Speaking the Language of Net Neutrality

10:25 AM -- Some language in the Federal Communications Commission (FCC) 's recently crafted Notice of Proposed Rulemaking (NPRM) on the topic of network neutrality appears to suggest a blanket mandate that would prohibit ISPs from prioritizing access to content and applications. (See FCC Sets Sail on Internet Rulemaking .)

Digital Society, a think tank, recently highlighted its concern that the NPRM prohibits good network management, specifically pointing to paragraph 106 of the proposal:

We understand the term (nondiscriminatory) to mean that a broadband Internet access service provider may not charge a content, application, or service provider for enhanced or prioritized access to the subscribers of the broadband Internet access service provider, as illustrated in the diagram below. We propose that this rule would not prevent a broadband Internet access service provider from charging subscribers different prices for different services. We seek comment on each of these proposals. We also seek comment on whether the specific language of this draft rule best serves the public interest.

The crux of the debate seems to be how such a ban on prioritization might be interpreted.

With the wide range of content flowing through broadband networks, those networks can't be rendered "dumb." ISPs must be allowed to apply network management techniques in order to handle the constantly changing requirements of Internet users. This is not a linear format with constant speeds and demands.

The network must constantly adjust to those varying needs, which may require one user to demand more capacity than others at unique times. This management need not degrade the network for other users. It is a matter of choosing one higher demand over a lower demand without degrading the service for both. The idea is to manage the requirements of each individual user.

But ISPs should know their responsibilities regarding consumer and commercial traffic, and how to manage prioritizations fairly. Obviously, paid peering is needed for those whose products depend on increased speed and bandwidth for business survival. Consumers want a good experience whether they are streaming movies, downloading PDF files, or just sending email attachments.

It comes down to understanding how the Internet works and how network management can be used across a wide variety of circumstances and geographical locations. In essence, what will it take for both large and small ISPs to handle the varying traffic over their networks and upgrade to a standard that reasonably doesn’t degrade the user experience?

The FCC should revisit NPRM Paragraph 106 and make sure proposed net neutrality rules do not discriminate against one party in favor of another.

— Leonard Grace, a cable industry vet, is a telecom strategist and blogger. He can be reached at [email protected]. Special to Cable Digital News

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LeonardGrace 12/5/2012 | 3:50:36 PM
re: Speaking the Language of Net Neutrality The Internet cannot become a (dumb pipe).
fgoldstein 12/5/2012 | 3:50:36 PM
re: Speaking the Language of Net Neutrality <div>&gt; The Internet cannot become a (dumb pipe). </div>
<div>Not sure what you mean by that.&nbsp; But it would help if people had a clear understanding of what the Internet is and isn't.</div>
<div>It's not a pipe.&nbsp; It's not even a TOOB, or a series of them, as Ted said.&nbsp; It's not even a thing.&nbsp; You don't buy access from Internet Inc.; you buy it from an ISP.&nbsp; I like to define Internet as a voluntary agreement among network operators to exchange traffic for their mutual benefit.</div>
<div>Once you start mandating anything, it's no longer voluntary, and thus it's not Internet.&nbsp; That's the trouble with "neutrality" rules -- it adds the Duty to Connect, which is at the heart of common carrier regulation, not Internet.&nbsp; Duty to Connect is accompanied by a reglated price, since there's a terminating monopoly.&nbsp; This is all well and good at the carrier level but Internet is really content, and if content becomes carriage, at what point does content differ from carriage? </div>
<div>The problem is that some service providers would rather replace Internet access, which is basically a wide-open arrangement where subscribers can get almost anything they want, albeit at no guarantee of rate, with application-layer relay, in which content in general is managed by the ISP.&nbsp; Typically to do itemized billing; witness the abomination that is data over cell phones.&nbsp; Neutrality rules are in part a political reaction to that threat.&nbsp; This is what happens when there's not enough competition.&nbsp; Close off market entry, as the FCC has done, and there's every reason to suspect that the protected incumbents will behave as a cartel.
venturecapital 12/5/2012 | 3:50:35 PM
re: Speaking the Language of Net Neutrality

The FCC is saying that it is OK for ISPs to offer users differing grades of service but limits what the ISPs can offer to ASPs. For example, a user could pay extra for a managed-packet-loss-and-delay-variation connection to Hulu, but Hulu cannot differentiate its service by paying extra for such a connection to its users. This is certainly counter to the typical Internet style of users getting things for free (or at least ad supported). It is less than obvious that having the FCC manage Internet market dynamics in this way is such a good thing.


LeonardGrace 12/5/2012 | 3:50:35 PM
re: Speaking the Language of Net Neutrality Thanks for the great comment.

In reference to the (pipe); the Internet flows through a pipe built by the ISPGÇÖs, albeit, it also flows through Wireless connections. The fact remains it is not a linear format that can give equal access to content via, (one behind another). It has to be flexible in that varying content requirements are given their unique priority at any given time. Therefore, it canGÇÖt give equal access without good network management practices.

ISPGÇÖs have been allowed to create their own private networks, which they should manage in a responsible way allowing everyone to get what they want, when they want it, over the Internet. It is in their best interest to do so, creating different pricing schemes for varying customer needs, whether consumer or business. They have a tremendous responsibility to make sure their networks are upgraded to handle the increasing demands that content and applications will bring, in possibly avoiding regulation.

But again, it is a private network. The FCC must look at this carefully and not create one problem by attempting fix another. I have always felt that competition is the best answer in this type situation, but with privately owned networks that have been consolidated; this may not be an easy task.
bollocks187 12/5/2012 | 3:50:35 PM
re: Speaking the Language of Net Neutrality Well stated.

"This is what happens when there's not enough competition. Close off market entry, as the FCC has done, and there's every reason to suspect that the protected incumbents will behave as a cartel."
LeonardGrace 12/5/2012 | 3:50:34 PM
re: Speaking the Language of Net Neutrality In fact, Internet Service Providers sell access through their pipelines to all users. So, your point is lost on me. If you choose to make this kind of statement, and refer to someone as (muddle-headed), then you should back it up with research, including Brookseven's credentials and identity...just so we are on the same playing field.
paolo.franzoi 12/5/2012 | 3:50:34 PM
re: Speaking the Language of Net Neutrality


Back to the ASP thing.&nbsp; In my mind there are in fact NO ISPs.&nbsp; There are ASPs that give away ISP services.&nbsp; Why is that?&nbsp; Because, there is no value in being an ISP.&nbsp; You can NOT guarantee a service.&nbsp; No ISP has full end to end control over 100% of any connection that is truly an Internet connection.&nbsp; This is different than providing end to end IP services and sharing the same equipment and some of the same connections as the Internet service.

So, again - I think the whole thing is muddle headed when you use the word ISP.&nbsp; People pay for ASPs and get their ISP for free.



LeonardGrace 12/5/2012 | 3:50:34 PM
re: Speaking the Language of Net Neutrality Well said, an to my point.

fgoldstein 12/5/2012 | 3:50:33 PM
re: Speaking the Language of Net Neutrality

Seven, I think you're playing semantic games around the meaning of "ISP".&nbsp; If you define the term away, it doesn't exist, but your definition needn't be the only one.

The legal&nbsp; notion of ISP evolved from the old "value-added networks" (VANs) and fro time-sharing services.&nbsp; The Computer Decisions began with 1968's Computer I defining computer services as non-telecom, even if accessed over the payload of telecom.&nbsp; They left a gap in the middle for "hybrid" services, case-by-case, and within that, VANs were first tariffed, then later detariffed.&nbsp; Computer II made a clearer distinction between payload and carriage.&nbsp; It, along with the Sharing and Resale Order (which made it possible for ESPs/VANs/ISPs to purchase circuits to customers from telcos without themselves being carriers), made the commercial Internet possible.

As the commercial Internet evolved within the protection of Computer II/III, in the 1992-1996 time frame, three separate functions fell within the term:

<li>iAccessSPs were the rent-a-modem *and* DSL providers who bought wholesale local telecom.</li>
<li>iVeriticalSPs were the server operators, hosters, and retail service providers (like AOL).</li>
<li>iBackboneSPs were the backbone peers, buying LD telecom.</li>

The IASP and IBSP functions were typically wholesale, or sold to big enterprises; anybody could set up an IVSP and buy access from an IASP and backbone from an IBSP.&nbsp; LECs were, under Computer II/III, required to sell raw DSL to them, as telecom, not IASP.&nbsp; CLECs could do this too, like Covad, but they depended on unbundled ILEC loops. An ASP is a souped-up IVSP, but the IVSP made routing decisions (cut off this spammer or pink networks, assign this much CIR to that peer, etc.) which an ASP leaves to others.

The Cheney-Rove FCC declared War on ISPs and barred all of the gates.&nbsp; They drastically limited unbundled loops, so maybe half of US homes and businesses can be reached by them, and it's declining.&nbsp; They took away common carriage and revoked the Computer Decisions, so ISPs can't use telco services.&nbsp; In rural areas, Part 15 wireless is what's left. And all wireless is capacity-constrained by physics.&nbsp; (Bits are power.)&nbsp; Turn up the average bit rate (not the peak) and wireless rapidly loses out to wireline.&nbsp; Video over Internet does that.&nbsp; Game, set, match.

The current FCC is not doing squat to fix this; Blair Levin, in charge of the Broadband Plan, sounds like Kevin Martin preaching no unbundling, no common carriage, just a duopoply of wireline plus medium-speed wireless (VZW and ATTM) as the main competitors to, uh VZ and ATT.&nbsp; But hey, he'll regulate the content!&nbsp; Since they're preaching vertical integration of the natural-monopoly IASPs with the naturally-competitive IVSPs, the vital funtion of the IVSP is lost, and the IASP's choice of content and policy lterally becomes a Federal Case.

This is all heavily leavened by the fiction that TCP/IP is a decent protocol suite, takes care of things, and scales. And the even more preposterous fiction that the IETF has a shred of instituional competence.

There still is a role for ISPs.&nbsp; But policy decisions made to benefit the Bells and knock out their competitors have hidden them inside other companies.&nbsp; That's bad policy.&nbsp; There's far too much vertical integration and far too little competition in the switching and service layers.&nbsp; And whining for "neutrality" doesn't fix things; it just replaces one broken substitute for Internet (Fat Wasteband) with another (regulated but unstable, spam-ridden public packet networks).

venturecapital 12/5/2012 | 3:50:33 PM
re: Speaking the Language of Net Neutrality Sorry for the confusing terminology. By ASP I was referring to Application Service Provider (e.g., Hulu) and not Access Service Provider that I referred to as an ISP (to avoid confusion with the other "ASP").
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