From: Vint Cerf <[email protected]> Date: Sun, Jul 15, 2012 at 1:04 AM Subject: Urgent M-LAB issue at FCC Cc: Meredith Whittaker <[email protected]>
I’m writing with an urgent request for your support on an issue that’s crucial to proper scientific treatment of open broadband Internet access measurement. For over two years the FCC has been using M-Lab as the foundation of their broadband measurement program. This was great for policy, and great for accountability, because it meant that the official statistics reported in their publications were made openly available, and that researchers could access the open data and reproduce and expand on the published results. Recently, the FCC measurement program has backed sharply away from their commitment to transparency, apparently at the bidding of the telcos in the program. The program is now proposing to replace the M-Lab platform with only ISP-managed servers. This effectively replaces transparency with a closed platform in which the ISPs -- whose performance this program purports to measure -- are in control of the measurements. This closed platform would provide the official US statistics on broadband performance. I view this as scientifically unacceptable. For the health of the Internet, and for the future of credible data-based policy, the research community must push back against this move. To do this, I am attaching a copy of a joint letter to the FCC. This letter explains why openness is crucial for good science, and rejects the FCC’s move toward closed measurement. I will be signing, and I request your signature. Our deadline for filing this letter is tight. We would like to file before July 19th. Given the nature of the politics here we weren’t able to predict the necessity until recently. I have CCed Meredith Whittaker, who’s managing this effort. She can answer any questions, and will be happy to have a quick call to discuss details. All of the claims made above are thoroughly documented, so please feel free to ask any and all questions. If you will confirm your willingness to sign to Meredith, she can compose the letter with your endorsements and send to the FCC by the 19th. Thank you in advance. vint cerf TEXT OF PROPOSED LETTER TO THE FCC Open data and an independent, transparent measurement framework must be the cornerstones of any scientifically credible broadband Internet access measurement program. Measuring network performance is complex. Even among those of us who focus on this topic as our life’s work, there are disagreements. The scientific process happens best in the sunlight and that can only happen when as many eyes as possible are able to look at a shared set of data, work to replicate results, and assess its meaning and impact. This ensures the conclusions from the broadband measurement allow for meaningful, data-driven policy making. Since the inception of the broadband measurement program, those of us who work on Internet research have lauded its precedent-setting commitment to open-data and transparency. Many of us have engaged with this program, advising on network transparency and measurement methodology and using the openly-released raw data as a part of our research. However, we understand that some participants in the program have proposed significant changes that would transform an open measurement process into a closed one. Specifically, that the Federal Communications Commission (FCC) is considering a proposal to replace the Measurement Lab server infrastructure with closed infrastructure, run by the participating Internet service providers (ISPs) whose own speeds are being measured. In order for the scientific process to work, measurement data must be openly available as well as access to methodologies, and explicit cataloging of assumptions is essential if results are to be confirmed and replicated. A switch from an open to a closed infrastructure makes this process impossible or, at best, questionable. We strongly oppose any decision by the FCC to run a closed measurement program. We urge the managers of the program to reconsider any steps to run measurement tests over closed infrastructure. If expansion of the current infrastructure is needed, those wishing to provision measurement servers should be encouraged to contribute resources to the Measurement Lab Consortium. Measurement Lab is a research network, and operates its servers in a consistent, openly documented manner. This ensures comparable, credible data, and enables the research community to put our faith in the measurement results, and to stake our professional reputations on conclusions based on the data. Sincerely, The undersigned.
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