You are right, a simple expression of the goal is almost certainly a far
better way to express a regulation than an endlessly detailed
enumeration of things.
My concerns arise from a variety of sources.
First is the natural inclination of some large organizations to use
regulatory language as a weapon, often twisting inadequately detailed
expressions of intent around a Procrustean iron bed of regulatory
definitions.
Second is that the US Supreme Court seems to be tending to cast disdain
on the expertise of regulatory bodies, such as the FCC, to find sensible
ways through difficult and ambiguous situations. (This legal stuff tends
to go under the header of "Chevron deference" -
https://www.law.cornell.edu/wex/chevron_deference ) Personally, I'd
rather that smart people at the FCC figure this out rather than a bunch
of j-random Congress critters.
Third is that sometimes it is useful to have a bit of financial or
competitive fire to push innovation or to impede ill use. (Imagine if
sending emails had a cost - that could have [perhaps] have slowed the
rise of spam.) So perhaps a small amount of non-neutrality could act as
a driver or catalyst.
I am intrigued by the possibility of obtaining better efficiency from
the net - by using underused bandwidth (hence my example of the spare
space where a small IP packet does not fully occupy a minimum sized
Ethernet frame.) Some of these ideas could cause streams to piggyback
on one another (such as how SMS messaging kinda piggybacked into the
empty spaces of telco signalling protocols.) We tend to focus our
attention of big fat flows, like entertainment video or gaming, but
there are a lot of small flows that could ride, with adequately
reliability, for essentially no technical cost. These could include a
lot of home, security, or medical monitoring stuff.) This is hard to
articulate - but there are real life analogies, such as the notion of
van-pooling to airports, where a single vehicle carries diverse
loads/passengers that have little relationship to one another except
that they are traveling to and from roughly the same locations.)
A while back I wrote some notes about network measuring tools such as
iperf. One of the things that struck me was the number of bits that
wrap even the smallest of packets. (For instance -
https://www.iwl.com/blog/counting-bits ) For video that overhead is
negligible, but for some forms of traffic (e.g. security alarms) that
overhead can add up.
And yes, I am stepping dangerously close to notions of multiplexing
within packets or at least within one of our most common wrappers for IP
packets, Ethernet frames.
--karl--
On 5/15/24 5:55 PM, Vint Cerf wrote:
An interpretation of the intent might be not so much a prohibition of
various grades of service but that all grades are available on the
same terms to all comers.
v
On Wed, May 15, 2024 at 5:43 PM Karl Auerbach via Nnagain
<nnagain@lists.bufferbloat.net> wrote:
As a matter of drafting the FCC has left some potholes:
"We clarify that a BIAS [Broadband Internet Access Service]
provider's decision to speed up 'on the basis of Internet content,
applications, or services' would 'impair or degrade' other
content, applications, or services which are not given the same
treatment,"
That phrase "speed up" is too vague. Does it conflict with active
or fair queue management? Does it prohibit things that some
Ethernet NIC "offloads" do (but which could be done by a provider)
such as TCP data aggregation (i.e. the merging of lots of small
TCP segments into one big one)? Does it prohibit insertion of an
ECN bit that would have the effect of slowing a sender of packets?
Might it preclude a provider "helpfully" dropping stale video
packets that would arrive at a users video rendering codec too
late to be useful? Could there be an issue with selective
compression? Or, to really get nerdy - given that a lot of
traffic uses Ethernet frames as a model, there can be a
non-trivial amount of hidden, usually unused, bandwidth in that
gap between the end of tiny IP packets and the end of minimum
length Ethernet frames. (I've seen that space used for things like
license management.) Or might this impact larger path issues,
such as routing choices, either dynamic or based on contractual
relationships - such as conversational voice over terrestrial or
low-earth-orbit paths while background file transfers are sent via
fat, but large latency paths such as geo-synch satellite? If an
ISP found a means of blocking spam from being delivered, would
that violate the rules? (Same question for blocking of VoIP calls
from undesirable sources. It may also call into question even the
use of IP address blacklists or reverse path algorithms that block
traffic coming from places where it has no business coming from.)
The answers may be obvious to tech folks here but in the hands of
troublesome lawyers (I'm one of those) these ambiguities could be
elevated to be real headaches.
These may seem like minor or even meaningless nits, but these are
the kinds of things that can be used by lawyers (again, like me)
to tie regulatory bodies into knots, which often a goal of some
large organizations that do not like regulation.
In addition, I can't put my finger on it, but I am sensing that
without some flexibility the FCC neutrality rules may be creating
a kind of no cost, tragedy of the commons situation. Sometimes a
bit of friction - cost - can be useful to either incentivize
improvements and invention or to make things (like spam) less
desirable/more expensive to abusers.
--karl--
On 5/10/24 7:31 AM, Frantisek Borsik via Nnagain wrote:
"Net neutrality proponents argued that these separate lanes for
different kinds of traffic would degrade performance of traffic
that isn't favored. The final FCC order released yesterday
addresses that complaint.
"We clarify that a BIAS [Broadband Internet Access Service]
provider's decision to speed up 'on the basis of Internet
content, applications, or services' would 'impair or degrade'
other content, applications, or services which are not given the
same treatment," the FCC's final order said.
The "impair or degrade" clarification means that speeding up is
banned because the no-throttling rule says that ISPs "shall not
impair or degrade lawful Internet traffic on the basis of
Internet content, application, or service."
https://arstechnica.com/tech-policy/2024/05/fcc-explicitly-prohibits-fast-lanes-closing-possible-net-neutrality-loophole/
All the best,
Frank
Frantisek (Frank) Borsik
https://www.linkedin.com/in/frantisekborsik
Signal, Telegram, WhatsApp: +421919416714
<tel:+421%20919%20416%20714>
iMessage, mobile: +420775230885 <tel:+420%20775%20230%20885>
Skype: casioa5302ca
frantisek.bor...@gmail.com
_______________________________________________
Nnagain mailing list
Nnagain@lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain
_______________________________________________
Nnagain mailing list
Nnagain@lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain
--
Please send any postal/overnight deliveries to:
Vint Cerf
Google, LLC
1900 Reston Metro Plaza, 16th Floor
Reston, VA 20190
+1 (571) 213 1346
until further notice
_______________________________________________
Nnagain mailing list
Nnagain@lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain
