[conspire] (forw) Legacy DSL ending at Raw Bandwidth on 12/19/19 - please read carefully!

[Rick Moen]

I've been a (deservedly) loyal Raw Bandwith Comunnications customer
since Jan. 2001, when NorthPoint Communications suddenly went out of
business and I was obliged to find a quick replacement for NorthPoint
SDSL service.  

Although sadly I'll not be in Raw Bandwidth's (reduced) DSL service area
starting Dec. 19th, I continue to strongly recommend that company to
others who're in their service area.

Obviously, my residence will soon be making some changes.


----- Forwarded message from Mike Durkin <mdurkin at rawbw.com> -----

Date: Mon, 11 Nov 2019 19:35:43 -0800 (PST)
From: Mike Durkin <mdurkin at rawbw.com>
To: [my contact address for billing purposes]
Subject: Legacy DSL ending at Raw Bandwidth on 12/19/19 - please read
	carefully!

Rick,

This notice is only about your DSL service on top
of landlineline phone number: 650-561-9820

Please read this notice carefully, and let me know if you have any questions.
Please reply to acknowlege receipt and confirm that you understand the
implications of this notice in any event, because I will be proactively
contacting anyone who hasn't acknowledged it in order to make sure everyone
affected understands what's happening and the implications, and
a quick acknowledgement to this email if you understand will make
that process go faster...

You are receiving this message because you're a Raw Bandwidth/Tsoft
customer still using Legacy DSL, where the DSLAM equipment and network
is operated by AT&T/Pacific Bell on top of an active voice/landline phone
service line from AT&T, who then hands off data to Raw Bandwidth in order
to provide the Internet service on top.

Unfortunately the time has come that we have to retire this particular
platform's service, and we will no longer be able to provide Internet
access at your location as of December 19th, 2019.  It's imperative that
you begin the process of switching to another access provider to ensure
continued Internet access of some sort before then.  Depending on the
provider you choose and type of service, it may take up to several weeks
to switch service (typically at least several days).

Note that this notice applies only to Legacy DSL on top of an
AT&T phone service line at speeds up to 6Mbps per line (the underlying
phone service phone # noted at the top of this email).  If you have
other service with us using our CLEC DSL where we operate the DSL
equipment ourselves and provide standalone DSL independent from phone
service (including at speeds both below and above 6Mbps), this
notice does *not* apply to that service.  Our CLEC DSL has a much
narrower geographic coverage area than Legacy DSL, and any customers
we can service on our CLEC DSL have or soon will be contacted
to migrate to that, rather than receive this notice.  If you're
receiving this notice directly from Raw Bandwidth however, at least
one of your services is affected and we don't have viable replacment
DSL service for your Legacy DSL service location.

Your service should continue to function through December 19th if you
haven't switched (and if your landline phone service remains
functional with AT&T), but will cease then.  If you switch to another
provider prior to then, please let me know and we can end your
DSL service with us early.  Once your particular end date has
been determined, you'll receive a prorated refund or credit
adjustment for any period of time paid beyond your DSL service's end
date.  Most customers on Legacy DSL don't have loaner DSL equipment
to return, but in the event you do, I'll provide return instructions
separately.

Additionally, if you have any other adjunct services with us that
you want to retain, that is generally feasible, including email,
web hosting, and shell accounts.  Please contact me to sort out what
you'll be retaining, but in any event if you have adjunct services that
appear to be in use, we'll confirm your intentions with those before
closing them.  Note for our shell and hosting services, we're about
to begin migrations to a new server with the most up-to-date software
and increased disk quota.

This service retirement is *not* related to the USTelecom Forebearance
proceeding that I emailed about back in late August 2018.  That
proceeding ended with AT&T and the ILECs getting a lot of the
forbearance they requested but mostly related to voice service, and
left in place access to the elements we most need for our CLEC
DSL, so our CLEC DSL continues largely unaffected for now.  But Legacy
DSL operated by AT&T was actually set on this path largely because of
rulemaking that the FCC did back at the end of 2005.  After the Brand X
loss at the Supreme Court in early 2005, the FCC was left with discretion
as to how to harmonize treatment of cable modem and DSL for third-party
access.  Instead of opening up cable modem service to multiple Internet
access providers on top like ILEC DSL had been since its inception, the
FCC chose to relieve the ILECs of their layer 2 wholesale obligation for
their DSL, what I'm calling Legacy DSL here.  (It did not affect
the Telecom Act obligation of ILECs to rent the copper pairs
for a competitive provider to service with their own DSL equipment
like we now do with or CLEC DSL.)  Technically by late 2006, AT&T
had the right to kick all other Internet providers off their
Legacy DSL network, but instead they chose to more or less freeze
it and allow the third-party ISPs to stay, while deploying their newer
and often faster U-verse DSL network along with video service
with no third-party access to the newer network.

So we continued to have access, but speeds were never improved,
standalone DSL (without the phone service) was never offered on
the wholesale side of Legacy DSL, and over the years AT&T's support
for the remaining Legacy DSL lines has faltered compared to what it
once was, fallen to sometimes unacceptable experiences.  In addition
as demand for faster speeds and availability of it has come about,
our and other provider's customer counts on Legacy DSL have slowly
dropped through attrition and have had slowing to non-existent new
sales.  Today, we don't have enough customers left on Legacy DSL to make
it financially viable, because of high fixed backhaul costs to
interconnect with AT&T.  So the time has come to end our support
for the service.  Most other ISPs using the Legacy DSL platform
have stopped taking new customers on Legacy DSL years ago, if not
also ended their own support for it.

On Legacy DSL, at one point we had customers served across about
95 different AT&T central office buildings in the SF Bay Area.  We have
deployed our own CLEC DSL equipment to 18 central offices, mostly
in SF and down the Peninsula to service as far a south as the northern
end of the City of San Mateo (which is served from the Burlingame
central office), with a couple more in Oakland and around the bottom
of the Bay in Union City, Milpitas, Santa Clara, and Los Altos.
Over the last couple years it's become apparent that continuing
to expand our CLEC DSL would not be a wise investment--both because
of the regulatory situation with the threat of Telecom Act forbearance,
and the competitive issues with Fiber to the Home becoming more widely
available, and the speeds available via DSL more limited in comparison
to other options.  Even within some central offices that we continue to
have CLEC DSL available in, some of our customers are so far
from the central office building that they needed to be served
from remote terminal DSL equipment on Legacy DSL, where the DSL
equipment is in a cabinet on the side of the road closer to shorten
the copper wire distance, and only AT&T has put in remote terminal DSL
equipment in the Bay Area, so those customers needing remote-terminals
for DSL due to a long distance from the central office are not servicable
on our CLEC network.

Some ISPs have chosen to resell AT&T U-verse service (which they
now just call AT&T Internet whether it's delivered via DSL, fiber,
or other means), but AT&T's U-verse/Internet service has never
been available at layer 2, that is it's not available in a way that
third-party ISPs can deliver their own Internet access over the
top of it, it just always has AT&T's own Internet access bundled
in even if you're getting it through a third-party ISP.  We have
chosen not to resell AT&T's Internet service due to the limited ability
to improve it, and instead focus on areas where we can continue
to deliver our own Internet access service.  To that end, we'll continue
to deliver our CLEC DSL to locations where it is viable and as long as
the regulatory and competive environment alllow, and will focus
on trying to expand into multitenant properties in particular
using fixed wireless and fiber where we can, then distributing
service on site using local DSL, ethernet, fiber to the home, etc.
We are also looking at some competitive options for layer 2 access
on wholesale networks to reach single family homes and smaller
apartment buildings to expand geographic coverage again. But for
now, we don't have a replacement access option to reach your current
location served by Legacy DSL.

Please take steps to begin deciding on your replacement service,
determine leadtimes needed, etc. to ensure that you have replacement
service in place by December 19th.

If you have any questions, or need assistance in locating a
suitable alternative service, please reply.

thanks, Mike


----- End forwarded message -----