nodes like smartphones could become clients or core routers in the network at any time — ad-hoc wireless mobile mesh networks have no real or permanent distinction between those two seemingly differing states. Therefore, we recommend that wireless mesh access to the Internet should be provided to everyone within municipal mesh range, free of charge for as long as their access hardware also serves as an open routing node within the mesh. Game theoretically automated cap penalties can be used to prevent nodes from requesting too much and routing too little, to keep things free and fair for everyone involved. The net result would be an open wireless access service that actually grows itself by giving away mesh node “subscriptions” for free! Customers can also pay into this wireless network for faster broadband or insurance-backed reliability guarantees. If you really want to lower the cost of wireless Internet access to near or at net zero for all Los Angeles residents, this is the best method.

4. Petition for (or directly draft) infrastructure policy changes at the city, county, state, and federal levels.

The sad truth, only hinted at within the RFI text, is that our federal government (the US Congress in particular) is not fulfilling their constitutional duty to “establish [Data] Offices and [Data] Roads” accessible to citizens throughout our nation. You may not immediately recognise that line from the US Constitution, but if you substitute the word in brackets “[Data]” with the word used by the founding fathers with the same original meaning (“post”), then it becomes more obvious that the “Postal Clause” should be renamed the “Communications Infrastructure Clause” for purposes of modern interpretation. The namesake of our current federal communications policy, the Federal Communications Commission (FCC), has done even more recent harm to this constitutional obligation than Congress. Their primary method of communications failure is giving or auctioning away most of our common natural resources (radio frequency or “RF bands”) to monopolists, militaries, and other resource hoarders and destroyers. They consistently regulate our once-free communications resources away to their monopolist lobbyist interests — they have never really regulated the communications industry in the public’s best interests since their office’s inception.

The City of Los Angeles has been left with a huge black hole hovering over all its businesses and residents — a black hole which is only visible in the FCC’s own white spaces frequency availability databases. Los Angeles regional RF monopolists used up all the white spaces frequencies here before that term was even coined! The US Post Office and its local stations should be petitioned to finish fulfilling its constitutional mandate towards equal access communications infrastructure. They should act on this mandate immediately and independently, despite the absence of any legislative leadership on this issue.

We must do much better for ourselves locally, and show these so-called federal regulators a much better example to emulate and follow.

The Southern California Joint Pole Committee (SCJPC) should be petitioned or enjoined to provide reciprocal access to each pole’s connected residents. Lines from their utility poles inevitably cross out of public rights-of-way and into private property at some point in space, yet no additional rents are levied by property owners at these crossings, ostensibly because these lines are necessary for each property’s service provision. As a show of good faith and reciprocity, property owners should be allowed to connect their own lines (of same or lesser circumference and weight) back onto these same poles, at the same or lower connection points on said poles. In the example of two neighbors across a street from each other, both connected to the same utility pole for cable and power services, they should be allowed to connect their own cables (of same or less width and weight as incoming power and coaxial cables) to each other directly using that same pole, attached at or below the same point on that pole (still well above street traffic level of course). This reciprocity policy would help solve part of the first mile deployment complexity for member-owned and community-operated networks.

In addition to granting all landowners reciprocal access to utility pole connections, easement conduits, and adjacent right-of-ways; the city should help enforce and uphold its local resident’s and small business owner’s rights to first sale doctrine principals in all local sales, including any sale or resale of broadband transit capacity. Any promise or sale of broadband network capacity in any form should be resalable by the initial purchaser without limitation. Any conflicting service contract terms should be struck null and void in all US courts of law. The City Attorney’s Office of Los Angeles should help defend its residents and local small businesses in any cases related to broadband Internet access, transit resale, or similar gift giving. This local office should also help enforce common carriage laws for all forms of local transport, including the same digital transport that the FCC has failed to recognize as subject to common carriage market neutrality.

California state and federal highway and rail infrastructure is optimal for communications line and conduit installation, and access to this conduit should be provided at-cost to the local municipal entities that all this infrastructure passes through. California State and its CPUC regulators should also change its policies to encourage more community networks to grow statewide, including by recognizing I.R.C. 501(c)(12) utility cooperatives as nonprofits within the state, subject to no state fees or other state taxation overhead that is only appropriately applied to for-profit business activity. The US IRS should also be petitioned to accelerate application processing for new I.R.C. 501(c)(12) incorporations, in order to help promote new community infrastructure networks to grow and peer nationwide.

The LACBN RFI text [PDF]  poses many more specific questions than those answered above. Data Roads Foundation addresses each of the questions posed by RFI section IV.B. directly within Addendum Q. Thank you for you time and consideration. We fundamentally agree that Los Angeles city residents and businesses deserve better Internet access. I hope we can arrive at further agreements about how we should change local network access and ownership for the benefit of all residents, both short and long term.

Jared Hardy
Founding Director
Data Roads Foundation

Pointless legal boilerplate below (included here for fans of run-on sentences and impenetrable legalese!):
The Respondent undertakes and agrees to defend, indemnify, and hold harmless the City of Los Angeles and any of its boards, officers, agents, and employees (collectively, the “City”) from and against all suits, claims, and causes of action brought against the City for the City’s refusal to disclose Respondent’s trade secrets or Respondent’s other technical, financial. or other information to any person making a request pursuant to the State of California Public Records Act (California Government Code Section 6250 et seq.). Respondent’s obligations herein include, but are not limited to, all reasonable attorney’s fees (both in house and outside counsel). reasonable costs of litigation incurred by the City or its attorneys (including all actual costs incurred by the City, not merely those costs recoverable by a prevailing party, and specifically including costs of experts and consultants) as well as all damages or liability of any nature whatsoever arising out of any such suits, claims, and causes of action brought against the City, through and including any appellate proceedings. Respondent’s obligations to the City under this indemnification provision shall be due and payable on a monthly, on-going basis within thirty (30) days after each submission to Respondent of the City’s invoices for all fees and costs incurred by the City, as well as all damages or liability of any nature. Respondent shall receive prompt notice from the City of any (1) communication to the City challenging the City’s refusal to disclose Respondent’s information, and (2) any complaint or petition to the court challenging the City’s refusal to disclose Respondent’s information.


Addendum Q.
Q&A Responses to LACBN RFI Section IV.B.

Q: 1.a. & b. Is respondent interested in building all or part of the LACBN?

A: This LACBN RFI/RFP process should be used for the City and every other local government institutions to build and operate their own municipal broadband networks, to open paths and policies that enable neighborhoods to build their own gigabit hybrid wired & wireless mesh networks, and then to peer or federate all these networks together in order to share or exchange spare transit capacity.

Q: 1.c. What approach might the City take to an RFP that would encourage you to apply to bid to build all or part of the LACBN?

A: Allow nonprofit entities to make proposals that include subcontracting to other local nonprofits, or even help to form new local nonprofits, in order to build and federate their own locally self-determined neighborhood networks. Promise to peer or federate with these neighborhood networks from all the closest available municipal institutions. Exclude existing monopolist franchise owners from all bidding, due to their unfair advantages, including their decades of lobbyist influence within our City Hall.

Q: 1.d. Would it be better to separate the wired and wireless components of the initiative? Are there any special problems associated with the wireline v. wireless deployments?

A: All fixed node OSI Layer 3 routing protocols tend to be transport medium or channel type agnostic, so the decision to use fixed wireless or wireline deployment methods should depend on environmental and economic factors alone. Ethernet variable link dependencies tend to be handled by connection adapter firmware at Layer 1, or at Layer_2 at the highest, so these values can be factored into Layer 3 route calculations dynamically as needed. For example, the cost and reliability of 2 routers connected from 20km away via either single-mode fiber or fixed wireless depends on the available conduits, pole mounts, or lines of sight between the buildings at each end point. Some wire, conduit, and wireless channel performance characteristics are also weather dependent.

Mobile or ad-hoc mesh routing protocols can be made robust to a mix of fixed and mobile nodes within any given region, but efficient routes and table storage may be difficult to scale out to a large metropolitan area. Therefore, we recommend that all wire (e.g. fiber or copper) connected fixed nodes run a fixed mesh Layer 3 routing protocol, while all fixed nodes with any multipoint (PtM or MtM) capability run on a hybrid stack of fixed mesh Layer 3 and ad-hoc mesh routing protocols — perhaps one routing protocol per subnet, with a separate subnet for every IP number allocation type.
Peering border gateways should always run a Layer 3 mesh or BGP routing protocol compatible with the adjacent peered nodes, so wireless gateways between network borders should always be maintained as fixed nodes by both peers.

Q: 2. What is a reasonable way to approach deployment timetables to achieve LACBN goals? Is there any way to do so without favoring incumbent providers?

A: Incumbent providers should be banned from the LACBN deployment process due to unfair advantages given by their past exclusive franchise agreements, especially in the form of their City Hall lobby power. They may offer their existing infrastructure assets for purchase at fair market value to the City or its selected contractors, but any consideration of continuing rental contracts for those same assets should be quashed immediately.

Building reliable networks and all their necessary conduits takes time, so start immediately. Nobody can predict the finish date with any accuracy at this point, and anyone who claims such ability is a liar, but local neighborhood network constituents have the best incentives of any applicants to act both quickly and cost effectively.

Q: 3.a. Are there specific areas within the City that should be targeted for deployment of the LACBN? What are those areas?

A: City owned or managed buildings near carrier neutral hotels and Internet exchange locations (including multiple points in downtown Los Angeles) require the least costs for 10, 40, and 100 Gigabits per second peering or transit connections due to short interconnection lengths. These connections give the City and its peers the best access to competitive Internet global transit and peering services, so these connectors should be built or refurbished first.

Copper Cat6a wires and ports cost less than any optical fiber line type for connections of the same bandwidth less than 100m apart. Multi-mode fiber technologies cost less per port and line length than single-mode fiber for connections less than 550m apart. Fixed or PtP wireless connections can extend as far as 100km, but tend to be faster and more reliable the closer they are together with direct line of sight between roof mounted antennas. A single-mode optical fiber can span from one Los Angeles City border node to its farthest opposite border node, with minimal amplification or repeaters, so all connection lengths over 550m have similar port and linear measured costs to each other. Therefore the City should spread its municipal mesh out between buildings less than 100m apart first, then those greater than 100m and less than 550m apart next, then buildings with line of sight between rooftops for high bandwidth fixed wireless PtP links, and finally nodes farther than 550m apart and with minimal roof-to-roof line of sight last.

Due to standard zoning and street layouts, these meshes will start as a dispersed set of small rectangular grids spread throughout the City. These rectangular grids will decrease in grid density and grow together as the build out continues. Every neighborhood with at least one library, fire station, police station, and school will have multiple connection points into the resulting high bandwidth municipal grid.

Q: 3.b Are there areas where businesses or residences are already servable by at least 300 Mbps access downstream and upstream?

A: No, never reliably, and definitely not affordably.

Q: 3.c. Are there areas where it is impractical to require a new entrant to build a new network because businesses and residences are already serveable by multiple advanced networks?

A: Due to properties of networks like Metcalfe’s Law, any new network is a complementary service that can be aggregated or used redundantly to those that already exist. Therefore, there will never exist an area where a new competitive network build is impractical or unwanted. If a given area is already “serveable [sic] by multiple advanced networks”, that is a sign of existing market demand for ever greater network capacity, which should never deter new market entrants.

Q: 3.d. Are there areas that should not be included in the LACBN because of environmental concerns, or other construction issues that make deployment impractical?

A: If such an area exists then it should not already have residential homes, business offices, roads, or other public services built anywhere near that area. Networking is core infrastructure, just as necessary as any other type of existing infrastructure, yet it is much smaller and easier to install. The presence of other existing infrastructure in an area is a sign that these issues have already been disregarded by previous construction. Network addendums to such construction are of negligible to zero net impact, and in most cases the low-power tools networks enable provide net positive impacts.

Q: 4.a. Are there ways in which the City could alter its permitting and contracting practices that would encourage deployment of advanced facilities?

A: Build or finance the municipal network, own it, and competitively contract or bring its operation in-house directly. Don’t charge yourself permitting fees to build your own network (that would be silly!). Don’t charge residents or their member-owned community networks for building their own infrastructure in their own neighborhoods. More specific recommendations are detailed in the attached open letter.

Q: 4.b. What changes [to City policies] would be the most valuable?

A: A general application of first-sale doctrine to Internet broadband, application of common carriage laws to all digital transport, utility pole or conduit usage reciprocity for all home and land owners, and settlement-free peering network interconnections between all local and government institutions generally.

Q: 4.c. Are there assets that would be of particular use to LACBN deployment?

A: Distributed fixed and mobile mesh networks, owned and operated by government or nonprofit entities or neighborhood community groups, all interconnected and sharing capacity. Community access to any existing municipal infrastructure to this end, such as nearby power and fiber lines, would be helpful immediately.

Q: 4.d. Are there assets that would be of little utility to deployment of the LACBN?

A: Lobbyists, ALEC legislation pushers, and their corrupted government officials.

Q: 4.e. Should the City install fiber or conduit as part of future construction or repair of roads, or as part of replacement of communications system?

A: Yes. The incremental cost of such construction additions are negligible, so just do it. You automatically save the cost of tearing up the old outdated infrastructure in the future. The need is inevitable, so just do it now whenever you have the chance to do so at small incremental cost!

Q: 4.f. Is having the City as an anchor tenant useful or of little use in encouraging deployment?

A: Continuing to act as a perpetual tenant to a monopolist rentier will never encourage competition. Slow upgrades and even slower new deployments are aspects of monopolist market stagnation that will not be cured without real market competition. Create your own competition by building your own network, and become an anchor institution instead of another mere tenant.

Q: 4.g. Are there particular City service/facility needs that may be of significant value to a person seeking to deploy all or part of the LACBN.

A: The City needs to provide its own communications infrastructure to operate internally, and to connect with the public for all security and outreach related communications. The City should save on these costs by cutting out all intermediary extractors and arbitrage artists by building and operating this communications network itself. This network should become cost effective quickly, thanks to City property and conduit in near proximity to many competitive global Internet transit and peer interconnection providers. By just sharing unused or excess capacity and wirelines from this network, the City can in turn give access to the same competitive Internet transit providers out to all LA neighborhoods and community networks.

Q: 4.h. Are there particular City service/facility needs that are of little value to a person seeking to deploy all or part of the LACBN.

A: Propping up monopolist-middle or perpetual-rentier contractors on behalf of lobbyists in City Hall is of no value to anyone except those lobbyists.

Q: 4.i. Are there City service/facility needs that the City should separate from the LACBN process?

A: Very little of what the City operates daily can be separated from dependencies on access to communications infrastructure. All this infrastructure, including both wired and wireless VoIP access, can and should be provided by the City for itself. It can easily extend wireless services beyond municipal building and campus areas by extending free wireless mesh access to all adjacent communities. These communities will effectively use such access to extend the wireless footprint for the City’s internal users, usually by paying to procure and maintain the wireless mesh routers required for this access and extension.

Q: 5.a. What specific steps should the City take to make broadband available to all Angelenos?

A: Step 1. Show a good example by building and operating your own internal municipal mesh network.
Step 2. Encourage other locally operating government institutions, small businesses, and neighborhoods to follow this example by building their own internal cross-campus and community-wide mesh networks.
Step 3. Federate or peer all local networks until you have one huge city-wide, settlement-free mesh connected to multiple competitive Internet global transit and peer interconnection providers throughout the region.
Step 4. Lower costs permanently by cutting out or outright banning all the middle-monopolist or perpetual-rentier extractions from our communications systems’ value — including all incumbent Big Telco, Big Cable, and all FCC-selected RF monopolists (where our government has always picked the market winners!).

Q: 5.b. What minimum requirement for services and facilities should be required to ensure that underserved populations have access to the Internet.

A: No service or facility should ever again be allowed to become a profiteering bottleneck or extortionate toll-taker between any resident and their nearby competitive Internet global transit providers. Provide affordable financing for everyone to build or vote over their own community network infrastructure, which they can use to bypass all incumbent toll-takers.

Q: 6.a. For an entity that is not interested in responding to an RFP for the LACBN, is there an interest in sponsoring deployment for specific areas (particular public parks, for example) or supporting deployment of services and equipment to underserved communities?

A: Data Roads Foundation and our partner nonprofit utility cooperatives plan to support such deployment with or without assistance from LA City officials. We would rather work with City officials directly than against your lobbyists indirectly.

Q: 6.b. Is sponsorship a feasible way to encourage deployment to particular areas in the City.

A: If monopolists and rentiers are never allowed to extract their tolls from these sponsored resources, then yes. If sponsored equipment and infrastructure resources are subject to perpetual tolls or extractive municipal fees, then no.

Q: 6.c. Does your organization have assets that may be useful for deployment of the LACBN, and that you may be willing to provide for an entity selected through the RFP process? What are those assets?

A: We work with local homes, businesses, and landowners to build community networks on their own private lands, buildings, and their other fixed geographic resources. These assets should always stay in full control of their true owners: the citizens and residents of Los Angeles. They should never be given away to the lobbyist incumbents most likely to be “selected” in a pre-stacked and lobbyist-biased RFP process.

Q: 6.d. Is your organization involved in construction that may make it cheaper to install fiber facilities, where you would be willing to coordinate with an entity selected through the RFP process?

A: The same constituents listed in the prior answer have conduit, shelter, and power resources ready to host fiber, copper, and wireless router facilities. They should coordinate with local nonprofits working in their own community interest, but should never give anything away to the monopolist incumbents most favored by the current predetermined RFP process.

Q: 6.e. Are there particular incentives or steps the City could take to make it easier for a selected provider to gain access to MDUs or to office buildings? Would it be useful to require building owners to identify what rights tenants will have to obtain services from broadband providers?

A: No rentier market incumbent should ever be allowed to restrict any tenant’s competitive access to other markets. Tenants should always have the right, regardless of the location or type of geographically fixed rental, to choose among competitive providers for any nearby service. This competitive market access definition should definitely include global Internet transit markets. No landlord or other rentier should ever be allowed to define or limit these tenant’s market access rights in any way whatsoever.

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  1. I met with Steve Reneker after coordinating the proposed management or acquisition from the SmartRiverside WiFi a couple of years ago in which he had a hand in it deployment. The thing could only do 128K. No kidding. Then after after waiting for 2 hours to meet with official and Reneker…yes they had my team waiting 10 minutes and then introduced us as the “WiFi” guys…what an insult…but my team met with the City of LA who would have been the Deputy Mayor of the Office of Budgeting and Finance, the City Director of Minority Business Office, and Mr. Reneker it was obvious to me where their head was. Not on the shoulders. If you get my drift. Before this though my team met with the officials without Reneker and guess what? I mentioned our working toward a relationship with SmartRiverside and they took my info and contacted the guy when I could have gotten him in my company but to the initial meeting the City of LA had not even heard of the guy. Then the City went behind my back and conjured the guy up after Reneker telling me he was retiring from Government after working with him for 9 months on this project upgrade. Left me holding a bag of information and proposals to go before Riverside with my offering. Now they have this guy doing this with LA? If they do this it will be a disaster just like the 67 million dollars Antonio blew away. Just like LAUSD spending a billion from a school bond fund for infrastructure and instead of building a network for the kids they go buy toys with my tax dollars. The kid of LAUSD has more since than this bag of bolts. I hold my tongue and wait on the fire to go down. But they are setting the stage for Google I believe. Or a mix with Time Warner and others. But, I have a plan and they will be embarrassed for burning us. At any rate that is my rant. Hope they see it.

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