Re: Net neutrality filing

[Stephen Satchell]

On 06/17/2017 02:10 PM, Jeremy Austin wrote:
> I appreciate that a target of 35,000 per county or "county equivalent"
> (parish, borough?) is just a number — but I believe I would prefer a metric
> keyed to actual geographic population density rather than to political or
> municipal boundaries qua boundaries. At least it seems to me that you are
> wanting to encourage rural development, given that the current broadband
> 'divide' is largely a rural vs. urban one, according to the 2016 Broadband
> Progress Report.

If you have a better idea regarding how to differentiate rural monopoly
broadband providers to urban monopoly providers, please submit a comment
to the FCC about your ideas of the right way to differentiate them.

> Natural monopolies worked for electrification. Do you anticipate Title I
> providers as being sufficient to the task of narrowing this divide, with or
> without a federal incentives program? Historically, federal incentives have
> largely gone to Title II providers or their affiliated ISPs, if I
> understand the math correctly.

Title I providers did an excellent job back in the early days of the
Internet providing service in virtually every area, including rural
locations.  Let me explain.

I was on the Telecommunications Industry Associations' Transmitter Group
30 (TR30) by invitation of members, because I was publishing modem
reviews in places like Byte and MacWorld magazines.  The membership
invited me to learn how to do it "right" to better serve the readership.

(By the way, TIA TR30 used to be known as the "Modem Working Group".
See the references to 47 CFR 68.)

What was interesting is that the model "loops" (telephone circuits)
included wire simulation for calls between  rural locations to town
upramps to the 'Net.  When I incorporated the recommended loop models in
my testing, I was able to show what modems would be good for the
outliers to use.  In that sense, that was the industry's way of trying
to serve everyone, not just the "townies".

The only Title II involvement was over the PSTN circuits themselves.

Now, I can't talk to federal incentives.  I can understand why, though
-- the large providers have enough lawyers to put in bids "in the proper
language" to win awards.  The small ISPs can't afford a law firm with
sixty names on the masthead.

You may want to check the FCC site to see if there is a NPRM on
subsidies on rural broadband, and comment on the questions contained in
such a document.  Or file a request for consideration -- there is a way
to do that on EFCS.

Re: Net neutrality filing

[Jeremy Austin]

On Sat, Jun 17, 2017 at 9:54 AM, Stephen Satchell  wrote:

>
> It does have a few color pictures, though.  And one comic strip.
>

Upvote for use of 'caisson'.

There is at least one thing that Sen. Ted Stevens got right; in the fiber
era, the Internet really *is* a series of tubes.

I appreciate that a target of 35,000 per county or "county equivalent"
(parish, borough?) is just a number — but I believe I would prefer a metric
keyed to actual geographic population density rather than to political or
municipal boundaries qua boundaries. At least it seems to me that you are
wanting to encourage rural development, given that the current broadband
'divide' is largely a rural vs. urban one, according to the 2016 Broadband
Progress Report.

Natural monopolies worked for electrification. Do you anticipate Title I
providers as being sufficient to the task of narrowing this divide, with or
without a federal incentives program? Historically, federal incentives have
largely gone to Title II providers or their affiliated ISPs, if I
understand the math correctly.

https://www.brookings.edu/blog/the-avenue/2017/02/13/in-infrastructure-plan-a-big-opening-for-rural-broadband/

Jeremy Austin

Re: Net Neutrality in Canada

[Rod Beck]

Zero rating is probably pretty popular with end users and puts net neutrality 
advocates in a difficult position. It is an astute political move. The EU 
allowing zero ratings exceptions because it is popular.


- R.



From: Jean-Francois Mezei <jfmezei_na...@vaxination.ca>
Sent: Sunday, October 30, 2016 9:19 PM
To: Rod Beck; Nanog@nanog.org
Subject: Re: Net Neutrality in Canada

On 2016-10-30 14:20, Rod Beck wrote:
> Hi Jean,
>
>
> What is the status of net neutrality in Canada?


The Telecom Act has had a clasue against undue
preference/discrimination, as well as a "cannot control content", but
both have loopholes. (27(2) , a carrier can argue a
preference/discrimination is not "undue", and for 36 (control of
content), exemptions can be granted by CRTC.

The 2009 ITMP framework was more about throttling and treating packets
differently.

In 2010, the CRTC decided to include wireless services into the ITMP
framework, treating them as ISPs.


 But since then, incumbents have begun to zero rate stuff and there were
2 challenges. In 2013 (decided in 2015), Bell Canada was challenged for
zero rating its own TV service on its own wireless service.  CRTC
decided Bell couldn't do that, but Bell went to Federal Court of Appeal,
arguing its MobileTV offering was covered under the Broadcasting Act and
not Telecom. Federal Court sided with CRTC, confirming that the content
may have been Broadcasting but it was delivered over telecom.

Despite this, Vidéotron launched Zero Rating for music in August 2015,
and instead of deciding on this the same way it did for Bell, the CRTC
decided to launch a wider public consultation on whether zero rating
should be allowed or not.

The hearing that will happen this week is a continuation of a process
which saw 2 rounds of submissions as well as 2 interrogatories and
included the record of the Vidéotron process from 2015. In a couple of
weeks we have final replies and CRTC will take 4-6 months to rule on matter.

Competition Bureau basically says that zero rating is OK unless the
contrent being zero rated is owned by the ISP's organisation. Consumer
groups state it isn't OK, and incumbents state it is OK and that there
should simply be individual challenges whenc onsumers feel one package
abuses 27(2) or 36.

As side note: Telus hires Eisenach lobbyist to write pro-incumbent
reports. He was also hired by the Trump campaign. Not sure if he will
appear this week.

Re: Net Neutrality in Canada

[Jean-Francois Mezei]

On 2016-10-30 14:20, Rod Beck wrote:
> Hi Jean,
> 
> 
> What is the status of net neutrality in Canada?


The Telecom Act has had a clasue against undue
preference/discrimination, as well as a "cannot control content", but
both have loopholes. (27(2) , a carrier can argue a
preference/discrimination is not "undue", and for 36 (control of
content), exemptions can be granted by CRTC.

The 2009 ITMP framework was more about throttling and treating packets
differently.

In 2010, the CRTC decided to include wireless services into the ITMP
framework, treating them as ISPs.


 But since then, incumbents have begun to zero rate stuff and there were
2 challenges. In 2013 (decided in 2015), Bell Canada was challenged for
zero rating its own TV service on its own wireless service.  CRTC
decided Bell couldn't do that, but Bell went to Federal Court of Appeal,
arguing its MobileTV offering was covered under the Broadcasting Act and
not Telecom. Federal Court sided with CRTC, confirming that the content
may have been Broadcasting but it was delivered over telecom.

Despite this, Vidéotron launched Zero Rating for music in August 2015,
and instead of deciding on this the same way it did for Bell, the CRTC
decided to launch a wider public consultation on whether zero rating
should be allowed or not.

The hearing that will happen this week is a continuation of a process
which saw 2 rounds of submissions as well as 2 interrogatories and
included the record of the Vidéotron process from 2015. In a couple of
weeks we have final replies and CRTC will take 4-6 months to rule on matter.

Competition Bureau basically says that zero rating is OK unless the
contrent being zero rated is owned by the ISP's organisation. Consumer
groups state it isn't OK, and incumbents state it is OK and that there
should simply be individual challenges whenc onsumers feel one package
abuses 27(2) or 36.

As side note: Telus hires Eisenach lobbyist to write pro-incumbent
reports. He was also hired by the Trump campaign. Not sure if he will
appear this week.

Re: Net Neutrality in Canada

[Rod Beck]

Hi Jean,


What is the status of net neutrality in Canada?


Regards,


Roderick.



From: NANOG  on behalf of Jean-Francois Mezei 

Sent: Sunday, October 30, 2016 6:52 PM
To: Nanog@nanog.org
Subject: FYI: Net Neutrality in Canada

This is a heads up, the CRTC (Canada's FCC) is holding a week long
hearing on net neutrality in Canada ("differential pricing" is the used).

Canada has had its "ITMP" (Internet Traffic Management Practices) policy
since 2009 which deals with unfair throttling, and now, we are arguing
on zero rating and sponsored content stuff).


It will be broadcasted at http://www.cpac.ca  (at bottom of home page
[http://www.cpac.ca/wp-content/uploads/default_2016_social_seo_logo_500x230.jpg]

CPAC - Cable Public Affairs Channel
www.cpac.ca
CPAC, the Cable Public Affairs Channel, is Canada's only privately-owned, 
commercial free, not for profit, bilingual television service.


there should be a selection for the CRTC hearing). Note: you can choose
between english, french of floor (untranslated).

Days generally start at 09:00. Can end at any time.

Either @CRTCeng or @CRTChearings will be tweeting links to presentations
as each presentation begins.

hashtag: #CRTC #Diffpricing


Facebook did not wish to appear but was "invited". Last time the CRTC
did that, it was with Netflix and Google and sparks flew ("you don't
regulate us, we don't have to answer"). (It appears on Tuesday right
after me, so they should be roughly ~ 10:30 or 11:00.)

The agenda:
http://www.crtc.gc.ca/Telecom/eng/HEARINGS/2016/ag31_10.htm

The original Notice of Consultation:
> http://crtc.gc.ca/eng/archive/2016/2016-192.htm?_ga=1.136052530.24154879.1433393531

And the record of the consultation:
> https://services.crtc.gc.ca/pub/instances-proceedings/Default-defaut.aspx?EN=2016-192=eng&_ga=1.136052530.24154879.1433393531

Note: this started with a different proceeding in September 2015 2 parts
1 filings against Vidéotron who started zero rated music on its wireless
service for music services that Vidéotron approved/selected.
> https://services.crtc.gc.ca/pub/instances-proceedings/Default-Defaut.aspx?lang=eng=2015=C=t=pt1=a#201510735

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Mark Tinka]

On 16/Aug/15 00:50, Harry McGregor wrote:


  

 Before this happens (ie when hell freezes over), I would like to see
 new home communities deploying fiber networks as part of the building
 of the master plan of the community.   That way the home owners
 association can go out for bid every year or few years for a service
 provider to operate the fiber network. 

This is exactly what communities in South Africa are starting to do.

In major suburbs around Johannesburg, neighborhoods are getting their
residents together and putting out bids for service providers to build
and operate FTTH networks on their behalf. In other parts of the
country, the local city or municipal councils are also getting involved.

In other neighborhoods, new and lean service providers are, by their own
volition, pulling fibre into various neighbors and deploying GPON FTTH
access nodes in homes regardless of whether you want a service or not.
If you want the service, ring them up and someone will come set you up.
You only pay for the setup fee, as the ONU remains theirs. This is what
happened in my neighborhood, which means I'm now sitting on a 25M/25M
FTTH service for about US$70/month. Big difference from when I had a
384k/3.2M ADSL service for about the same price.

The idea is that folk are taking matters into their own hands, as while
there is a national broadband strategy, its actual implementation is a
far cry.

Mark.

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Mark Tinka]

On 15/Aug/15 22:01, Owen DeLong wrote:


 IMHO, there’s only one yes answer here… If enough of the eyeball/content
 providers are able to cooperate and peer with each other directly, you might
 see a significant impact (reduction in need) on transit providers as their 
 entire
 business would become largely irrelevant.

This will work in a single market.

I've thought about this before too - when you start to cross nations or
continents, transit providers became a necessity; the eyeball networks
are typically not geared up to handle international or trans-continental
communications on their own.

The solution would be content providers deploying in each country to
remove the need for transit, but they still have to feed those clusters
somehow.

Ultimately, the big content players build and run their own networks,
completely bypassing the transit providers and peering with the eyeball
(and all) networks wherever they pitch tent. As it were, not all of them
have this muscle.

Mark.

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Mark Tinka]

On 15/Aug/15 22:45, jim deleskie wrote:

 There is more to it, then just being tired of it, it take, $$ and time
 and bodies to build a network, even in 1 country.  Its not something
 everyone can do.  I suspect the game and transit networks, will
 continue long after most of us are no long playing

I do not disagree.

Mark.

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[jim deleskie]

There is more to it, then just being tired of it, it take, $$ and time and
bodies to build a network, even in 1 country.  Its not something everyone
can do.  I suspect the game and transit networks, will continue long
after most of us are no long playing


On Sat, Aug 15, 2015 at 5:35 PM, Mark Tinka mark.ti...@seacom.mu wrote:



 On 15/Aug/15 19:32, jim deleskie wrote:

  In my 20+ yrs now of playing this game, everyone has had a turn
 thinking
  their content/eyeballs are special and should get free peering.

 That's why those tired of playing the game build their own networks to
 take out the middleman, for better or worse.

 Mark.

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Harry McGregor]

On 08/15/2015 09:44 AM, Owen DeLong wrote:
snip


The most viable solution, IMHO, is to require a separation between physical 
infrastructure providers and those that provide services over that 
infrastructure. Breaking the tight coupling between the two and requiring 
physical infrastructure providers to lease facilities to operators on an equal 
footing for all operators will reduce the barriers to competition in the 
operator space. It will also make limited competition in the facilities space 
possible, though unlikely.

This model exists to some extent in a few areas that have municipal residential 
fiber services, and in most of those localities, it is working well.

That’s one of the reasons that the incumbent facilities based carriers have 
lobbied so hard to get laws in states where a city has done this that prevent 
other cities from following suit.

Fortunately, one of the big gains in recent FCC rulings is that these laws are 
likely to be rendered null and void.

Unfortunately, there is so much vested interest in the status quo that 
achieving this sort of separation is unlikely without a really strong grass 
roots movement. Sadly, the average sound-bite oriented citizen doesn’t know (or 
want to learn) enough to facilitate such a grass-roots movement, so if we want 
to build such a future, we have a long slog of public education and recruitment 
ahead of us.

In the mean time, we’ll get to continue to watch companies like CC, VZ, TW 
screw over their customers and the content providers their customers want to 
reach for the sake of extorting extra money from both sides of the transaction.

Owen


I have talked about this idea for years, but most places seem to have a 
difficult time understanding the difference between layer 0, layer 2, 
and layer 3 networks.


IMHO the should be one residential fiber network (either passive or 
active, depending on the deployment and the physical layout of the 
area), and it should be run by an essential utility, such as the 
city/county water department, or if necessary the local electric company 
(I far prefer the water department).  The access would be near 
universal, and the layer 0 and layer 2 network fees would be part of the 
water bill.  Apartment complexes may have to be serviced with G.fast 
or other technologies to make the deployment faster and easier.


Getting IP bandwidth, technical support, voice service, and video 
service would be a competitive service provider model, with local ISPs, 
and large Cable COs and TelCOs competing on top of this physical 
network.  You could even have providers that specialize in low income 
life line services, such as 5Mbit of IP bandwidth and local voice 
service with e911.


Historically services that have huge sunk costs, and high build out 
costs have been a natural monopoly and regulated.  You would not think 
of trying to build out a competitive water or sewer network, and most 
building codes prevent the installation of a septic system if a sewer 
connection is at all possible.   Why we are not going this way for a 
high cost of build out network (last mile) is beyond me.


Before this happens (ie when hell freezes over), I would like to see new 
home communities deploying fiber networks as part of the building of the 
master plan of the community.   That way the home owners association 
can go out for bid every year or few years for a service provider to 
operate the fiber network.   Around here (souther AZ) new communities 
tend to either alliance with CenturyLink, Cox, or Comcast depending on 
the location, and they DO NOT bring in the other providers.  If a 
builder goes with Cox, you can NOT get a CenturyLink (ILEC) landline or 
DSL, if a builder goes with CenturyLink, Cox will not run anything into 
the community.


-Harry

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Mike Hammett]

I think we're on the same side, just saying it differently substituting greed 
for arrogance. 

Additionally, the last mile providers are acting no differently than a carrier 
would, getting paid on both sides... only carriers are typically balanced 
ratios where as last mile\first mile are not. 




- 
Mike Hammett 
Intelligent Computing Solutions 
http://www.ics-il.com 



Midwest Internet Exchange 
http://www.midwest-ix.com 


- Original Message -

From: Owen DeLong o...@delong.com 
To: Mike Hammett na...@ics-il.net 
Cc: nanog@nanog.org 
Sent: Saturday, August 15, 2015 12:18:04 PM 
Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent 
in Dallas 

Your reply implies that your understanding does not match my intended meaning. 

(IOW, Perhaps you did not receive what I intended to transmit) 

I’m saying that the incumbents in an act of unreasonable greed are demanding 
money for peering from providers with a lot of content providers while also 
collecting money from their direct customers for the sake of delivering that 
same content. 

It would be like me standing between you and a hotdog stand and demanding that 
you give me 1.5x the price of the hotdog and then demanding that the hotdog 
stand sell me the hotdog to give to you for 0.5x the listed price. 

In the more functional physical world, you simply walk around me and buy the 
hotdog for 1x the listed price and the only one who loses is the guy standing 
in the middle. 

In the case of the incumbent facilities based carriers, they’ve managed to 
build a wall in front of the hot dog stand and a wall in front of you such that 
your view is limited to the window that they have to open and so is the hot dog 
vendor. Thus, you have no choice but to give them the extra 50% for the hot dog 
and the hot dog vendor has no choice but to give them half of the listed price 
as a “delivery charge”. 

Admittedly, the fractions are not as I described, but the basic principle is 
exactly as I have described it. 

Owen 

 On Aug 15, 2015, at 09:59 , Mike Hammett na...@ics-il.net wrote: 
 
 Arrogance is the only reason I can think of why the incumbents think that 
 way. I'd be surprised if any competitive providers (regardless of their 
 market dominance) would expect free peering. 
 
 
 
 
 - 
 Mike Hammett 
 Intelligent Computing Solutions 
 http://www.ics-il.com 
 
 
 
 Midwest Internet Exchange 
 http://www.midwest-ix.com 
 
 
 - Original Message - 
 
 From: Owen DeLong o...@delong.com 
 To: Matthew Huff mh...@ox.com 
 Cc: nanog@nanog.org 
 Sent: Saturday, August 15, 2015 11:44:57 AM 
 Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and 
 Cogent in Dallas 
 
 This issue isn’t limited to Cogent. 
 
 There is this bizarre belief by the larger eyeball networks (and CC, VZ, and 
 TW are the worst offenders, pretty much in that order) that they are entitled 
 to be paid by both the content provider _AND_ the eyeball user for carrying 
 bits between the two. 
 
 In a healthy market, the eyeball providers would face competition and the 
 content providers would simply ignore these demands and the eyeballs would 
 buy from other eyeball providers. 
 
 Unfortunately, especially in the US, we don’t have a healthy market. In the 
 best of circumstances, we have oligopolies and in the worst places, we have 
 effective (or even actual) monopolies. 
 
 For example, in the area where I live, the claim you will hear is that there 
 is competition. With my usage patterns, that’s a choice between Comcast (up 
 to 30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up to 30/15 
 $500+/month). 
 
 I’m not in some rural backwater or even some second-tier metro. I’m within 10 
 miles of the former MAE West and also within 10 miles of Equinix SV1 (11 
 Great Oaks). There’s major fiber bundles within 2 miles of my house. I’m near 
 US101 and Capitol Expressway in San Jose. 
 
 The reason that things are this way, IMHO, is because we have allowed 
 “facilities based carriers” to leverage the monopoly on physical 
 infrastructure into a monopoly for services over that infrastructure. 
 
 The most viable solution, IMHO, is to require a separation between physical 
 infrastructure providers and those that provide services over that 
 infrastructure. Breaking the tight coupling between the two and requiring 
 physical infrastructure providers to lease facilities to operators on an 
 equal footing for all operators will reduce the barriers to competition in 
 the operator space. It will also make limited competition in the facilities 
 space possible, though unlikely. 
 
 This model exists to some extent in a few areas that have municipal 
 residential fiber services, and in most of those localities, it is working 
 well. 
 
 That’s one of the reasons that the incumbent facilities based carriers have 
 lobbied so hard to get laws in states where a city has done this that prevent 
 other cities from following suit

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[jim deleskie]

In my 20+ yrs now of playing this game, everyone has had a turn thinking
their content/eyeballs are special and should get free peering.

On Sat, Aug 15, 2015 at 1:59 PM, Mike Hammett na...@ics-il.net wrote:

 Arrogance is the only reason I can think of why the incumbents think that
 way. I'd be surprised if any competitive providers (regardless of their
 market dominance) would expect free peering.




 -
 Mike Hammett
 Intelligent Computing Solutions
 http://www.ics-il.com



 Midwest Internet Exchange
 http://www.midwest-ix.com


 - Original Message -

 From: Owen DeLong o...@delong.com
 To: Matthew Huff mh...@ox.com
 Cc: nanog@nanog.org
 Sent: Saturday, August 15, 2015 11:44:57 AM
 Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and
 Cogent in Dallas

 This issue isn’t limited to Cogent.

 There is this bizarre belief by the larger eyeball networks (and CC, VZ,
 and TW are the worst offenders, pretty much in that order) that they are
 entitled to be paid by both the content provider _AND_ the eyeball user for
 carrying bits between the two.

 In a healthy market, the eyeball providers would face competition and the
 content providers would simply ignore these demands and the eyeballs would
 buy from other eyeball providers.

 Unfortunately, especially in the US, we don’t have a healthy market. In
 the best of circumstances, we have oligopolies and in the worst places, we
 have effective (or even actual) monopolies.

 For example, in the area where I live, the claim you will hear is that
 there is competition. With my usage patterns, that’s a choice between
 Comcast (up to 30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up
 to 30/15 $500+/month).

 I’m not in some rural backwater or even some second-tier metro. I’m within
 10 miles of the former MAE West and also within 10 miles of Equinix SV1 (11
 Great Oaks). There’s major fiber bundles within 2 miles of my house. I’m
 near US101 and Capitol Expressway in San Jose.

 The reason that things are this way, IMHO, is because we have allowed
 “facilities based carriers” to leverage the monopoly on physical
 infrastructure into a monopoly for services over that infrastructure.

 The most viable solution, IMHO, is to require a separation between
 physical infrastructure providers and those that provide services over that
 infrastructure. Breaking the tight coupling between the two and requiring
 physical infrastructure providers to lease facilities to operators on an
 equal footing for all operators will reduce the barriers to competition in
 the operator space. It will also make limited competition in the facilities
 space possible, though unlikely.

 This model exists to some extent in a few areas that have municipal
 residential fiber services, and in most of those localities, it is working
 well.

 That’s one of the reasons that the incumbent facilities based carriers
 have lobbied so hard to get laws in states where a city has done this that
 prevent other cities from following suit.

 Fortunately, one of the big gains in recent FCC rulings is that these laws
 are likely to be rendered null and void.

 Unfortunately, there is so much vested interest in the status quo that
 achieving this sort of separation is unlikely without a really strong grass
 roots movement. Sadly, the average sound-bite oriented citizen doesn’t know
 (or want to learn) enough to facilitate such a grass-roots movement, so if
 we want to build such a future, we have a long slog of public education and
 recruitment ahead of us.

 In the mean time, we’ll get to continue to watch companies like CC, VZ, TW
 screw over their customers and the content providers their customers want
 to reach for the sake of extorting extra money from both sides of the
 transaction.

 Owen

  On Aug 15, 2015, at 06:40 , Matthew Huff mh...@ox.com wrote:
 
  It's only partially about net neutrality. Cogent provides cheap
 bandwidth for content providers, and sends a lot of traffic to eyeball
 networks. In the past, peering partners expected symmetrical load sharing.
 Cogent feels that eyeball networks should be happy to carry their traffic
 since the customers want their services, the eyeball networks want Cogent
 to pay them extra. When there is congestion, neither side wants to upgrade
 their peeing until this is resolved, so they haven't. This has been going
 on for at least 5 years, and happens all over the cogent peering map.
 
  Depending on what protocol you are using, it can be an issue or not. Our
 end users on eyeball networks had difficulty maintaining VPN connections.
 We had to drop our Cogent upstream and work with our remaining upstream
 provides to traffic engineer around Cogent. YMMV.
 
 
 
  
  Matthew Huff | 1 Manhattanville Rd
  Director of Operations | Purchase, NY 10577
  OTA Management LLC | Phone: 914-460-4039
  aim: matthewbhuff | Fax: 914-694-5669
 
  -Original Message-
  From: NANOG [mailto:nanog-boun...@nanog.org] On Behalf

RE: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Matthew Huff]

It's only partially about net neutrality. Cogent provides cheap bandwidth for 
content providers, and sends a lot of traffic to eyeball networks. In the past, 
peering partners expected symmetrical load sharing. Cogent feels that eyeball 
networks should be happy to carry their traffic since the customers want their 
services, the eyeball networks want Cogent to pay them extra. When there is 
congestion, neither side wants to upgrade their peeing until this is resolved, 
so they haven't. This has been going on for at least 5 years, and happens all 
over the cogent peering map.

Depending on what protocol you are using, it can be an issue or not. Our end 
users on eyeball networks had difficulty maintaining VPN connections. We had to 
drop our Cogent upstream and work with our remaining upstream provides to 
traffic engineer around Cogent. YMMV.




Matthew Huff | 1 Manhattanville Rd
Director of Operations   | Purchase, NY 10577
OTA Management LLC   | Phone: 914-460-4039
aim: matthewbhuff    | Fax:   914-694-5669

-Original Message-
From: NANOG [mailto:nanog-boun...@nanog.org] On Behalf Of Jordan Hamilton
Sent: Friday, August 14, 2015 5:31 PM
To: nanog@nanog.org
Subject: net neutrality peering dispute between CenturyTel/Qwest and Cogent in 
Dallas 

I have several customers that are having packet loss issues, the packet loss 
appears to be associated with a Cogent router interface of 38.104.86.222.  My 
upstream provider is telling me that the packet loss is being caused by a net 
neutrality peering dispute between CenturyTel/Quest and Cogent in Dallas.  I 
did some quick googling to see if I could come up with any articles or 
something like that I could provide to my customers and did not see anything.  
Anyone know any details?

Thanks

Jordan Hamilton
Senior Telecommunications Engineer

Empire District Electric Co.
720 Schifferdecker
PO Box 127
Joplin, MO 64802

Ph:  417-625-4223
Cell:  417-388-3351


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Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Stephen Satchell]

On 08/15/2015 06:40 AM, Matthew Huff wrote:

neither side wants to upgrade their peeing


Oh, the irony of this typo of peering...

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Owen DeLong]

Your reply implies that your understanding does not match my intended meaning.

(IOW, Perhaps you did not receive what I intended to transmit)

I’m saying that the incumbents in an act of unreasonable greed are demanding 
money for peering from providers with a lot of content providers while also 
collecting money from their direct customers for the sake of delivering that 
same content.

It would be like me standing between you and a hotdog stand and demanding that 
you give me 1.5x the price of the hotdog and then demanding that the hotdog 
stand sell me the hotdog to give to you for 0.5x the listed price.

In the more functional physical world, you simply walk around me and buy the 
hotdog for 1x the listed price and the only one who loses is the guy standing 
in the middle.

In the case of the incumbent facilities based carriers, they’ve managed to 
build a wall in front of the hot dog stand and a wall in front of you such that 
your view is limited to the window that they have to open and so is the hot dog 
vendor. Thus, you have no choice but to give them the extra 50% for the hot dog 
and the hot dog vendor has no choice but to give them half of the listed price 
as a “delivery charge”.

Admittedly, the fractions are not as I described, but the basic principle is 
exactly as I have described it.

Owen

 On Aug 15, 2015, at 09:59 , Mike Hammett na...@ics-il.net wrote:
 
 Arrogance is the only reason I can think of why the incumbents think that 
 way. I'd be surprised if any competitive providers (regardless of their 
 market dominance) would expect free peering. 
 
 
 
 
 - 
 Mike Hammett 
 Intelligent Computing Solutions 
 http://www.ics-il.com 
 
 
 
 Midwest Internet Exchange 
 http://www.midwest-ix.com 
 
 
 - Original Message -
 
 From: Owen DeLong o...@delong.com 
 To: Matthew Huff mh...@ox.com 
 Cc: nanog@nanog.org 
 Sent: Saturday, August 15, 2015 11:44:57 AM 
 Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and 
 Cogent in Dallas 
 
 This issue isn’t limited to Cogent. 
 
 There is this bizarre belief by the larger eyeball networks (and CC, VZ, and 
 TW are the worst offenders, pretty much in that order) that they are entitled 
 to be paid by both the content provider _AND_ the eyeball user for carrying 
 bits between the two. 
 
 In a healthy market, the eyeball providers would face competition and the 
 content providers would simply ignore these demands and the eyeballs would 
 buy from other eyeball providers. 
 
 Unfortunately, especially in the US, we don’t have a healthy market. In the 
 best of circumstances, we have oligopolies and in the worst places, we have 
 effective (or even actual) monopolies. 
 
 For example, in the area where I live, the claim you will hear is that there 
 is competition. With my usage patterns, that’s a choice between Comcast (up 
 to 30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up to 30/15 
 $500+/month). 
 
 I’m not in some rural backwater or even some second-tier metro. I’m within 10 
 miles of the former MAE West and also within 10 miles of Equinix SV1 (11 
 Great Oaks). There’s major fiber bundles within 2 miles of my house. I’m near 
 US101 and Capitol Expressway in San Jose. 
 
 The reason that things are this way, IMHO, is because we have allowed 
 “facilities based carriers” to leverage the monopoly on physical 
 infrastructure into a monopoly for services over that infrastructure. 
 
 The most viable solution, IMHO, is to require a separation between physical 
 infrastructure providers and those that provide services over that 
 infrastructure. Breaking the tight coupling between the two and requiring 
 physical infrastructure providers to lease facilities to operators on an 
 equal footing for all operators will reduce the barriers to competition in 
 the operator space. It will also make limited competition in the facilities 
 space possible, though unlikely. 
 
 This model exists to some extent in a few areas that have municipal 
 residential fiber services, and in most of those localities, it is working 
 well. 
 
 That’s one of the reasons that the incumbent facilities based carriers have 
 lobbied so hard to get laws in states where a city has done this that prevent 
 other cities from following suit. 
 
 Fortunately, one of the big gains in recent FCC rulings is that these laws 
 are likely to be rendered null and void. 
 
 Unfortunately, there is so much vested interest in the status quo that 
 achieving this sort of separation is unlikely without a really strong grass 
 roots movement. Sadly, the average sound-bite oriented citizen doesn’t know 
 (or want to learn) enough to facilitate such a grass-roots movement, so if we 
 want to build such a future, we have a long slog of public education and 
 recruitment ahead of us. 
 
 In the mean time, we’ll get to continue to watch companies like CC, VZ, TW 
 screw over their customers and the content providers their customers want to 
 reach

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Owen DeLong]

This issue isn’t limited to Cogent.

There is this bizarre belief by the larger eyeball networks (and CC, VZ, and TW 
are the worst offenders, pretty much in that order) that they are entitled to 
be paid by both the content provider _AND_ the eyeball user for carrying bits 
between the two.

In a healthy market, the eyeball providers would face competition and the 
content providers would simply ignore these demands and the eyeballs would buy 
from other eyeball providers.

Unfortunately, especially in the US, we don’t have a healthy market. In the 
best of circumstances, we have oligopolies and in the worst places, we have 
effective (or even actual) monopolies.

For example, in the area where I live, the claim you will hear is that there is 
competition. With my usage patterns, that’s a choice  between Comcast (up to 
30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up to 30/15 
$500+/month).

I’m not in some rural backwater or even some second-tier metro. I’m within 10 
miles of the former MAE West and also within 10 miles of Equinix SV1 (11 Great 
Oaks). There’s major fiber bundles within 2 miles of my house. I’m near US101 
and Capitol Expressway in San Jose.

The reason that things are this way, IMHO, is because we have allowed 
“facilities based carriers” to leverage the monopoly on physical infrastructure 
into a monopoly for services over that infrastructure.

The most viable solution, IMHO, is to require a separation between physical 
infrastructure providers and those that provide services over that 
infrastructure. Breaking the tight coupling between the two and requiring 
physical infrastructure providers to lease facilities to operators on an equal 
footing for all operators will reduce the barriers to competition in the 
operator space. It will also make limited competition in the facilities space 
possible, though unlikely.

This model exists to some extent in a few areas that have municipal residential 
fiber services, and in most of those localities, it is working well.

That’s one of the reasons that the incumbent facilities based carriers have 
lobbied so hard to get laws in states where a city has done this that prevent 
other cities from following suit.

Fortunately, one of the big gains in recent FCC rulings is that these laws are 
likely to be rendered null and void.

Unfortunately, there is so much vested interest in the status quo that 
achieving this sort of separation is unlikely without a really strong grass 
roots movement. Sadly, the average sound-bite oriented citizen doesn’t know (or 
want to learn) enough to facilitate such a grass-roots movement, so if we want 
to build such a future, we have a long slog of public education and recruitment 
ahead of us.

In the mean time, we’ll get to continue to watch companies like CC, VZ, TW 
screw over their customers and the content providers their customers want to 
reach for the sake of extorting extra money from both sides of the transaction.

Owen

 On Aug 15, 2015, at 06:40 , Matthew Huff mh...@ox.com wrote:
 
 It's only partially about net neutrality. Cogent provides cheap bandwidth for 
 content providers, and sends a lot of traffic to eyeball networks. In the 
 past, peering partners expected symmetrical load sharing. Cogent feels that 
 eyeball networks should be happy to carry their traffic since the customers 
 want their services, the eyeball networks want Cogent to pay them extra. When 
 there is congestion, neither side wants to upgrade their peeing until this is 
 resolved, so they haven't. This has been going on for at least 5 years, and 
 happens all over the cogent peering map.
 
 Depending on what protocol you are using, it can be an issue or not. Our end 
 users on eyeball networks had difficulty maintaining VPN connections. We had 
 to drop our Cogent upstream and work with our remaining upstream provides to 
 traffic engineer around Cogent. YMMV.
 
 
 
 
 Matthew Huff | 1 Manhattanville Rd
 Director of Operations   | Purchase, NY 10577
 OTA Management LLC   | Phone: 914-460-4039
 aim: matthewbhuff| Fax:   914-694-5669
 
 -Original Message-
 From: NANOG [mailto:nanog-boun...@nanog.org] On Behalf Of Jordan Hamilton
 Sent: Friday, August 14, 2015 5:31 PM
 To: nanog@nanog.org
 Subject: net neutrality peering dispute between CenturyTel/Qwest and Cogent 
 in Dallas 
 
 I have several customers that are having packet loss issues, the packet loss 
 appears to be associated with a Cogent router interface of 38.104.86.222.  My 
 upstream provider is telling me that the packet loss is being caused by a net 
 neutrality peering dispute between CenturyTel/Quest and Cogent in Dallas.  I 
 did some quick googling to see if I could come up with any articles or 
 something like that I could provide to my customers and did not see anything. 
  Anyone know any details?
 
 Thanks
 
 Jordan Hamilton
 Senior Telecommunications Engineer
 
 Empire District Electric Co.
 720 Schifferdecker
 

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Mike Hammett]

Arrogance is the only reason I can think of why the incumbents think that way. 
I'd be surprised if any competitive providers (regardless of their market 
dominance) would expect free peering. 




- 
Mike Hammett 
Intelligent Computing Solutions 
http://www.ics-il.com 



Midwest Internet Exchange 
http://www.midwest-ix.com 


- Original Message -

From: Owen DeLong o...@delong.com 
To: Matthew Huff mh...@ox.com 
Cc: nanog@nanog.org 
Sent: Saturday, August 15, 2015 11:44:57 AM 
Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent 
in Dallas 

This issue isn’t limited to Cogent. 

There is this bizarre belief by the larger eyeball networks (and CC, VZ, and TW 
are the worst offenders, pretty much in that order) that they are entitled to 
be paid by both the content provider _AND_ the eyeball user for carrying bits 
between the two. 

In a healthy market, the eyeball providers would face competition and the 
content providers would simply ignore these demands and the eyeballs would buy 
from other eyeball providers. 

Unfortunately, especially in the US, we don’t have a healthy market. In the 
best of circumstances, we have oligopolies and in the worst places, we have 
effective (or even actual) monopolies. 

For example, in the area where I live, the claim you will hear is that there is 
competition. With my usage patterns, that’s a choice between Comcast (up to 
30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up to 30/15 
$500+/month). 

I’m not in some rural backwater or even some second-tier metro. I’m within 10 
miles of the former MAE West and also within 10 miles of Equinix SV1 (11 Great 
Oaks). There’s major fiber bundles within 2 miles of my house. I’m near US101 
and Capitol Expressway in San Jose. 

The reason that things are this way, IMHO, is because we have allowed 
“facilities based carriers” to leverage the monopoly on physical infrastructure 
into a monopoly for services over that infrastructure. 

The most viable solution, IMHO, is to require a separation between physical 
infrastructure providers and those that provide services over that 
infrastructure. Breaking the tight coupling between the two and requiring 
physical infrastructure providers to lease facilities to operators on an equal 
footing for all operators will reduce the barriers to competition in the 
operator space. It will also make limited competition in the facilities space 
possible, though unlikely. 

This model exists to some extent in a few areas that have municipal residential 
fiber services, and in most of those localities, it is working well. 

That’s one of the reasons that the incumbent facilities based carriers have 
lobbied so hard to get laws in states where a city has done this that prevent 
other cities from following suit. 

Fortunately, one of the big gains in recent FCC rulings is that these laws are 
likely to be rendered null and void. 

Unfortunately, there is so much vested interest in the status quo that 
achieving this sort of separation is unlikely without a really strong grass 
roots movement. Sadly, the average sound-bite oriented citizen doesn’t know (or 
want to learn) enough to facilitate such a grass-roots movement, so if we want 
to build such a future, we have a long slog of public education and recruitment 
ahead of us. 

In the mean time, we’ll get to continue to watch companies like CC, VZ, TW 
screw over their customers and the content providers their customers want to 
reach for the sake of extorting extra money from both sides of the transaction. 

Owen 

 On Aug 15, 2015, at 06:40 , Matthew Huff mh...@ox.com wrote: 
 
 It's only partially about net neutrality. Cogent provides cheap bandwidth for 
 content providers, and sends a lot of traffic to eyeball networks. In the 
 past, peering partners expected symmetrical load sharing. Cogent feels that 
 eyeball networks should be happy to carry their traffic since the customers 
 want their services, the eyeball networks want Cogent to pay them extra. When 
 there is congestion, neither side wants to upgrade their peeing until this is 
 resolved, so they haven't. This has been going on for at least 5 years, and 
 happens all over the cogent peering map. 
 
 Depending on what protocol you are using, it can be an issue or not. Our end 
 users on eyeball networks had difficulty maintaining VPN connections. We had 
 to drop our Cogent upstream and work with our remaining upstream provides to 
 traffic engineer around Cogent. YMMV. 
 
 
 
  
 Matthew Huff | 1 Manhattanville Rd 
 Director of Operations | Purchase, NY 10577 
 OTA Management LLC | Phone: 914-460-4039 
 aim: matthewbhuff | Fax: 914-694-5669 
 
 -Original Message- 
 From: NANOG [mailto:nanog-boun...@nanog.org] On Behalf Of Jordan Hamilton 
 Sent: Friday, August 14, 2015 5:31 PM 
 To: nanog@nanog.org 
 Subject: net neutrality peering dispute between CenturyTel/Qwest and Cogent 
 in Dallas 
 
 I have several customers

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Matthew Petach]

I dunno, Jim, that sounds almost like you might
think the inevitable outcome will be an everyone
pays model of settlements, the way telcos do
it.  Unfortunately, in that model, the only winners
are the transit networks in the middle, because
no accounting department is going to want to
keep track of settlements for 4,000 other ASNs
that you peer with; their demand will be reduce
the number of invoices, aggregate through 2 or
3 providers so we only have a small number of
invoices to reconcile.
I can see where you're coming from, but I'm not
sure I like the destination.  :(

Matt


On Sat, Aug 15, 2015 at 10:32 AM, jim deleskie deles...@gmail.com wrote:
 In my 20+ yrs now of playing this game, everyone has had a turn thinking
 their content/eyeballs are special and should get free peering.

 On Sat, Aug 15, 2015 at 1:59 PM, Mike Hammett na...@ics-il.net wrote:

 Arrogance is the only reason I can think of why the incumbents think that
 way. I'd be surprised if any competitive providers (regardless of their
 market dominance) would expect free peering.




 -
 Mike Hammett
 Intelligent Computing Solutions
 http://www.ics-il.com



 Midwest Internet Exchange
 http://www.midwest-ix.com


 - Original Message -

 From: Owen DeLong o...@delong.com
 To: Matthew Huff mh...@ox.com
 Cc: nanog@nanog.org
 Sent: Saturday, August 15, 2015 11:44:57 AM
 Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and
 Cogent in Dallas

 This issue isn’t limited to Cogent.

 There is this bizarre belief by the larger eyeball networks (and CC, VZ,
 and TW are the worst offenders, pretty much in that order) that they are
 entitled to be paid by both the content provider _AND_ the eyeball user for
 carrying bits between the two.

 In a healthy market, the eyeball providers would face competition and the
 content providers would simply ignore these demands and the eyeballs would
 buy from other eyeball providers.

 Unfortunately, especially in the US, we don’t have a healthy market. In
 the best of circumstances, we have oligopolies and in the worst places, we
 have effective (or even actual) monopolies.

 For example, in the area where I live, the claim you will hear is that
 there is competition. With my usage patterns, that’s a choice between
 Comcast (up to 30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up
 to 30/15 $500+/month).

 I’m not in some rural backwater or even some second-tier metro. I’m within
 10 miles of the former MAE West and also within 10 miles of Equinix SV1 (11
 Great Oaks). There’s major fiber bundles within 2 miles of my house. I’m
 near US101 and Capitol Expressway in San Jose.

 The reason that things are this way, IMHO, is because we have allowed
 “facilities based carriers” to leverage the monopoly on physical
 infrastructure into a monopoly for services over that infrastructure.

 The most viable solution, IMHO, is to require a separation between
 physical infrastructure providers and those that provide services over that
 infrastructure. Breaking the tight coupling between the two and requiring
 physical infrastructure providers to lease facilities to operators on an
 equal footing for all operators will reduce the barriers to competition in
 the operator space. It will also make limited competition in the facilities
 space possible, though unlikely.

 This model exists to some extent in a few areas that have municipal
 residential fiber services, and in most of those localities, it is working
 well.

 That’s one of the reasons that the incumbent facilities based carriers
 have lobbied so hard to get laws in states where a city has done this that
 prevent other cities from following suit.

 Fortunately, one of the big gains in recent FCC rulings is that these laws
 are likely to be rendered null and void.

 Unfortunately, there is so much vested interest in the status quo that
 achieving this sort of separation is unlikely without a really strong grass
 roots movement. Sadly, the average sound-bite oriented citizen doesn’t know
 (or want to learn) enough to facilitate such a grass-roots movement, so if
 we want to build such a future, we have a long slog of public education and
 recruitment ahead of us.

 In the mean time, we’ll get to continue to watch companies like CC, VZ, TW
 screw over their customers and the content providers their customers want
 to reach for the sake of extorting extra money from both sides of the
 transaction.

 Owen

  On Aug 15, 2015, at 06:40 , Matthew Huff mh...@ox.com wrote:
 
  It's only partially about net neutrality. Cogent provides cheap
 bandwidth for content providers, and sends a lot of traffic to eyeball
 networks. In the past, peering partners expected symmetrical load sharing.
 Cogent feels that eyeball networks should be happy to carry their traffic
 since the customers want their services, the eyeball networks want Cogent
 to pay them extra. When there is congestion, neither side wants to upgrade
 their peeing until

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Owen DeLong]

Let me turn that on its head…

I don’t think anyone’s eyeballs are special.
I don’t think anyone’s content is special.

I think everyone should get free peering with any network whose customers 
expect to be able to reach that other network’s customers.

Ignoring for a moment the idea of maximizing effective avarice, think how
much better it would be for eyeballs and content providers alike if they
could all just peer directly settlement free and/or pay a single layer of
transit providers all of whom peered with each other
for free.

Time and time again we have repeatedly proven that increased interconnect
density and promiscuous settlement free peering reduce
costs, improve performance, and generally make the internet better for
all concerned.

Now, ask yourself… If everyone followed that model, would it actually reduce
the viability of any of the businesses in question?

IMHO, there’s only one yes answer here… If enough of the eyeball/content
providers are able to cooperate and peer with each other directly, you might
see a significant impact (reduction in need) on transit providers as their 
entire
business would become largely irrelevant.

That’s called cutting out the middle man. In almost every industry that has been
able to do so, it’s been considered a really good thing for everyone except the
middle man who rarely gets much sympathy.

Owen

 On Aug 15, 2015, at 10:32 , jim deleskie deles...@gmail.com wrote:
 
 In my 20+ yrs now of playing this game, everyone has had a turn thinking
 their content/eyeballs are special and should get free peering.
 
 On Sat, Aug 15, 2015 at 1:59 PM, Mike Hammett na...@ics-il.net wrote:
 
 Arrogance is the only reason I can think of why the incumbents think that
 way. I'd be surprised if any competitive providers (regardless of their
 market dominance) would expect free peering.
 
 
 
 
 -
 Mike Hammett
 Intelligent Computing Solutions
 http://www.ics-il.com
 
 
 
 Midwest Internet Exchange
 http://www.midwest-ix.com
 
 
 - Original Message -
 
 From: Owen DeLong o...@delong.com
 To: Matthew Huff mh...@ox.com
 Cc: nanog@nanog.org
 Sent: Saturday, August 15, 2015 11:44:57 AM
 Subject: Re: net neutrality peering dispute between CenturyTel/Qwest and
 Cogent in Dallas
 
 This issue isn’t limited to Cogent.
 
 There is this bizarre belief by the larger eyeball networks (and CC, VZ,
 and TW are the worst offenders, pretty much in that order) that they are
 entitled to be paid by both the content provider _AND_ the eyeball user for
 carrying bits between the two.
 
 In a healthy market, the eyeball providers would face competition and the
 content providers would simply ignore these demands and the eyeballs would
 buy from other eyeball providers.
 
 Unfortunately, especially in the US, we don’t have a healthy market. In
 the best of circumstances, we have oligopolies and in the worst places, we
 have effective (or even actual) monopolies.
 
 For example, in the area where I live, the claim you will hear is that
 there is competition. With my usage patterns, that’s a choice between
 Comcast (up to 30/7 $100/mo), ATT DSL (1.5M/384k $40/mo+) and wireless (Up
 to 30/15 $500+/month).
 
 I’m not in some rural backwater or even some second-tier metro. I’m within
 10 miles of the former MAE West and also within 10 miles of Equinix SV1 (11
 Great Oaks). There’s major fiber bundles within 2 miles of my house. I’m
 near US101 and Capitol Expressway in San Jose.
 
 The reason that things are this way, IMHO, is because we have allowed
 “facilities based carriers” to leverage the monopoly on physical
 infrastructure into a monopoly for services over that infrastructure.
 
 The most viable solution, IMHO, is to require a separation between
 physical infrastructure providers and those that provide services over that
 infrastructure. Breaking the tight coupling between the two and requiring
 physical infrastructure providers to lease facilities to operators on an
 equal footing for all operators will reduce the barriers to competition in
 the operator space. It will also make limited competition in the facilities
 space possible, though unlikely.
 
 This model exists to some extent in a few areas that have municipal
 residential fiber services, and in most of those localities, it is working
 well.
 
 That’s one of the reasons that the incumbent facilities based carriers
 have lobbied so hard to get laws in states where a city has done this that
 prevent other cities from following suit.
 
 Fortunately, one of the big gains in recent FCC rulings is that these laws
 are likely to be rendered null and void.
 
 Unfortunately, there is so much vested interest in the status quo that
 achieving this sort of separation is unlikely without a really strong grass
 roots movement. Sadly, the average sound-bite oriented citizen doesn’t know
 (or want to learn) enough to facilitate such a grass-roots movement, so if
 we want to build such a future, we have a long slog of public education

Re: net neutrality peering dispute between CenturyTel/Qwest and Cogent in Dallas

[Mark Tinka]

On 15/Aug/15 19:32, jim deleskie wrote:

 In my 20+ yrs now of playing this game, everyone has had a turn thinking
 their content/eyeballs are special and should get free peering.

That's why those tired of playing the game build their own networks to
take out the middleman, for better or worse.

Mark.

Re: Net Neutrality...

[Richard Bennett]

Minor nit: McDowell is a former two term commissioner, but was not a 
chairman. He is, however, a real standout in terms of understanding the 
Internet and has many of the most coherent comments of any commissioner 
since his appointment. He was a leader in the campaign to push back the 
attempts of the ITU to establish sovereignty over interconnection and to 
apply telecom tariffs to the Internet.


It's worth noting that there was a time when Internet policy at the 
national level was not the ideological exercise that it has become. 
There was very little difference between Clinton's last FCC chairman 
(Kennard) and Bush 43's first chairman (Powell) on the general approach 
of the federal government to the Internet. Powell was, after all, the 
chairman who first articulated Internet Freedom goals in his famous 
Four Freedoms speech in Boulder in 2004; see: 
http://www.jthtl.org/content/articles/V3I1/JTHTLv3i1_Powell.PDF


It's a shame that people can't discuss principles of network policy 
today without first signing a loyalty oath to one of the political 
parties. It seems to me that Kennard, Powell, Wheeler, McDowell, and 
current commissioner Pai have all articulated great ideas about Internet 
policy that stand on their own without regard to political affiliations.


RB

On 7/16/14, 7:50 AM, Fred Baker (fred) wrote:

Relevant article by former FCC Chair

http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/


--
Richard Bennett
Visiting Fellow, American Enterprise Institute
Center for Internet, Communications, and Technology Policy
Editor, High Tech Forum

RE: Net Neutrality...

[Keith Medcalf]

An LED screen doesn't refresh the way a CRT does, right? The light
doesn't flash and fade, it stays constant until the next change. So
why would a 30 hz refresh rate make any difference at all for tasks
which update the screen less often than 30 times a second? Mike did
say he used it for doing software development.

You are absolutely correct Bill, however,

Movies were shot at 24fps and TV shows at 30fps (60 interlaced), so
I'm not sure where the harm would be there either.

In order to create a perception of movement, the images need to have no image 
between them.  24 frame progressive (such as a movie theatre from real film) is 
usually projected as 48 frames using double shutters.  It is the blank/dark/no 
image parts between the images that create the perception of movement in the 
brain.  For a scanning display (CRT) this is automatic -- the persistence of 
each display frame is timed such that it only persists for one half a scan 
(which is why if you take a picture of a CRT displaying an image with a camera 
with a shutter speed faster than the refresh rate, you see a rolling black 
bar).  The blank/black frames are created automatically.

LCD displays, however, do not have these blank frames between the actual 
frames, which is why they do not create the appearance of motion correctly.  
Most LCD display devices, however, have a refresh rate of 60 Hz (some are 
higher).  When fed with a 30p signal, the display electronics should display 
blackness for every other 60p image.  If you send a 60 Hz display a 60p signal, 
however, it will not have smooth motion.

LCD's designed to display moving pictures (ie, TVs) will run at even higher 
refresh rates (120 Hz for example) which allows a 60p display with proper 
blanking.  In some cases the motion vectors are calculated and only the moving 
bits are blanked (or in some cases displayed as a complement image).  Devices 
with even higher refresh rates do even more esoteric computations to determine 
the interstitial frames to create a proper perception of motion by the brain.

Each manufacturer uses their own proprietary algorithms to determine what to 
actually display -- some better some worse.  Some even use a scanning 
backlight which makes the LCD display emulate the scanning behaviour of a 
CRT display allowing for a CRT-like creation of motion.

Now, back to regularly scheduled programming

Re: Net Neutrality...

[Larry Sheldon]

On 7/20/2014 11:08 AM, Keith Medcalf wrote:



An LED screen doesn't refresh the way a CRT does, right? The light
doesn't flash and fade, it stays constant until the next change. So
why would a 30 hz refresh rate make any difference at all for tasks
which update the screen less often than 30 times a second? Mike did
say he used it for doing software development.


You are absolutely correct Bill, however,


Movies were shot at 24fps and TV shows at 30fps (60 interlaced), so
I'm not sure where the harm would be there either.


In order to create a perception of movement, the images need to have no image between them.  24 
frame progressive (such as a movie theatre from real film) is usually projected as 48 frames using double 
shutters.  It is the blank/dark/no image parts between the images that create the perception of 
movement in the brain.  For a scanning display (CRT) this is automatic -- the persistence of each display 
frame is timed such that it only persists for one half a scan (which is why if you take a picture of a CRT 
displaying an image with a camera with a shutter speed faster than the refresh rate, you see a rolling black 
bar).  The blank/black frames are created automatically.

LCD displays, however, do not have these blank frames between the actual 
frames, which is why they do not create the appearance of motion correctly.  
Most LCD display devices, however, have a refresh rate of 60 Hz (some are 
higher).  When fed with a 30p signal, the display electronics should display 
blackness for every other 60p image.  If you send a 60 Hz display a 60p signal, 
however, it will not have smooth motion.

LCD's designed to display moving pictures (ie, TVs) will run at even higher refresh rates 
(120 Hz for example) which allows a 60p display with proper blanking.  In some cases the 
motion vectors are calculated and only the moving bits are blanked (or in 
some cases displayed as a complement image).  Devices with even higher refresh rates do 
even more esoteric computations to determine the interstitial frames to create a proper 
perception of motion by the brain.

Each manufacturer uses their own proprietary algorithms to determine what to actually display -- 
some better some worse.  Some even use a scanning backlight which makes the LCD display 
emulate the scanning behaviour of a CRT display allowing for a CRT-like creation of 
motion.

Now, back to regularly scheduled programming


Like TV--time for a potty break.

Really interesting read--lotta stuff I didn't know.  It is a good day.


--
Requiescas in pace o email   Two identifying characteristics
of System Administrators:
Ex turpi causa non oritur actio  Infallibility, and the ability to
learn from their mistakes.
  (Adapted from Stephen Pinker)

Re: Net Neutrality...

[Rob Seastrom]

Michael Thomas m...@mtcc.com writes:

 On 7/17/14, 2:15 PM, valdis.kletni...@vt.edu wrote:
 /me makes popcorn and waits for 4K displays to drop under US$1K and
 watch the network providers completely lose their shit

 http://www.amazon.com/Seiki-SE39UY04-39-Inch-Ultra-120Hz/dp/B00DOPGO2G

 $339!

 I use it for doing dev. It's *fabulous*.

Refresh rate is limited to 30Hz with 4K

Bracing for my first seizure ever in 3...  2... 1...

-r

Re: Net Neutrality...

[Michael Thomas]

On 07/18/2014 11:05 AM, Rob Seastrom wrote:

Michael Thomas m...@mtcc.com writes:


On 7/17/14, 2:15 PM, valdis.kletni...@vt.edu wrote:

/me makes popcorn and waits for 4K displays to drop under US$1K and
watch the network providers completely lose their shit

http://www.amazon.com/Seiki-SE39UY04-39-Inch-Ultra-120Hz/dp/B00DOPGO2G

$339!

I use it for doing dev. It's *fabulous*.

Refresh rate is limited to 30Hz with 4K

Bracing for my first seizure ever in 3...  2... 1...



I just use it as a monitor for my compooter, so it doesn't bother me at 
all. Which is pretty much
the only thing you can do with 4k these days... not much content 
available that i know of.


Mike

Re: Net Neutrality...

[William Herrin]

On Fri, Jul 18, 2014 at 2:05 PM, Rob Seastrom r...@seastrom.com wrote:
 Michael Thomas m...@mtcc.com writes:
 On 7/17/14, 2:15 PM, valdis.kletni...@vt.edu wrote:
 /me makes popcorn and waits for 4K displays to drop under US$1K and
 watch the network providers completely lose their shit

 http://www.amazon.com/Seiki-SE39UY04-39-Inch-Ultra-120Hz/dp/B00DOPGO2G

 $339!

 I use it for doing dev. It's *fabulous*.

 Refresh rate is limited to 30Hz with 4K

 Bracing for my first seizure ever in 3...  2... 1...

Hi Rob,

An LED screen doesn't refresh the way a CRT does, right? The light
doesn't flash and fade, it stays constant until the next change. So
why would a 30 hz refresh rate make any difference at all for tasks
which update the screen less often than 30 times a second? Mike did
say he used it for doing software development.

Movies were shot at 24fps and TV shows at 30fps (60 interlaced), so
I'm not sure where the harm would be there either.

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
Can I solve your unusual networking challenges?

Re: Net Neutrality...

[Brandon Butterworth]

 I just use it as a monitor for my compooter, so it doesn't bother me at 
 all. Which is pretty much
 the only thing you can do with 4k these days... not much content 
 available that i know of.

Pretty much the only thing it will ever be good for.

4K doesn't look so good at 30Hz if things move -

http://www.bbc.co.uk/rd/blog/2013/12/high-frame-rate-at-the-ebu-uhdtv-voices-and-choices-workshop

We're working with the industry in defining the UHD standard,
120Hz is being considered though we'd prefer a bit more.

brandon

Re: Net Neutrality...

[Paul S.]

On 7/19/2014 午前 03:35, William Herrin wrote:

On Fri, Jul 18, 2014 at 2:05 PM, Rob Seastrom r...@seastrom.com wrote:

Michael Thomas m...@mtcc.com writes:

On 7/17/14, 2:15 PM, valdis.kletni...@vt.edu wrote:

/me makes popcorn and waits for 4K displays to drop under US$1K and
watch the network providers completely lose their shit

http://www.amazon.com/Seiki-SE39UY04-39-Inch-Ultra-120Hz/dp/B00DOPGO2G

$339!

I use it for doing dev. It's *fabulous*.

Refresh rate is limited to 30Hz with 4K

Bracing for my first seizure ever in 3...  2... 1...

Hi Rob,

An LED screen doesn't refresh the way a CRT does, right? The light
doesn't flash and fade, it stays constant until the next change. So
why would a 30 hz refresh rate make any difference at all for tasks
which update the screen less often than 30 times a second? Mike did
say he used it for doing software development.

Movies were shot at 24fps and TV shows at 30fps (60 interlaced), so
I'm not sure where the harm would be there either.

Regards,
Bill Herrin




For all intents and purposes, it actually does work fine -- yeah.

I've got a few friends who bought it, it seems to work fine.

Re: Net Neutrality...

[Owen DeLong]

On Jul 18, 2014, at 11:35 , William Herrin b...@herrin.us wrote:

 On Fri, Jul 18, 2014 at 2:05 PM, Rob Seastrom r...@seastrom.com wrote:
 Michael Thomas m...@mtcc.com writes:
 On 7/17/14, 2:15 PM, valdis.kletni...@vt.edu wrote:
 /me makes popcorn and waits for 4K displays to drop under US$1K and
 watch the network providers completely lose their shit
 
 http://www.amazon.com/Seiki-SE39UY04-39-Inch-Ultra-120Hz/dp/B00DOPGO2G
 
 $339!
 
 I use it for doing dev. It's *fabulous*.
 
 Refresh rate is limited to 30Hz with 4K
 
 Bracing for my first seizure ever in 3...  2... 1...
 
 Hi Rob,
 
 An LED screen doesn't refresh the way a CRT does, right? The light
 doesn't flash and fade, it stays constant until the next change. So
 why would a 30 hz refresh rate make any difference at all for tasks
 which update the screen less often than 30 times a second? Mike did
 say he used it for doing software development.

Well... Yes and no.

An LED screen doesn't refresh the way a CRT does, that part is true.

However, the brightness of any particular color of any particular pixel in any 
LED
screen is usually controlled by a process known as Pulse Width Modulation (PWM)
where the LED actually turns on and off several thousand times per second and
modifications of the ratio between the on-time and off-time in those cycles are
used to control the apparent brightness. As such, the LEDs are actually turning 
on
and off (flickering) much much faster than any CRT would, but it's not the same
kind of flicker.

However, most LED Screens aren't actually LED screens, most of them are
LED backlit CRT Screens. (I didn't look at the specs on this one in detail, so
I don't actually know which type it is).

This gets further complicated by technologies such as selective dimming, etc.

Owen

Re: Net Neutrality...

[William Herrin]

On Fri, Jul 18, 2014 at 6:48 PM, Owen DeLong o...@delong.com wrote:
 On Jul 18, 2014, at 11:35 , William Herrin b...@herrin.us wrote:
 An LED screen doesn't refresh the way a CRT does, right? The light
 doesn't flash and fade, it stays constant until the next change. So
 why would a 30 hz refresh rate make any difference at all for tasks
 which update the screen less often than 30 times a second? Mike did
 say he used it for doing software development.

However, the brightness of any particular color of any particular
pixel in any LED screen is usually controlled by a process known
as Pulse Width Modulation (PWM) where the LED actually turns
 on and off several thousand times per second and modifications
 of the ratio between the on-time and off-time in those cycles are
used to control the apparent brightness.

 However, most LED Screens aren't actually LED screens, most of them are
 LED backlit CRT Screens. (I didn't look at the specs on this one in detail, so
 I don't actually know which type it is).

Hi Owen,

You probably meant LED backlit LCD (liquid crystal display) screens,
yes? As opposed to an LCD panel backlit with fluorescent tubes? LCDs
don't have a flicker rate either, unless they're particularly badly
implemented.

http://en.wikipedia.org/wiki/LED-backlit_LCD_display

Interesting point about PWM controlling the LED brightness, although
that won't be tied to screen's overall refresh rate either. The pulse
timing will be the same whether your overall refresh rate is 30 fps or
300.

(And for those of you who don't bother turning off your flat panel
monitors at night because what the heck, they won't burn in right?...
That's a mistake. You won't hurt the LCD but the cold cathode
fluorescent tube backlights are wearing out.)

Regards,
Bill Herrin


-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
Can I solve your unusual networking challenges?

Re: Net Neutrality...

[Gary Buhrmaster]

On Fri, Jul 18, 2014 at 6:49 PM, Paul S. cont...@winterei.se wrote:


 For all intents and purposes, it actually does work fine -- yeah.

 I've got a few friends who bought it, it seems to work fine.

This is way off topic, but 

This topic was covered back in the beginning of the year at:

  http://tiamat.tsotech.com/4k-is-for-programmers

and the followup at:

  http://tiamat.tsotech.com/4k-is-for-programmers-redux

The conclusion (in the case) was that for devs, the
goods outweigh the bads.  As always, your mileage
will vary, and some settling occurred during transport.

Note, too that Dell, Asus, and Lenovo have newer 4K
models out there that address some of the issues
(I have explicitly tried to avoid finding the reviews because
I do not want to be forced, forced I say, to buy
a 4K monitor).

Re: Net Neutrality...

[Ray Soucy]

In truth, however, market failures like these have never happened,
and nothing is broken that needs fixing.

Prefixing a statement with in truth doesn't actually make it true, Bob.


On Wed, Jul 16, 2014 at 10:50 AM, Fred Baker (fred) f...@cisco.com wrote:
 Relevant article by former FCC Chair

 http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/



-- 
Ray Patrick Soucy
Network Engineer
University of Maine System

T: 207-561-3526
F: 207-561-3531

MaineREN, Maine's Research and Education Network
www.maineren.net

Re: Net Neutrality...

[Owen DeLong]

On Jul 15, 2014, at 08:19 , Naslund, Steve snasl...@medline.com wrote:

 I don't believe either of those points.  I will grant you that the LECs are 
 near monopolies in some rural areas, but these are few and far between.  Yes, 
 a LEC may control the last mile but I can usually get circuits from a lot of 
 carriers.  A company I work for has over 50 locations mostly in rural areas 
 and we do not have much problem getting Sprint and CenturyLink access 
 circuits to them regardless of location.  In fact, we have never found a 
 location in the US that I can't get both of those carrier to deliver to us.  
 In a lot of areas there is also a cable provider available.  Residential 
 users have somewhat more limited options but you do always have the option of 
 deciding where to live.  Most of us in this group would consider the 
 broadband options available to them before they move.

If you want more than 1Mbps downstream or more than 384k upstream over 
terrestrial facilities in most of San Jose, California (the 3rd largest city by 
population in the largest population state in the US and the 10th largest city 
in the US last I looked), then you have exactly one choice. If that's not a 
monopoly, I'm not sure how you define one.

The situation in the vast majority of the bay area (including most of silicon 
valley) is the same.

It's even worse in less densely populated areas in many cases, though USF has 
distorted that to some extent because there are rural areas where the monopoly 
facilities based carrier has taken subsidies to provide higher quality access 
than is currently available to many of us living in more urban areas.

 Being a content provider has very little to do with market forces.  Comcast 
 is, of course, a major content provider and access provider but if they limit 
 their customer's access to Netflix (which they have been accused of) the 
 customers will still react to that.  The content providing access provider 
 has to know that no matter how good their content is, they are not the only 
 source and their customers will react to that.  I think the service providers 
 are sophisticated enough to know that and they will walk the fine line of 
 keeping their customer happy while trying to promote their own content.  It 
 is like saying a Ford dealer does not want to change the oil on your Chevy, 
 sure they would like for you to have bought from them but they will take what 
 they can get.

How is a customer supposed to react to that? In a location where their choice 
is $CABLECO for 30Mbps/7Mbps vs. $TELCO for 768k/384k, how, exactly, does one 
react in a meaningful or useful way?

Owen

Re: Net Neutrality...

[Valdis . Kletnieks]

On Tue, 15 Jul 2014 13:08:58 -0600, Brett Glass said:

 Estimates of the maximum bandwidths of all the human senses, combined,
 range between the capacity of a T1 line (at the low end) and
 about 4 Mbps (at the high end). A human being simply is not wired to
 accept more input. (Yes, machines could digest more... which means that
 additional bandwidth to and from the home might be useful for the purpose
 of spying on us.) What does this imply about the FCC's proposal to
 redefine broadband as a symmetrical 10 Mbps?

Actually, vision is higher bandwidth than that - most VR people estimate that
approaching human vision requires a gigapixel/second (at 24 bits or more per
pixel) - and even that needs to play lots of eye-tracking games to concentrate
the rendering on where the eye is focused.  Consider how fast even high-end
NVidia cards can pump out pixels and you can *still* see it's CGI.  Well-shot
4K video of real objects displayed on a good monitor is *just* reaching the it
actually looks real level - and that's a hell of a lot more than 4Mbps.

And remember that bits are consumed by more than just one human per dwelling -
you can have multiple people watching different things, and silicon-based
consumers burning lots of bandwidth on behalf of their carbon-based masters.
There's about a half-zillion ways a gaming console can burn bandwidth, for
example.  Heck, the Raspberry Pi under my TV can soak up more than 4Mbits/sec
just doing a software update.

/me makes popcorn and waits for 4K displays to drop under US$1K and watch the
network providers completely lose their shit


pgpL7JfQWAopv.pgp
Description: PGP signature

Re: Net Neutrality...

[Michael Thomas]

On 7/17/14, 2:15 PM, valdis.kletni...@vt.edu wrote:
/me makes popcorn and waits for 4K displays to drop under US$1K and 
watch the network providers completely lose their shit 


http://www.amazon.com/Seiki-SE39UY04-39-Inch-Ultra-120Hz/dp/B00DOPGO2G

$339!

I use it for doing dev. It's *fabulous*.

Mike

Re: Net Neutrality...

[Larry Sheldon]

On 7/16/2014 1:57 PM, Doug Barton wrote:

On 07/16/2014 08:45 AM, Eric Brunner-Williams wrote:

On 7/16/14 7:50 AM, Fred Baker (fred) wrote:

Relevant article by former FCC Chair

http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/




It reads like a hit piece (by a Republican free markets ideologue) on
a (Progressive) Democratic primary candidate for Lt. Governor of New
York, not like a reasoned case by an informed policy analyst.


Errr, I didn't see anything about any LTG candidates in that piece, what
did I miss? I'm also curious about what it is that you think is
misstated or overblown in that piece that would lead you to believe that
it's a hit piece.


His use of phrases like by a Republican free markets ideologue 
pretty much nailed the value of his remarks for me.



--
Requiescas in pace o email   Two identifying characteristics
of System Administrators:
Ex turpi causa non oritur actio  Infallibility, and the ability to
learn from their mistakes.
  (Adapted from Stephen Pinker)

Re: Net Neutrality...

[Graham Donaldson]

On 2014-07-16 04:04, Jay Ashworth wrote:

- Original Message -

From: Brett Glass na...@brettglass.com



Estimates of the maximum bandwidths of all the human senses, combined,
range between the capacity of a T1 line (at the low end) and
about 4 Mbps (at the high end). A human being simply is not wired to
accept more input. (Yes, machines could digest more... which means 
that
additional bandwidth to and from the home might be useful for the 
purpose

of spying on us.) What does this imply about the FCC's proposal to
redefine broadband as a symmetrical 10 Mbps?


That they understand that more than one person lives in a house.

Spying on us?



Presumably he means Internet of Things, and Snowden et. al.

Graham.

--
“If you want to keep a secret, you must also hide it from yourself.”  
George Orwell, 1984

Re: Net Neutrality...

[Fletcher Kittredge]

Page 9-10 from the Connect America Fund (CAF) Report and Order on Rural
Broadband Experiments.  I don't think this needs translation, but please
read carefully.

*2.*
We concluded in the Tech Transitions Order that we would encourage
participation in

the rural broadband experiments from a wide range of entities—including
competitive local exchange
carriers, electric utilities, fixed and mobile wireless providers, WISPs,
State and regional authorities,
Tribal governments, and partnerships among interested entities.49
 We were encouraged to see the
diversity in the expressions of interest submitted by interested parties.
Of the more than 1,000
expressions of interest filed, almost half were from entities that are not
currently ETCs, including electric
utilities, WISPS, and agencies of state, county or local governments.
*22.* We remind entities that they need not be ETCs at the time they
initially submit their
formal proposals for funding through the rural broadband experiments, but
that they must obtain ETC
designation after being identified as winning bidders for the funding award.
 As stated in the Tech
Transitions Order, we expect entities to confirm their ETC status within 90
days of the public notice
announcing the winning bidders selected to receive funding.51
 Any winning bidder that fails to notify the
Bureau that it has obtained ETC designation within the 90 day timeframe
will be considered in default
and will not be eligible to receive funding for its proposed rural
broadband experiment. Any funding that
is forfeited in such a manner will not be redistributed to other
applicants. We conclude this is necessary
so that we can move forward with the experiments in a timely manner.
However, a waiver of this
deadline may be appropriate if a winning bidder is able to demonstrate that
it has engaged in good faith to
obtain ETC designation, but has not received approval within the 90-day
timeframe.[52]
*23.* We sought comment in the Tech Transitions FNPRM on whether to adopt a
presumption
that if a state fails to act on an ETC application from a selected
participant within a specified period of
time, the state lacks jurisdiction over the applicant, and the Commission
will address the ETC
application.   Multiple commenters supported this proposal.54
 We now conclude that, for purposes of this experiment, if after 90 days a
state has failed to act on a pending ETC application, an entity may
request that the Commission designate it as an ETC, pursuant to section
214(e)(6).55
 Although we are
confident that states share our desire to work cooperatively to advance
broadband, and we expect states to
expeditiously designate qualified entities that have expressed an interest
in providing voice and
broadband to consumers in price cap areas within their states, we also
recognize the need to adopt
measures that will provide a pathway to obtaining ETC designation in
situations where there is a lack of
action by the state.
==
 52 See 47 C.F.R. § 1.3. We expect entities selected for funding to submit
their ETC applications to the relevant
jurisdiction as soon as possible after release of the public notice
announcing winning bids, and will presume an
entity to have shown good faith if it files its ETC application within 15
days of release of the public notice. A
waiver of the 90-day deadline would be appropriate if, for example, if an
entity has an ETC application pending with
a state, and the state’s next meeting at which it would consider the ETC
application will occur after the 90-day
window.



On Tue, Jul 15, 2014 at 10:01 PM, Brett Glass na...@brettglass.com wrote:

 I'll just say that we've consulted legal counsel about what it would take
 to become an ETC, and it's simply too burdensome for us to consider. We'd
 need to become a telephone company, at the very time when old fashioned
 telephone service is becoming a thing of the past. (We enthusiastically
 support over the top VoIP so that we can help our customers get
 inexpensive
 telephone service without ourselves having to be a telephone company.)

 --Brett Glass


 At 07:53 PM 7/15/2014, Bob Evans wrote:

  I think your point needs to be explained. Because anything gnment is
 riddled will large carrier benefiting. Look at the school discounts for
 internet services...pretty much just for LECs.
 Thank You
 Bob Evans
 CTO





-- 
Fletcher Kittredge
GWI
8 Pomerleau Street
Biddeford, ME 04005-9457
207-602-1134

Re: Net Neutrality...

[Scott Helms]

Here is the actual document for defining what the federal government
considers to be an ETC.  Keep in mind that state level boards actually make
the designation based on these, and potentially state level regulations, so
there is some variation based on the state(s) you operate in.  Having said,
that the requirements have not seemed overly onerous to us where we have
considered them, which certainly isn't all 50 states.

https://apps.fcc.gov/edocs_public/attachmatch/FCC-05-46A1.pdf

20. As described above, ETC applicants must meet statutorily prescribed
requirements before
we can approve their designation as an ETC.46 Based on the record before
us, we find that an ETC
applicant must demonstrate: (1) a commitment and ability to provide
services, including providing
service to all customers within its proposed service area; (2) how it will
remain functional in emergency
situations; (3) that it will satisfy consumer protection and service
quality standards; (4) that it offers
local usage comparable to that offered by the incumbent LEC; and (5) an
understanding that it may be
required to provide equal access if all other ETCs in the designated
service area relinquish their
designations pursuant to section 214(e)(4) of the Act.47 As noted above,
these requirements are
mandatory for all ETCs designated by the Commission. ETCs designated by the
Commission prior to
this Report and Order will be required to make such showings when they
submit their annual
certification filing on October 1, 2006. We also encourage state
commissions to apply these
requirements to all ETC applicants over which they exercise jurisdiction.
We do not believe that
different ETCs should be subject to different obligations, going forward,
because of when they
happened to first obtain ETC designation from the Commission or the state.
These are responsibilities
associated with receiving universal service support that apply to all ETCs,
regardless of the date of
initial designation.

Its also worth noting that you do _not_ have to offer voice or life line
services according the federal guidelines.

3947 U.S.C. § 214(e)(1)(A). The services that are supported by the federal
universal service support mechanisms
are: (1) voice grade access to the public switched network; (2) local
usage; (3) Dual Tone Multifrequency (DTMF)
signaling or its functional equivalent; (4) single-party service or its
functional equivalent; (5) access to emergency
services, including 911 and enhanced 911; (6) access to operator services;
(7) access to interexchange services; (8)
access to directory assistance; and (9) toll limitation for qualifying
low-income customers. See 47 C.F.R. § 54.101.
 While section 214(e)(1) requires an ETC to “offer” the services supported
by the federal universal service support
mechanisms, the Commission has determined that this does not require a
competitive carrier to actually provide the
supported services throughout the designated service area before
designation as an ETC. Federal-State Joint Board
on Universal Service; Western Wireless Corporation Petition for Preemption
of an Order of the South Dakota
Public Utilities Commission, Declaratory Ruling, CC Docket No. 96-45, 15
FCC Rcd 15168, 15172-75, paras. 10-
18 (2000), recon. pending (Section 214(e) Declaratory Ruling).

That was once a requirement that kept most WISPs from being able to
participate, but is no longer.  I don't personally see a large hurdle for
WISPs in the federal language and I work with 4 I know of that have ETC
status in 3 different states.


Scott Helms
Vice President of Technology
ZCorum
(678) 507-5000

http://twitter.com/kscotthelms



On Tue, Jul 15, 2014 at 9:53 PM, Bob Evans b...@fiberinternetcenter.com
wrote:

 I think your point needs to be explained. Because anything gnment is
 riddled will large carrier benefiting. Look at the school discounts for
 internet services...pretty much just for LECs.
 Thank You
 Bob Evans
 CTO




  I have stayed out of much of this, but can't help myself.   Along with
  everything else, you are seriously misinformed about the process of
  becoming an ETC.   It is not onerous.   Please stop.   You are giving
  rural
  ISPs a bad reputation.
 
 
  On Tue, Jul 15, 2014 at 7:57 PM, Brett Glass na...@brettglass.com
 wrote:
 
  At 05:06 PM 7/15/2014, Rubens Kuhl wrote:
 
   Do you see Connect America Fund, the successor to Universal Service
  Fund,
  as a threat to US rural WISPs or as the possible solution for them ?
 
 
  It's a major threat to rural WISPs and all competitive ISPs. Here's why.
  The FCC is demanding that ISPs become Eligible Telecommunications
  Carriers, or ETCs, before they can receive money from it. An ETC is a
  telephone company which is regulated under the mountain of regulations,
  requirements, and red tape of Title II of the Telecomm Act. It has to
  report to both state regulatory agencies AND the FCC. It's a
  classification
  that doesn't 

Re: Net Neutrality...

[Miles Fidelman]

ETCs aside for a moment, the NTIA used to give out an awful lot of money 
for rural electrification, then for telecom - a lot of it going to small 
players, coops, and municipalities.  A Probably still does - though I 
haven't followed the program in recent years.  Yes, writing and selling 
a grant proposal can be tedious, but then again, so is a venture capital 
proposal, or dealing with banks.  Or, for that matter, selling to large 
customers public or private.


Miles Fidelman

On Tue, Jul 15, 2014 at 9:53 PM, Bob Evans b...@fiberinternetcenter.com 
wrote:

I think your point needs to be explained. Because anything gnment is
riddled will large carrier benefiting. Look at the school discounts for
internet services...pretty much just for LECs.
Thank You
Bob Evans
CTO





I have stayed out of much of this, but can't help myself.   Along with
everything else, you are seriously misinformed about the process of
becoming an ETC.   It is not onerous.   Please stop.   You are giving
rural
ISPs a bad reputation.


On Tue, Jul 15, 2014 at 7:57 PM, Brett Glass na...@brettglass.com

wrote:

At 05:06 PM 7/15/2014, Rubens Kuhl wrote:

  Do you see Connect America Fund, the successor to Universal Service
Fund,

as a threat to US rural WISPs or as the possible solution for them ?


It's a major threat to rural WISPs and all competitive ISPs. Here's why.
The FCC is demanding that ISPs become Eligible Telecommunications
Carriers, or ETCs, before they can receive money from it. An ETC is a
telephone company which is regulated under the mountain of regulations,
requirements, and red tape of Title II of the Telecomm Act. It has to
report to both state regulatory agencies AND the FCC. It's a
classification
that doesn't fit ISPs at all, but they would have to subject themselves
to
this heavy-handed regulation before they could get a dime from the fund.

The FCC just announced a rural broadband experiment in which it will
fund ETCs, but not pure-play ISPs, to build out rural broadband; see

http://www.fcc.gov/document/rural-broadband-experiments-order

As part of this experiment, the FCC will pay telephone companies to
overbuild us, even though the residents of the areas in question already
have service. This is because, as far as the regulators are concerned,
if
they do not have their regulatory hooks in us, we don't exist and any
service we provide does not count. The experiment also requires
participants to tie up large amounts of money in escrow accounts so that
they can obtain letters of credit guaranteeing performance.

All of this is, alas, the regulators' way of attempting to destroy those
whom they cannot regulate.

IMHO, the USF is outmoded and should be disbanded.

--Brett Glass






--
Fletcher Kittredge
GWI
8 Pomerleau Street
Biddeford, ME 04005-9457
207-602-1134







--
In theory, there is no difference between theory and practice.
In practice, there is.    Yogi Berra

Re: Net Neutrality...

[Bob Evans]

Wow, first time I ever saw this line so thanks for the text.

partnerships among interested entities...that leaves it open to all.
Unless, a bureaucrat wants to pull out this some other supporting
documentssomething additional that is all encompassing like our equal
opportunity, filed and registered bla-blah-blah, on the government
list...and now you have to do this and this and this. Sometimes it's even
referred to on page 681...723...it often becomes a battle of words. That
cost money and demands time. Do you know how difficult it is to teach a
lawyer somethings a simple as what an IP address is.

Seen that happen before a lot !  Just saying.however, you did prove
your point that it's possible. Well done.

Thank You
Bob Evans
CTO




 Page 9-10 from the Connect America Fund (CAF) Report and Order on Rural
 Broadband Experiments.  I don't think this needs translation, but please
 read carefully.

 *2.*
 We concluded in the Tech Transitions Order that we would encourage
 participation in

 the rural broadband experiments from a wide range of entities—including
 competitive local exchange
 carriers, electric utilities, fixed and mobile wireless providers, WISPs,
 State and regional authorities,
 Tribal governments, and partnerships among interested entities.49
  We were encouraged to see the
 diversity in the expressions of interest submitted by interested parties.
 Of the more than 1,000
 expressions of interest filed, almost half were from entities that are not
 currently ETCs, including electric
 utilities, WISPS, and agencies of state, county or local governments.
 *22.* We remind entities that they need not be ETCs at the time they
 initially submit their
 formal proposals for funding through the rural broadband experiments, but
 that they must obtain ETC
 designation after being identified as winning bidders for the funding
 award.
  As stated in the Tech
 Transitions Order, we expect entities to confirm their ETC status within
 90
 days of the public notice
 announcing the winning bidders selected to receive funding.51
  Any winning bidder that fails to notify the
 Bureau that it has obtained ETC designation within the 90 day timeframe
 will be considered in default
 and will not be eligible to receive funding for its proposed rural
 broadband experiment. Any funding that
 is forfeited in such a manner will not be redistributed to other
 applicants. We conclude this is necessary
 so that we can move forward with the experiments in a timely manner.
 However, a waiver of this
 deadline may be appropriate if a winning bidder is able to demonstrate
 that
 it has engaged in good faith to
 obtain ETC designation, but has not received approval within the 90-day
 timeframe.[52]
 *23.* We sought comment in the Tech Transitions FNPRM on whether to adopt
 a
 presumption
 that if a state fails to act on an ETC application from a selected
 participant within a specified period of
 time, the state lacks jurisdiction over the applicant, and the Commission
 will address the ETC
 application.   Multiple commenters supported this proposal.54
  We now conclude that, for purposes of this experiment, if after 90 days a
 state has failed to act on a pending ETC application, an entity may
 request that the Commission designate it as an ETC, pursuant to section
 214(e)(6).55
  Although we are
 confident that states share our desire to work cooperatively to advance
 broadband, and we expect states to
 expeditiously designate qualified entities that have expressed an interest
 in providing voice and
 broadband to consumers in price cap areas within their states, we also
 recognize the need to adopt
 measures that will provide a pathway to obtaining ETC designation in
 situations where there is a lack of
 action by the state.
 ==
  52 See 47 C.F.R. § 1.3. We expect entities selected for funding to
 submit
 their ETC applications to the relevant
 jurisdiction as soon as possible after release of the public notice
 announcing winning bids, and will presume an
 entity to have shown good faith if it files its ETC application within 15
 days of release of the public notice. A
 waiver of the 90-day deadline would be appropriate if, for example, if an
 entity has an ETC application pending with
 a state, and the state’s next meeting at which it would consider the ETC
 application will occur after the 90-day
 window.



 On Tue, Jul 15, 2014 at 10:01 PM, Brett Glass na...@brettglass.com
 wrote:

 I'll just say that we've consulted legal counsel about what it would
 take
 to become an ETC, and it's simply too burdensome for us to consider.
 We'd
 need to become a telephone company, at the very time when old fashioned
 telephone service is becoming a thing of the past. (We enthusiastically
 support over the top VoIP so that we can help our customers get
 inexpensive
 telephone service without ourselves having to be a telephone company.)

 --Brett Glass


 At 07:53 PM 7/15/2014, Bob Evans wrote:

  I think 

Re: Net Neutrality...

[Fred Baker (fred)]

Relevant article by former FCC Chair

http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/


signature.asc
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Re: Net Neutrality...

[Eric Brunner-Williams]

On 7/16/14 7:50 AM, Fred Baker (fred) wrote:

Relevant article by former FCC Chair

http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/


It reads like a hit piece (by a Republican free markets ideologue) on 
a (Progressive) Democratic primary candidate for Lt. Governor of New 
York, not like a reasoned case by an informed policy analyst.


YMMV, of course.
Eric

Re: Net Neutrality...

[Jason Iannone]

Barry,

Your point is well made and applies to present conditions.  I'm not
sure the current Net Neutrality debate extends so much to access,
though we should talk about that (Consumer access service policy: No
servers at home!? Asymmetric bandwidth profiles!?  What is this, the
dark ages?).  The problem as I understand exists within the realm of
the backbone and content where scale is a concern.  And your point
still applies as some explicit value for adequate can be determined,
i.e. 10 or 100g peer and transit links.  Regarding neutrality, if
public megacorp monetizes priority traffic, does that present a moral
hazard for megacorp to allow interface saturation and push more
content into priority service?  What is the high water mark for
priority services reaching best effort behavior, i.e. all traffic is
priority contending for a single queue?  Anyway, I feel like this
horse is dead.  I'd like to talk about neutrality in symmetry on
consumer access services.  I'd gladly trade my 30/5 for 15/15 with the
ability to host services for the ~$60/mo I pay today.

Jason

On Tue, Jul 15, 2014 at 12:19 PM, Barry Shein b...@world.std.com wrote:

 Re: Net Neutrality

 In the past all attempts to create a content competitor to the
 internet-at-large -- to create the one true commercial content
 provider -- have failed.

 For example, AOL, Prodigy, various portals, MSN, Netscape, on and
 on. We can split hairs about who goes on the list but the result is
 clear since if even only one qualifies we know it failed. The point
 stands.

 To a great extent net neutrality (or non-neutrality) is yet another
 attempt to create a content competitor to the internet-at-large.

 This doesn't prove it won't work but the track record viewed this way
 is bad: 100% failure rate to date.

 Mere bandwidth can foil any such nefarious plans, assuming an
 enforceable zero bandwidth (or nearly so) isn't one of the choices.

 But just somewhat less bandwidth or as proposed prioritized bandwidth?

 Maybe not a problem/advantage for very long.

   Note: I'm using bandwidth measures below as a stand-in for all
   possible throughput parameters.

 For example if the norm have-not bandwidth were 100mb/s but the
 have bw was 1gb/s I doubt it would make much difference to many,
 many business models such as news and magazine distribution. Those
 services in general don't even need 100mb/s end to end (barring some
 ramp-up in what they view as service) so what do they care if they
 were excluded from 1gb/s except as a moral calumny?

 Do you think you could tell the difference between surfing
 news.google.com at 100mb/s vs 1gb/s? I don't.

 And if have-not-bw was 1gb/s and have 10gb/s it would make little
 difference to video stream services except perhaps when someone tried
 to ramp up to 4K or whatever. But, etc., there's always a new horizon,
 or will be for a while.

 So the key to network non-neutrality having any effect is bandwidth
 inadequacy for certain competitive business models. It only can exist
 as a business force in a bw-poor world.

 Right now the business model of concern is video streaming.

 But at what bandwidth is video streaming a non-issue?

 That is, I have 100mb/s, you have 1gb/s. We both watch the same
 movie. Do we even notice?  How about 1gb/s vs 10gb/s?

 There exists a low and high (practical) bandwidth range within which
 it simply doesn't make any difference to a given business model.

 56kb dial-up is sufficient for displaying 512kx512k images, and 1mb/s
 is luxurious for that application, you couldn't gain a business
 advantage by offering 10mb/s modest-sized image downloads.

 There's simply no such open-ended extrapolation. Adequate is adequate.

   The internet views attempts at content monopoly as damage and routes
   around it.

 to paraphrase John Gilmore's famous observation on censorship.


 P.S. I suppose an up-and-coming bandwidth business model which vastly
 exceeds video streaming is adequate (i.e., frequent and complete)
 cloud backup. With cheap consumer disks in the multi-TB range, well,
 do the math.

 --
 -Barry Shein

 The World  | b...@theworld.com   | http://www.TheWorld.com
 Purveyors to the Trade | Voice: 800-THE-WRLD| Dial-Up: US, PR, Canada
 Software Tool  Die| Public Access Internet | SINCE 1989 *oo*

Re: Net Neutrality...

[Doug Barton]

On 07/16/2014 08:45 AM, Eric Brunner-Williams wrote:

On 7/16/14 7:50 AM, Fred Baker (fred) wrote:

Relevant article by former FCC Chair

http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/



It reads like a hit piece (by a Republican free markets ideologue) on
a (Progressive) Democratic primary candidate for Lt. Governor of New
York, not like a reasoned case by an informed policy analyst.


Errr, I didn't see anything about any LTG candidates in that piece, what 
did I miss? I'm also curious about what it is that you think is 
misstated or overblown in that piece that would lead you to believe that 
it's a hit piece.


Doug

Re: Net Neutrality...

[Collin Anderson]

On Wed, Jul 16, 2014 at 6:57 PM, Doug Barton do...@dougbarton.us wrote:

 Errr, I didn't see anything about any LTG candidates in that piece, what
 did I miss? I'm also curious about what it is that you think is misstated
 or overblown in that piece that would lead you to believe that it's a hit
 piece.


Tim Wu is a candidate for Lieutenant Governor race in New York this year.


-- 
*Collin David Anderson*
averysmallbird.com | @cda | Washington, D.C.

Re: Net Neutrality...

[Doug Barton]

On 07/16/2014 12:24 PM, Collin Anderson wrote:


On Wed, Jul 16, 2014 at 6:57 PM, Doug Barton do...@dougbarton.us
mailto:do...@dougbarton.us wrote:

Errr, I didn't see anything about any LTG candidates in that piece,
what did I miss? I'm also curious about what it is that you think is
misstated or overblown in that piece that would lead you to believe
that it's a hit piece.


Tim Wu is a candidate for Lieutenant Governor race in New York this year.


Ah, gotcha. :)  Thanks for that insight.

Doug

Re: Net Neutrality...

[Barry Shein]

On July 15, 2014 at 13:08 na...@brettglass.com (Brett Glass) wrote:
  At 12:19 PM 7/15/2014, Barry Shein wrote:
  
  There exists a low and high (practical) bandwidth range within which
  it simply doesn't make any difference to a given business model.
  
  Very true. And there's another factor to consider.
  
  Estimates of the maximum bandwidths of all the human senses, combined,
  range between the capacity of a T1 line (at the low end) and
  about 4 Mbps (at the high end). A human being simply is not wired to
  accept more input. (Yes, machines could digest more... which means that
  additional bandwidth to and from the home might be useful for the purpose
  of spying on us.) What does this imply about the FCC's proposal to
  redefine broadband as a symmetrical 10 Mbps?

You can do the same sort of calculation for devices. Once the screen
is updating at the screen refresh rate you are done, plus or minus
getting a faster screen but as you note that's not open-ended. At some
point you can't see faster refreshes anyhow.

etc for other human interface devices.


-- 
-Barry Shein

The World  | b...@theworld.com   | http://www.TheWorld.com
Purveyors to the Trade | Voice: 800-THE-WRLD| Dial-Up: US, PR, Canada
Software Tool  Die| Public Access Internet | SINCE 1989 *oo*

Re: Net Neutrality...

[Michael Hallgren]

Le 16/07/2014 17:45, Eric Brunner-Williams a écrit :
 On 7/16/14 7:50 AM, Fred Baker (fred) wrote:
 Relevant article by former FCC Chair

 http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/


 It reads like a hit piece (by a Republican free markets ideologue)
 on a (Progressive) Democratic primary candidate for Lt. Governor of
 New York, not like a reasoned case by an informed policy analyst.

 YMMV, of course.

I tend to agree ;-) Now, what's the ops content of this discussion?
Might be a better choice to reroute this discussion
to a suitable ISOC forum? I don't judge, but I think the debate is of
great value, but not necessarily ``here'', but rather
``there''?---see you there? ;-)

Cheers,

mh

 Eric

Re: Net Neutrality...

[Randy Bush]

 http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/

In a common hypothetical they cite, ISPs would slow — or buffer —
traffic for Netflix unless it unfairly pays for more access points,
or “off ramps,” and better quality of service.

In truth, however, market failures like these have never happened

the author neglected to say what planet he was on

randy

Re: Net Neutrality...

[joel jaeggli]

On 7/16/14 3:30 PM, Randy Bush wrote:
 http://www.washingtonpost.com/posteverything/wp/2014/07/14/this-is-why-the-government-should-never-control-the-internet/
 In a common hypothetical they cite, ISPs would slow — or buffer —
 traffic for Netflix unless it unfairly pays for more access points,
 or “off ramps,” and better quality of service.

 In truth, however, market failures like these have never happened
If one deliberately allows a path to become congested in the direction
towards a receiver, It is the peer, not the receiving network who
discards the traffic...
 the author neglected to say what planet he was on
 randy





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Re: Net Neutrality...

[manning]

regarding content, I’m not sure you and I live in the same media space, but I 
live in the same space as Springsteen who wrote 57 CHANNELS (AND NOTHIN' ON)”

reports of TW in NYC having 2000 channels and nothing on are common.  granted 
that major BB providers -own- a lot of content, but they certainly don’t allow 
for à la carte
access - one must take the whole bundle.  (blame the FCC)

the promise of the Internet was that -anyone- could create and publish.   
that called for curation skills (assuming equal access to published content)

such a system would have allowed for personally tailored content on a global 
scale.

Instead, we have “eyeballs” that are encouraged to spend USD 4/per view of 
poorly digitized DVD copies of 30 year old movies
and all the “Honey Boo Boo” you can handle.   And be GRATEFUL for the privilege 
….

That real, quality content is out there, not part of the IP stable of corporate 
giants, is indisputable.   As is the fact that
it is effectively locked out of the Internet at large.   (youtube was a grand, 
failed, experiment)

/bill  (who will return to his oubliette now)


On 14July2014Monday, at 16:15, Miles Fidelman mfidel...@meetinghouse.net 
wrote:

 Steve, the key piece you're missing here is that the major broadband 
 providers are both
 - near-monopolies in their access areas
 - content providers
 
 Not a situation where market forces can work all that well.
 
 Miles Fidelman
 
 Naslund, Steve wrote:
 Net Neutrality is really something that has me worried.  I know there have 
 to be some ground rules, but I believe that government regulation of 
 internet interconnection and peering is a sure way to stagnate things.  I 
 have been in the business a long time and remember how peering kind of 
 evolved based on mutual benefit or some concept of doing the right thing.  
 For example, at InterAccess Chicago, our peer policy in the late 90s was 
 pretty much the following.
 
 1.  Non-profits or educational institutions could private peer with us as 
 long as they bore the cost of the circuit.  (this kind of connection was 
 more beneficial to them than us).
 2.  Comparable sized carriers got to peer with us, with each of us picking 
 up our portions of equipment and circuit cost since it was mutually 
 beneficial.
 3.  We would peer with anyone at any NAP we had a mutual appearance in.
 4.  Larger network usual would not peer with smaller networks without some 
 sort of compensation.
 
 Seemed to work pretty fair at the time and we managed the backbone by 
 watching customer traffic.  If things got congested, you paid for or peered 
 with whoever you needed to in order to get acceptable performance for our 
 customers.  The big guys did get to call the shots and made you pay but then 
 again they provided the largest fastest connections so I guess it was fair 
 enough.  It may have been the wild west in some ways but at that time 
 everyone needed to get along because if your peering policies were unfair 
 you would get universally shunned and then you would have real problems.  I 
 hate that the network operators now feel the need to ask the government to 
 step in.  When you ask for that don't be surprised that the government 
 creates a cumbersome mess and disadvantages you in another way.  The problem 
 is that the gov does not react at internet speed.
 
 I remember the first unbundling agreements and trust me when I say that 
 ourselves and the ILEC both found the gov't rules to be nearly unworkable.  
 We eventually started with the telecom act framework that forced them to the 
 table where they finally sat down with us and said Ok, Ok, what do you 
 really need here and we banged out a pretty good interconnection agreement 
 that was workable for both of us.  Well, about as workable as it gets with 
 an ILEC.
 
 I think what will really drive everything is the market forces.  You either 
 provide what your end user wants or you go out of business.  The customer 
 could care less who pays for what pieces or what is fair because in the end, 
 their service provider is the only one they will punish.  If Netflix becomes 
 universally hard to connect to, then they will lose the customers.  The 
 customer does not really care why your connectivity sucks, they just know 
 that it does and that if someone better comes along, they are gone.
 
 Maybe something better would be some sort of industry group that you could 
 become a member of and that group could resolve peering disputes through 
 some kind of arbitration process.   The benefit of being a member could be 
 something like the opportunity to peer with any other member on demand with 
 some sort of cost splitting arrangement.  They would need something like a 
 group wide interconnection agreement.  The responsibility would then be the 
 industry and not some appointed FCC working group that spends all of their 
 time writing convoluted gibberish.  If the group was big enough and powerful 
 enough, the incentive to 

Re: Net Neutrality...

[Graham Donaldson]

On 2014-07-15 12:11, manning wrote:

(youtube was
a grand, failed, experiment)



It was?  I stopped watching broadcast TV in about 2010, and watch 
Netflix, downloaded video, other streaming, and Youtube in roughly equal 
amounts.  My main gripe with Netflix is overly liberal bias.


But this is all off topic I guess.

Regards,

Graham

--

“If you want to keep a secret, you must also hide it from yourself.”  
George Orwell, 1984

Re: Net Neutrality...

[Graham Donaldson]

On 2014-07-15 13:24, Ray Soucy wrote:

My main gripe with Netflix is overly liberal bias.


Well that escalated quickly.


You're right, I should have kept my mouth shut.  Sorry about that.  It's 
just an opinion, you're all welcome to have your own opinion of it, I'm 
wasn't intended for debate, especially when its so off topic.


Graham.


--

“If you want to keep a secret, you must also hide it from yourself.”  
George Orwell, 1984

Re: Net Neutrality...

[Blake Dunlap]

Reality has a well-known liberal bias

-Blake

On Tue, Jul 15, 2014 at 7:35 AM, Graham Donaldson
gra...@airstripone.org.uk wrote:
 On 2014-07-15 13:24, Ray Soucy wrote:

 My main gripe with Netflix is overly liberal bias.


 Well that escalated quickly.


 You're right, I should have kept my mouth shut.  Sorry about that.  It's
 just an opinion, you're all welcome to have your own opinion of it, I'm
 wasn't intended for debate, especially when its so off topic.

 Graham.



 --

 “If you want to keep a secret, you must also hide it from yourself.”  George
 Orwell, 1984

RE: Net Neutrality...

[Naslund, Steve]

Sorry to be cold about this but as high speed connectivity becomes more 
necessity than luxury, the market will still react.  For example,  I could move 
to the top of a mountain with no electric however most of us would not.  If I 
was buying a home and I could not get decent high speed Internet, I would not 
live there because that is my business and I need it.  If rural areas cannot 
get the kind of services they need from the carriers they have, they will have 
to react and break the monopoly.  The economic model still works but is not as 
fast and efficient.

There is always satellite which will all know if painful but it is an option so 
there is almost always not a real monopoly.  Granted, if all I have to do is 
beat satellite, my bar is lower.  You are right about becoming your own ISP.  
If you want to lose a lot of money in a hurry I would advise you to go to Las 
Vegas or become a facilities based small ISP.

Steven Naslund
Chicago IL


There's the problem.  In my neck of the woods, there is one and only one 
provider.  They have a guaranteed monopoly for the next few decades.  They 
got a huge grant to put in FTTH from the government and they still have 
pricing from the last decade.

An 8/1 connection is $120/mo and require you to get dialtone (they say it's 
FCC mandated) to the tune of an additional $20/mo (that's with no long 
distance and every possible feature stripped).  (Side-note: when the power 
fails during the winter, they turn off all internet access after 5 
minutes so they can save battery power for the phones--which travel the 
exact same fiber path as the interntet).

I'm not a huge fan of Comcast's recent actions, but if they rolled into the 
area with the same offer they have in town (100/25 for ~$75/mo), I would 
switch faster than you could spell monopoly.

There's plenty of fiber lying within 1/4 mile from my house (runs between 
Seattle and Portland), but none of the companies are interested in being a 
local ISP, or leasing to a non-business, and I couldn't afford to start my 
own, let alone trenching my own fiber to other residents who are also fed 
up.

It doesn't matter to me what the big players do because as a consumer, I 
still don't have a choice.  So while I find my local provider's practices 
utterly despicable, I can't exactly speak with my wallet unless I quit being 
an IT guy, cancel my internet, and start raising goats or something.

-A

RE: Net Neutrality...

[Naslund, Steve]

I don't believe either of those points.  I will grant you that the LECs are 
near monopolies in some rural areas, but these are few and far between.  Yes, a 
LEC may control the last mile but I can usually get circuits from a lot of 
carriers.  A company I work for has over 50 locations mostly in rural areas and 
we do not have much problem getting Sprint and CenturyLink access circuits to 
them regardless of location.  In fact, we have never found a location in the US 
that I can't get both of those carrier to deliver to us.  In a lot of areas 
there is also a cable provider available.  Residential users have somewhat more 
limited options but you do always have the option of deciding where to live.  
Most of us in this group would consider the broadband options available to them 
before they move.

Being a content provider has very little to do with market forces.  Comcast is, 
of course, a major content provider and access provider but if they limit their 
customer's access to Netflix (which they have been accused of) the customers 
will still react to that.  The content providing access provider has to know 
that no matter how good their content is, they are not the only source and 
their customers will react to that.  I think the service providers are 
sophisticated enough to know that and they will walk the fine line of keeping 
their customer happy while trying to promote their own content.  It is like 
saying a Ford dealer does not want to change the oil on your Chevy, sure they 
would like for you to have bought from them but they will take what they can 
get.

Steven Naslund

 


Steve, the key piece you're missing here is that the major broadband 
providers are both
- near-monopolies in their access areas
- content providers

Not a situation where market forces can work all that well.

Miles Fidelman

Re: Net Neutrality...

[Scott Helms]

Steve,

I'd question you're use of the word rural if this statement is accurate, Yes,
a LEC may control the last mile but I can usually get circuits from a lot
of carriers.  A company I work for has over 50 locations mostly in rural
areas and we do not have much problem getting Sprint and CenturyLink access
circuits to them regardless of location.  In fact, we have never found a
location in the US that I can't get both of those carrier to deliver to
us.  Perhaps you've just been lucky or your economics are different, but I
can (off list) provide you with lots of locations in the US that neither of
those operators, much less both, can reach.  Perhaps more importantly the
economics are such that one and only one tier 2 (sometimes tier 2/3)
operator is available.  I work with an ISP in west Texas who has been
waiting on an ATT build out for nearly 14 months to be able to buy
bandwidth from anyone because there is no remaining capacity on the SONET
network and no other operator has any physical facilities in the area.


Scott Helms
Vice President of Technology
ZCorum
(678) 507-5000

http://twitter.com/kscotthelms



On Tue, Jul 15, 2014 at 11:19 AM, Naslund, Steve snasl...@medline.com
wrote:

 I don't believe either of those points.  I will grant you that the LECs
 are near monopolies in some rural areas, but these are few and far between.
  Yes, a LEC may control the last mile but I can usually get circuits from a
 lot of carriers.  A company I work for has over 50 locations mostly in
 rural areas and we do not have much problem getting Sprint and CenturyLink
 access circuits to them regardless of location.  In fact, we have never
 found a location in the US that I can't get both of those carrier to
 deliver to us.  In a lot of areas there is also a cable provider available.
  Residential users have somewhat more limited options but you do always
 have the option of deciding where to live.  Most of us in this group would
 consider the broadband options available to them before they move.

 Being a content provider has very little to do with market forces.
  Comcast is, of course, a major content provider and access provider but if
 they limit their customer's access to Netflix (which they have been accused
 of) the customers will still react to that.  The content providing access
 provider has to know that no matter how good their content is, they are not
 the only source and their customers will react to that.  I think the
 service providers are sophisticated enough to know that and they will walk
 the fine line of keeping their customer happy while trying to promote their
 own content.  It is like saying a Ford dealer does not want to change the
 oil on your Chevy, sure they would like for you to have bought from them
 but they will take what they can get.

 Steven Naslund




 Steve, the key piece you're missing here is that the major broadband
 providers are both
 - near-monopolies in their access areas
 - content providers

 Not a situation where market forces can work all that well.

 Miles Fidelman

Re: Net Neutrality...

[William Herrin]

On Mon, Jul 14, 2014 at 6:24 PM, Naslund, Steve snasl...@medline.com wrote:
 I think what will really drive everything is the
 market forces.  You either provide what your
 end user wants or you go out of business.

Hi Steve,

Barrier to entry tends to negate market forces.

I dislike Verizon. Their FiOS service does not provide the technology
I really want (e.g. delegated reverse DNS and a battery backup in the
local vault that doesn't cut my voip via internet on power loss) and
their customer support process is infuriating (It took me 5 hours of
calls over 2 months to fix my login to a point where I could change
the credit card used for payment.I just wanted to pay the damn bill.)

And yet I buy their service. No one else is likely to bring fiber to
my home and they categorically refuse to unbundle just the fiber part
to any other business that might be willing to provide the service I
actually want.

Barrier to entry, typically in the form of sunk infrastructure,
cross-subsidy and/or regulatory shenanigans, tends to fully negate the
effect of other market forces. You don't have to give the customer
what they want. You just have to make sure it is impractical for
anyone else to sell them something better.

Regards,
Bill Herrin



-- 
William Herrin  her...@dirtside.com  b...@herrin.us
Owner, Dirtside Systems . Web: http://www.dirtside.com/
Can I solve your unusual networking challenges?

Re: Net Neutrality...

[Barry Shein]

Re: Net Neutrality

In the past all attempts to create a content competitor to the
internet-at-large -- to create the one true commercial content
provider -- have failed.

For example, AOL, Prodigy, various portals, MSN, Netscape, on and
on. We can split hairs about who goes on the list but the result is
clear since if even only one qualifies we know it failed. The point
stands.

To a great extent net neutrality (or non-neutrality) is yet another
attempt to create a content competitor to the internet-at-large.

This doesn't prove it won't work but the track record viewed this way
is bad: 100% failure rate to date.

Mere bandwidth can foil any such nefarious plans, assuming an
enforceable zero bandwidth (or nearly so) isn't one of the choices.

But just somewhat less bandwidth or as proposed prioritized bandwidth?

Maybe not a problem/advantage for very long.

  Note: I'm using bandwidth measures below as a stand-in for all
  possible throughput parameters.

For example if the norm have-not bandwidth were 100mb/s but the
have bw was 1gb/s I doubt it would make much difference to many,
many business models such as news and magazine distribution. Those
services in general don't even need 100mb/s end to end (barring some
ramp-up in what they view as service) so what do they care if they
were excluded from 1gb/s except as a moral calumny?

Do you think you could tell the difference between surfing
news.google.com at 100mb/s vs 1gb/s? I don't.

And if have-not-bw was 1gb/s and have 10gb/s it would make little
difference to video stream services except perhaps when someone tried
to ramp up to 4K or whatever. But, etc., there's always a new horizon,
or will be for a while.

So the key to network non-neutrality having any effect is bandwidth
inadequacy for certain competitive business models. It only can exist
as a business force in a bw-poor world.

Right now the business model of concern is video streaming.

But at what bandwidth is video streaming a non-issue?

That is, I have 100mb/s, you have 1gb/s. We both watch the same
movie. Do we even notice?  How about 1gb/s vs 10gb/s?

There exists a low and high (practical) bandwidth range within which
it simply doesn't make any difference to a given business model.

56kb dial-up is sufficient for displaying 512kx512k images, and 1mb/s
is luxurious for that application, you couldn't gain a business
advantage by offering 10mb/s modest-sized image downloads.

There's simply no such open-ended extrapolation. Adequate is adequate.

  The internet views attempts at content monopoly as damage and routes
  around it.

to paraphrase John Gilmore's famous observation on censorship.


P.S. I suppose an up-and-coming bandwidth business model which vastly
exceeds video streaming is adequate (i.e., frequent and complete)
cloud backup. With cheap consumer disks in the multi-TB range, well,
do the math.

-- 
-Barry Shein

The World  | b...@theworld.com   | http://www.TheWorld.com
Purveyors to the Trade | Voice: 800-THE-WRLD| Dial-Up: US, PR, Canada
Software Tool  Die| Public Access Internet | SINCE 1989 *oo*

Re: Net Neutrality...

[Brett Glass]

At 12:19 PM 7/15/2014, Barry Shein wrote:


There exists a low and high (practical) bandwidth range within which
it simply doesn't make any difference to a given business model.


Very true. And there's another factor to consider.

Estimates of the maximum bandwidths of all the human senses, combined,
range between the capacity of a T1 line (at the low end) and
about 4 Mbps (at the high end). A human being simply is not wired to
accept more input. (Yes, machines could digest more... which means that
additional bandwidth to and from the home might be useful for the purpose
of spying on us.) What does this imply about the FCC's proposal to
redefine broadband as a symmetrical 10 Mbps?

--Brett

Re: Net Neutrality...

[Doug Barton]

On 07/15/2014 12:08 PM, Brett Glass wrote:

At 12:19 PM 7/15/2014, Barry Shein wrote:


There exists a low and high (practical) bandwidth range within which
it simply doesn't make any difference to a given business model.


Very true. And there's another factor to consider.

Estimates of the maximum bandwidths of all the human senses, combined,
range between the capacity of a T1 line (at the low end) and
about 4 Mbps (at the high end). A human being simply is not wired to
accept more input. (Yes, machines could digest more... which means that
additional bandwidth to and from the home might be useful for the purpose
of spying on us.) What does this imply about the FCC's proposal to
redefine broadband as a symmetrical 10 Mbps?


Just off the top of my head 

More than one person in a location, and they are watching different shows.

Watch a show, while downloading something else in the background.

Downloading something, while uploading backups.

etc. etc.

This is a classic example of the oversubscription problem that I and 
others have described on numerous previous occasions, several of which 
have occurred since you joined the list. Your customers are using the 
service they are paying you to provide in a way that makes your life 
more difficult. You need to deal with that reality, not complain that it 
exists.


Doug

Re: Net Neutrality...

[Harlan Stenn]

Brett Glass writes:
 At 12:19 PM 7/15/2014, Barry Shein wrote:
 
 There exists a low and high (practical) bandwidth range within which
 it simply doesn't make any difference to a given business model.
 
 Very true. And there's another factor to consider.
 
 Estimates of the maximum bandwidths of all the human senses, combined,
 range between the capacity of a T1 line (at the low end) and
 about 4 Mbps (at the high end). A human being simply is not wired to
 accept more input. (Yes, machines could digest more... which means that
 additional bandwidth to and from the home might be useful for the purpose
 of spying on us.) What does this imply about the FCC's proposal to
 redefine broadband as a symmetrical 10 Mbps?

For single-person households, nefarious things.

For households (or small businesses) things change.  And while most
folks will not need those uplink speeds, for others it can be real
useful.

And yes, there is room for abuse.

H

Re: Net Neutrality FCC COMMENTS OF THE INTERNET ASSOCIATION

[Eliot Lear]

If you want to join the millions of comments, apparently the deadline
has been extended to midnight, July 18th.[1]

Eliot
[1]
http://online.wsj.com/articles/fcc-extends-comment-period-for-net-neutrality-1405449739

On 7/15/14, 10:02 PM, William Allen Simpson wrote:
 http://internetassociation.org/wp-content/uploads/2014/07/Comments.pdf

 Really good, for those of us with the patience to ponder it.  I tried
 writing my own FCC response, and was flummoxed by the difficulty.

 Official comment period ends today.

Re: Net Neutrality...

[Joly MacFie]

On Tue, Jul 15, 2014 at 3:08 PM, Brett Glass na...@brettglass.com wrote:


 Estimates of the maximum bandwidths of all the human senses, combined,
 range between the capacity of a T1 line (at the low end) and
 about 4 Mbps (at the high end). A human being simply is not wired to
 accept more input. (Yes, machines could digest more... which means that
 additional bandwidth to and from the home might be useful for the purpose
 of spying on us.) What does this imply about the FCC's proposal to
 redefine broadband as a symmetrical 10 Mbps?

 --Brett


That is per household, not per person.

And, in my experience, one needs around double or more of the listed
bandwidth for a robust streaming connection.

j

-- 
---
Joly MacFie  218 565 9365 Skype:punkcast
WWWhatsup NYC - http://wwwhatsup.com
 http://pinstand.com - http://punkcast.com
 VP (Admin) - ISOC-NY - http://isoc-ny.org
--
-

Re: Net Neutrality...

[Brett Glass]

At 01:24 PM 7/15/2014, Doug Barton wrote:


Just off the top of my head 

More than one person in a location, and they are watching different shows.


How many do you allow for per household? Do they want to pay to be 
able to saturate everyone's senses simultaneously, with different 
programming, at any time? (We can do that, but it will cost more.)


This is a classic example of the oversubscription problem that I 
and others have described on numerous previous occasions, several 
of which have occurred since you joined the list. Your customers 
are using the service they are paying you to provide in a way that 
makes your life more difficult.


Having customers use the service I sell them does not make my life 
more difficult. I state very clearly what they are paying for: a 
certain guaranteed minimum capacity, to a certain point on the 
Internet backbone, with a certain maximum duty cycle. I can (and 
often do) take spot measurements of the amount of capacity they are 
using, tell them how much they are using, and verify that they are 
getting what they pay for. If they want more, they can always purchase it.


The things that are making my life difficult at the moment include 
the following:


* Government agencies attempting to impose requirements upon us and 
then denying us the resources we need to fulfill them;


* Government agencies trying to dictate what users can buy rather 
than allowing them to choose;


* Corporations exploiting market power or attempting to use the 
government so as to tilt the playing field in their favor; and


* Corporations lying to consumers so as to get them to blame me for 
their own failings.


If I quit the business, it won't be because I don't care about my 
customers or love what I do. It'll be because government and 
corporations have put so many roadblocks in my way that I can no 
longer deliver.


--Brett Glass

Re: Net Neutrality...

[Brett Glass]

At 02:16 PM 7/15/2014, Joly MacFie wrote:
 
And, in my experience, one needs around double or more of the listed bandwidth 
for a robust streaming connection.

This is only true if the connection is of poor quality and dropped packets lead 
to regular 50% cuts in the data rate. Most users (and the FCC!) do not 
understand that, due to the Van Jacobson AIMD algorithm, quality matters far 
more than quantity when a service is delivered via TCP.

--Brett Glass

Re: Net Neutrality...

[Doug Barton]

Brett,

You've more or less accurately described the reality of the situation. 
Please feel free to proceed with the dealing with it suggestion that I 
also made as part of the post you responded to. :)


Good luck,

Doug


On 07/15/2014 01:42 PM, Brett Glass wrote:

At 01:24 PM 7/15/2014, Doug Barton wrote:


Just off the top of my head 

More than one person in a location, and they are watching different
shows.


How many do you allow for per household? Do they want to pay to be able
to saturate everyone's senses simultaneously, with different
programming, at any time? (We can do that, but it will cost more.)


This is a classic example of the oversubscription problem that I and
others have described on numerous previous occasions, several of which
have occurred since you joined the list. Your customers are using the
service they are paying you to provide in a way that makes your life
more difficult.


Having customers use the service I sell them does not make my life more
difficult. I state very clearly what they are paying for: a certain
guaranteed minimum capacity, to a certain point on the Internet
backbone, with a certain maximum duty cycle. I can (and often do) take
spot measurements of the amount of capacity they are using, tell them
how much they are using, and verify that they are getting what they pay
for. If they want more, they can always purchase it.

The things that are making my life difficult at the moment include the
following:

* Government agencies attempting to impose requirements upon us and then
denying us the resources we need to fulfill them;

* Government agencies trying to dictate what users can buy rather than
allowing them to choose;

* Corporations exploiting market power or attempting to use the
government so as to tilt the playing field in their favor; and

* Corporations lying to consumers so as to get them to blame me for
their own failings.

If I quit the business, it won't be because I don't care about my
customers or love what I do. It'll be because government and
corporations have put so many roadblocks in my way that I can no longer
deliver.

--Brett Glass

Re: Net Neutrality...

[Rubens Kuhl]

 The things that are making my life difficult at the moment include the
 following:

 * Government agencies attempting to impose requirements upon us and then
 denying us the resources we need to fulfill them;

 * Government agencies trying to dictate what users can buy rather than
 allowing them to choose;

 * Corporations exploiting market power or attempting to use the government
 so as to tilt the playing field in their favor; and

 * Corporations lying to consumers so as to get them to blame me for their
 own failings.


Do you see Connect America Fund, the successor to Universal Service Fund,
as a threat to US rural WISPs or as the possible solution for them ?


Rubens

Re: Net Neutrality...

[Brett Glass]

At 05:06 PM 7/15/2014, Rubens Kuhl wrote:


Do you see Connect America Fund, the successor to Universal Service Fund,
as a threat to US rural WISPs or as the possible solution for them ?


It's a major threat to rural WISPs and all competitive ISPs. Here's 
why. The FCC is demanding that ISPs become Eligible 
Telecommunications Carriers, or ETCs, before they can receive 
money from it. An ETC is a telephone company which is regulated 
under the mountain of regulations, requirements, and red tape of 
Title II of the Telecomm Act. It has to report to both state 
regulatory agencies AND the FCC. It's a classification that doesn't 
fit ISPs at all, but they would have to subject themselves to this 
heavy-handed regulation before they could get a dime from the fund.


The FCC just announced a rural broadband experiment in which it 
will fund ETCs, but not pure-play ISPs, to build out rural broadband; see


http://www.fcc.gov/document/rural-broadband-experiments-order

As part of this experiment, the FCC will pay telephone companies to 
overbuild us, even though the residents of the areas in question 
already have service. This is because, as far as the regulators are 
concerned, if they do not have their regulatory hooks in us, we 
don't exist and any service we provide does not count. The 
experiment also requires participants to tie up large amounts of 
money in escrow accounts so that they can obtain letters of 
credit guaranteeing performance.


All of this is, alas, the regulators' way of attempting to destroy 
those whom they cannot regulate.


IMHO, the USF is outmoded and should be disbanded.

--Brett Glass

Re: Net Neutrality...

[Fletcher Kittredge]

I have stayed out of much of this, but can't help myself.   Along with
everything else, you are seriously misinformed about the process of
becoming an ETC.   It is not onerous.   Please stop.   You are giving rural
ISPs a bad reputation.


On Tue, Jul 15, 2014 at 7:57 PM, Brett Glass na...@brettglass.com wrote:

 At 05:06 PM 7/15/2014, Rubens Kuhl wrote:

  Do you see Connect America Fund, the successor to Universal Service Fund,
 as a threat to US rural WISPs or as the possible solution for them ?


 It's a major threat to rural WISPs and all competitive ISPs. Here's why.
 The FCC is demanding that ISPs become Eligible Telecommunications
 Carriers, or ETCs, before they can receive money from it. An ETC is a
 telephone company which is regulated under the mountain of regulations,
 requirements, and red tape of Title II of the Telecomm Act. It has to
 report to both state regulatory agencies AND the FCC. It's a classification
 that doesn't fit ISPs at all, but they would have to subject themselves to
 this heavy-handed regulation before they could get a dime from the fund.

 The FCC just announced a rural broadband experiment in which it will
 fund ETCs, but not pure-play ISPs, to build out rural broadband; see

 http://www.fcc.gov/document/rural-broadband-experiments-order

 As part of this experiment, the FCC will pay telephone companies to
 overbuild us, even though the residents of the areas in question already
 have service. This is because, as far as the regulators are concerned, if
 they do not have their regulatory hooks in us, we don't exist and any
 service we provide does not count. The experiment also requires
 participants to tie up large amounts of money in escrow accounts so that
 they can obtain letters of credit guaranteeing performance.

 All of this is, alas, the regulators' way of attempting to destroy those
 whom they cannot regulate.

 IMHO, the USF is outmoded and should be disbanded.

 --Brett Glass






-- 
Fletcher Kittredge
GWI
8 Pomerleau Street
Biddeford, ME 04005-9457
207-602-1134

Re: Net Neutrality...

[Bob Evans]

I think your point needs to be explained. Because anything gnment is
riddled will large carrier benefiting. Look at the school discounts for
internet services...pretty much just for LECs.
Thank You
Bob Evans
CTO




 I have stayed out of much of this, but can't help myself.   Along with
 everything else, you are seriously misinformed about the process of
 becoming an ETC.   It is not onerous.   Please stop.   You are giving
 rural
 ISPs a bad reputation.


 On Tue, Jul 15, 2014 at 7:57 PM, Brett Glass na...@brettglass.com wrote:

 At 05:06 PM 7/15/2014, Rubens Kuhl wrote:

  Do you see Connect America Fund, the successor to Universal Service
 Fund,
 as a threat to US rural WISPs or as the possible solution for them ?


 It's a major threat to rural WISPs and all competitive ISPs. Here's why.
 The FCC is demanding that ISPs become Eligible Telecommunications
 Carriers, or ETCs, before they can receive money from it. An ETC is a
 telephone company which is regulated under the mountain of regulations,
 requirements, and red tape of Title II of the Telecomm Act. It has to
 report to both state regulatory agencies AND the FCC. It's a
 classification
 that doesn't fit ISPs at all, but they would have to subject themselves
 to
 this heavy-handed regulation before they could get a dime from the fund.

 The FCC just announced a rural broadband experiment in which it will
 fund ETCs, but not pure-play ISPs, to build out rural broadband; see

 http://www.fcc.gov/document/rural-broadband-experiments-order

 As part of this experiment, the FCC will pay telephone companies to
 overbuild us, even though the residents of the areas in question already
 have service. This is because, as far as the regulators are concerned,
 if
 they do not have their regulatory hooks in us, we don't exist and any
 service we provide does not count. The experiment also requires
 participants to tie up large amounts of money in escrow accounts so that
 they can obtain letters of credit guaranteeing performance.

 All of this is, alas, the regulators' way of attempting to destroy those
 whom they cannot regulate.

 IMHO, the USF is outmoded and should be disbanded.

 --Brett Glass






 --
 Fletcher Kittredge
 GWI
 8 Pomerleau Street
 Biddeford, ME 04005-9457
 207-602-1134

Re: Net Neutrality...

[Brett Glass]

I'll just say that we've consulted legal counsel about what it would take
to become an ETC, and it's simply too burdensome for us to consider. We'd
need to become a telephone company, at the very time when old fashioned
telephone service is becoming a thing of the past. (We enthusiastically
support over the top VoIP so that we can help our customers get inexpensive
telephone service without ourselves having to be a telephone company.)

--Brett Glass

At 07:53 PM 7/15/2014, Bob Evans wrote:


I think your point needs to be explained. Because anything gnment is
riddled will large carrier benefiting. Look at the school discounts for
internet services...pretty much just for LECs.
Thank You
Bob Evans
CTO

Re: Net Neutrality...

[Keefe John]

Any ISP can tap into Erate funding.  We are a WISP and lots of our 
school customers get Erate funding/discounts.



On 7/15/2014 8:53 PM, Bob Evans wrote:

I think your point needs to be explained. Because anything gnment is
riddled will large carrier benefiting. Look at the school discounts for
internet services...pretty much just for LECs.
Thank You
Bob Evans
CTO





I have stayed out of much of this, but can't help myself.   Along with
everything else, you are seriously misinformed about the process of
becoming an ETC.   It is not onerous.   Please stop.   You are giving
rural
ISPs a bad reputation.


On Tue, Jul 15, 2014 at 7:57 PM, Brett Glass na...@brettglass.com wrote:


At 05:06 PM 7/15/2014, Rubens Kuhl wrote:

  Do you see Connect America Fund, the successor to Universal Service
Fund,

as a threat to US rural WISPs or as the possible solution for them ?


It's a major threat to rural WISPs and all competitive ISPs. Here's why.
The FCC is demanding that ISPs become Eligible Telecommunications
Carriers, or ETCs, before they can receive money from it. An ETC is a
telephone company which is regulated under the mountain of regulations,
requirements, and red tape of Title II of the Telecomm Act. It has to
report to both state regulatory agencies AND the FCC. It's a
classification
that doesn't fit ISPs at all, but they would have to subject themselves
to
this heavy-handed regulation before they could get a dime from the fund.

The FCC just announced a rural broadband experiment in which it will
fund ETCs, but not pure-play ISPs, to build out rural broadband; see

http://www.fcc.gov/document/rural-broadband-experiments-order

As part of this experiment, the FCC will pay telephone companies to
overbuild us, even though the residents of the areas in question already
have service. This is because, as far as the regulators are concerned,
if
they do not have their regulatory hooks in us, we don't exist and any
service we provide does not count. The experiment also requires
participants to tie up large amounts of money in escrow accounts so that
they can obtain letters of credit guaranteeing performance.

All of this is, alas, the regulators' way of attempting to destroy those
whom they cannot regulate.

IMHO, the USF is outmoded and should be disbanded.

--Brett Glass






--
Fletcher Kittredge
GWI
8 Pomerleau Street
Biddeford, ME 04005-9457
207-602-1134

Re: Net Neutrality...

[Jay Ashworth]

- Original Message -
 From: Brett Glass na...@brettglass.com

 Estimates of the maximum bandwidths of all the human senses, combined,
 range between the capacity of a T1 line (at the low end) and
 about 4 Mbps (at the high end). A human being simply is not wired to
 accept more input. (Yes, machines could digest more... which means that
 additional bandwidth to and from the home might be useful for the purpose
 of spying on us.) What does this imply about the FCC's proposal to
 redefine broadband as a symmetrical 10 Mbps?

That they understand that more than one person lives in a house.

Spying on us?

plonk

Cheers,
-- jr 'I retract the apology' a
-- 
Jay R. Ashworth  Baylink   j...@baylink.com
Designer The Things I Think   RFC 2100
Ashworth  Associates   http://www.bcp38.info  2000 Land Rover DII
St Petersburg FL USA  BCP38: Ask For It By Name!   +1 727 647 1274

Re: Net Neutrality...

[Bob Evans]

Oh I agree Brett. My point was for flecher. We lost business once the
government school discount happened. Its an example to what you speak
ofall the time red tape overhead designed to give to LEcs business.
And one of my companies is a CLEC.
Thank You
Bob Evans
CTO




 I'll just say that we've consulted legal counsel about what it would take
 to become an ETC, and it's simply too burdensome for us to consider. We'd
 need to become a telephone company, at the very time when old fashioned
 telephone service is becoming a thing of the past. (We enthusiastically
 support over the top VoIP so that we can help our customers get
 inexpensive
 telephone service without ourselves having to be a telephone company.)

 --Brett Glass

 At 07:53 PM 7/15/2014, Bob Evans wrote:

I think your point needs to be explained. Because anything gnment is
riddled will large carrier benefiting. Look at the school discounts for
internet services...pretty much just for LECs.
Thank You
Bob Evans
CTO

RE: Net Neutrality...

[Naslund, Steve]

Net Neutrality is really something that has me worried.  I know there have to 
be some ground rules, but I believe that government regulation of internet 
interconnection and peering is a sure way to stagnate things.  I have been in 
the business a long time and remember how peering kind of evolved based on 
mutual benefit or some concept of doing the right thing.  For example, at 
InterAccess Chicago, our peer policy in the late 90s was pretty much the 
following.

1.  Non-profits or educational institutions could private peer with us as long 
as they bore the cost of the circuit.  (this kind of connection was more 
beneficial to them than us).
2.  Comparable sized carriers got to peer with us, with each of us picking up 
our portions of equipment and circuit cost since it was mutually beneficial.
3.  We would peer with anyone at any NAP we had a mutual appearance in.
4.  Larger network usual would not peer with smaller networks without some sort 
of compensation.

Seemed to work pretty fair at the time and we managed the backbone by watching 
customer traffic.  If things got congested, you paid for or peered with whoever 
you needed to in order to get acceptable performance for our customers.  The 
big guys did get to call the shots and made you pay but then again they 
provided the largest fastest connections so I guess it was fair enough.  It may 
have been the wild west in some ways but at that time everyone needed to get 
along because if your peering policies were unfair you would get universally 
shunned and then you would have real problems.  I hate that the network 
operators now feel the need to ask the government to step in.  When you ask for 
that don't be surprised that the government creates a cumbersome mess and 
disadvantages you in another way.  The problem is that the gov does not react 
at internet speed.

I remember the first unbundling agreements and trust me when I say that 
ourselves and the ILEC both found the gov't rules to be nearly unworkable.  We 
eventually started with the telecom act framework that forced them to the table 
where they finally sat down with us and said Ok, Ok, what do you really need 
here and we banged out a pretty good interconnection agreement that was 
workable for both of us.  Well, about as workable as it gets with an ILEC.

I think what will really drive everything is the market forces.  You either 
provide what your end user wants or you go out of business.  The customer could 
care less who pays for what pieces or what is fair because in the end, their 
service provider is the only one they will punish.  If Netflix becomes 
universally hard to connect to, then they will lose the customers.  The 
customer does not really care why your connectivity sucks, they just know that 
it does and that if someone better comes along, they are gone.

Maybe something better would be some sort of industry group that you could 
become a member of and that group could resolve peering disputes through some 
kind of arbitration process.   The benefit of being a member could be something 
like the opportunity to peer with any other member on demand with some sort of 
cost splitting arrangement.  They would need something like a group wide 
interconnection agreement.  The responsibility would then be the industry and 
not some appointed FCC working group that spends all of their time writing 
convoluted gibberish.  If the group was big enough and powerful enough, the 
incentive to get on board would be huge.

Steven Naslund
Chicago IL

Re: Net Neutrality...

[Miles Fidelman]

Steve, the key piece you're missing here is that the major broadband 
providers are both

- near-monopolies in their access areas
- content providers

Not a situation where market forces can work all that well.

Miles Fidelman

Naslund, Steve wrote:

Net Neutrality is really something that has me worried.  I know there have to be some 
ground rules, but I believe that government regulation of internet interconnection and 
peering is a sure way to stagnate things.  I have been in the business a long time and 
remember how peering kind of evolved based on mutual benefit or some concept of 
doing the right thing.  For example, at InterAccess Chicago, our peer policy 
in the late 90s was pretty much the following.

1.  Non-profits or educational institutions could private peer with us as long 
as they bore the cost of the circuit.  (this kind of connection was more 
beneficial to them than us).
2.  Comparable sized carriers got to peer with us, with each of us picking up 
our portions of equipment and circuit cost since it was mutually beneficial.
3.  We would peer with anyone at any NAP we had a mutual appearance in.
4.  Larger network usual would not peer with smaller networks without some sort 
of compensation.

Seemed to work pretty fair at the time and we managed the backbone by watching 
customer traffic.  If things got congested, you paid for or peered with whoever 
you needed to in order to get acceptable performance for our customers.  The 
big guys did get to call the shots and made you pay but then again they 
provided the largest fastest connections so I guess it was fair enough.  It may 
have been the wild west in some ways but at that time everyone needed to get 
along because if your peering policies were unfair you would get universally 
shunned and then you would have real problems.  I hate that the network 
operators now feel the need to ask the government to step in.  When you ask for 
that don't be surprised that the government creates a cumbersome mess and 
disadvantages you in another way.  The problem is that the gov does not react 
at internet speed.

I remember the first unbundling agreements and trust me when I say that ourselves and the 
ILEC both found the gov't rules to be nearly unworkable.  We eventually started with the 
telecom act framework that forced them to the table where they finally sat down with us 
and said Ok, Ok, what do you really need here and we banged out a pretty good 
interconnection agreement that was workable for both of us.  Well, about as workable as 
it gets with an ILEC.

I think what will really drive everything is the market forces.  You either 
provide what your end user wants or you go out of business.  The customer could 
care less who pays for what pieces or what is fair because in the end, their 
service provider is the only one they will punish.  If Netflix becomes 
universally hard to connect to, then they will lose the customers.  The 
customer does not really care why your connectivity sucks, they just know that 
it does and that if someone better comes along, they are gone.

Maybe something better would be some sort of industry group that you could 
become a member of and that group could resolve peering disputes through some 
kind of arbitration process.   The benefit of being a member could be something 
like the opportunity to peer with any other member on demand with some sort of 
cost splitting arrangement.  They would need something like a group wide 
interconnection agreement.  The responsibility would then be the industry and 
not some appointed FCC working group that spends all of their time writing 
convoluted gibberish.  If the group was big enough and powerful enough, the 
incentive to get on board would be huge.

Steven Naslund
Chicago IL





--
In theory, there is no difference between theory and practice.
In practice, there is.    Yogi Berra

Re: Net Neutrality...

[Aaron C. de Bruyn]

On Mon, Jul 14, 2014 at 3:24 PM, Naslund, Steve snasl...@medline.com
wrote:

 I think what will really drive everything is the market forces.  You
 either provide what your end user wants or you go out of business.


There's the problem.  In my neck of the woods, there is one and only one
provider.  They have a guaranteed monopoly for the next few decades.  They
got a huge grant to put in FTTH from the government and they still have
pricing from the last decade.

An 8/1 connection is $120/mo and require you to get dialtone (they say it's
FCC mandated) to the tune of an additional $20/mo (that's with no long
distance and every possible feature stripped).  (Side-note: when the power
fails during the winter, they turn off all internet access after 5 minutes
so they can save battery power for the phones--which travel the exact same
fiber path as the interntet).

I'm not a huge fan of Comcast's recent actions, but if they rolled into the
area with the same offer they have in town (100/25 for ~$75/mo), I would
switch faster than you could spell monopoly.

There's plenty of fiber lying within 1/4 mile from my house (runs between
Seattle and Portland), but none of the companies are interested in being a
local ISP, or leasing to a non-business, and I couldn't afford to start my
own, let alone trenching my own fiber to other residents who are also fed
up.

It doesn't matter to me what the big players do because as a consumer, I
still don't have a choice.  So while I find my local provider's practices
utterly despicable, I can't exactly speak with my wallet unless I quit
being an IT guy, cancel my internet, and start raising goats or something.

-A

Re: net neutrality and peering wars continue

[Randy Bush]

 i have not been able to find it easily, but some years back rexford
 and others published on a crypto method for peers to negotiate
 traffic adjustment between multiple peering points with minimal
 disclosure.  it was a cool paper.
 I don't know Jen's work on this off the top of my head, but Ratul
 Mahajan had some papers on this too (for his dissertation). One is
 called Wiser.

good stuff.  but i thought the paper i had in mind was normal bgp and
the exchanges were negotiations of prefix and med policies at mutual
peering points using crypto to cloak one's internals.  but i could
easily be wrong.

randy

Re: net neutrality and peering wars continue

[Matthew Petach]

On Thu, Jun 20, 2013 at 2:29 PM, valdis.kletni...@vt.edu wrote:

 On Thu, 20 Jun 2013 22:39:56 +0200, Niels Bakker said:

  You're mistaken if you think that CDNs have equal number of packets
  going in and out.

 And even if the number of packets match, there's the whole 1500 bytes
 of data, 64 bytes of ACK thing to factor in...



That's easily solved by padding the ACK to 1500 bytes as well.

Matt

Re: net neutrality and peering wars continue

[Neil Harris]

On 22/06/13 13:08, Matthew Petach wrote:

On Thu, Jun 20, 2013 at 2:29 PM, valdis.kletni...@vt.edu wrote:


On Thu, 20 Jun 2013 22:39:56 +0200, Niels Bakker said:


You're mistaken if you think that CDNs have equal number of packets
going in and out.

And even if the number of packets match, there's the whole 1500 bytes
of data, 64 bytes of ACK thing to factor in...



That's easily solved by padding the ACK to 1500 bytes as well.

Matt



Or indeed by the media player sending large amounts of traffic back to 
the CDN via auxiliary HTTP POST requests?


Neil

Re: net neutrality and peering wars continue

[Owen DeLong]

 
 That's easily solved by padding the ACK to 1500 bytes as well.
 
 Matt
 
 
 Or indeed by the media player sending large amounts of traffic back to the 
 CDN via auxiliary HTTP POST requests?
 
 Neil
 
 
 

That would assume that the client has symmetrical upstream bandwidth over which 
to send such datagrams. At least in the US, that is the exception, not the rule.

Owen

Re: net neutrality and peering wars continue

[Christopher Morrow]

On Sat, Jun 22, 2013 at 9:19 AM, Neil Harris n...@tonal.clara.co.uk wrote:
 On 22/06/13 13:08, Matthew Petach wrote:
 That's easily solved by padding the ACK to 1500 bytes as well.

 Matt


 Or indeed by the media player sending large amounts of traffic back to the
 CDN via auxiliary HTTP POST requests?

ah... botnet... how I love thee?

Re: net neutrality and peering wars continue

[jim deleskie]

Botnets to help with peering ratio's could be a new business model? :)


On Sat, Jun 22, 2013 at 1:00 PM, Christopher Morrow morrowc.li...@gmail.com
 wrote:

 On Sat, Jun 22, 2013 at 9:19 AM, Neil Harris n...@tonal.clara.co.uk
 wrote:
  On 22/06/13 13:08, Matthew Petach wrote:
  That's easily solved by padding the ACK to 1500 bytes as well.
 
  Matt
 
 
  Or indeed by the media player sending large amounts of traffic back to
 the
  CDN via auxiliary HTTP POST requests?

 ah... botnet... how I love thee?

Re: net neutrality and peering wars continue

[Owen DeLong]

When you convert your botnet to a business model, you have to change the name. 
If it's a business, the politically correct term is Elastic Cloud Computing

Owen

On Jun 22, 2013, at 6:19 PM, jim deleskie deles...@gmail.com wrote:

 Botnets to help with peering ratio's could be a new business model? :)
 
 
 On Sat, Jun 22, 2013 at 1:00 PM, Christopher Morrow morrowc.li...@gmail.com
 wrote:
 
 On Sat, Jun 22, 2013 at 9:19 AM, Neil Harris n...@tonal.clara.co.uk
 wrote:
 On 22/06/13 13:08, Matthew Petach wrote:
 That's easily solved by padding the ACK to 1500 bytes as well.
 
 Matt
 
 
 Or indeed by the media player sending large amounts of traffic back to
 the
 CDN via auxiliary HTTP POST requests?
 
 ah... botnet... how I love thee?
 
 

Re: net neutrality and peering wars continue

[William Herrin]

On Thu, Jun 20, 2013 at 6:47 PM, Robert M. Enger na...@enger.us wrote:
 Perhaps last-mile operators should
 A) advertise each of their metropolitan regional systems as a separate AS
 B) establish an interconnection point in each region where they will accept
 traffic destined for their in-region customers without charging any fee

What would be the point of (A)? They can just set a BGP community
based on where a route originates and then match by BGP community for
the sufficiently-local routes when they peer.

They don't do B because the complaint about you're abusing my long
haul bandwidth is basically a lie. They want to get paid twice for
each byte and if they think they can then they won't do settlement
free peering with you. Period.



On Thu, Jun 20, 2013 at 9:10 PM, Aaron C. de Bruyn aa...@heyaaron.com wrote:
 Maybe someone could enlighten my ignorance on this issue.
 Why is there a variable charge for bandwidth anyways?

Some equipment is used to connect to you. A cable. A port on a card in
a router. Whatever. Also, that router can only have so many ports, so
when you connect to it a fraction of that router's equipment,
maintenance and management cost is attributable to your specific
connection.

That's the monthly port charge.

Your packets are then multiplex with lots of other folks' packets an a
variety of cables and through a variety of routers as they travel
between you and the machines you're talking to. That infrastructure
has a cost $X. It's used by all of their customers (packets cross it)
at a total of Y gbps.

Your consumption divided by Y is your fraction of that usage. That
fraction times $X is the service provider's variable cost of moving
your packets. Variable cost, variable charge.




On Thu, Jun 20, 2013 at 11:42 PM, Jon Lewis jle...@lewis.org wrote:
 At this rate, if they do produce a PFC that takes the 6500 to several
 million routes, it's probably going to be too late for those to be available
 in any real quantity on the secondary market.  Maybe that's the plan.

Maybe?

Regards,
Bill Herrin




-- 
William D. Herrin  her...@dirtside.com  b...@herrin.us
3005 Crane Dr. .. Web: http://bill.herrin.us/
Falls Church, VA 22042-3004

Re: net neutrality and peering wars continue

[Neil Harris]

On 22/06/13 16:34, Owen DeLong wrote:

That's easily solved by padding the ACK to 1500 bytes as well.

Matt


Or indeed by the media player sending large amounts of traffic back to the CDN 
via auxiliary HTTP POST requests?

Neil




That would assume that the client has symmetrical upstream bandwidth over which 
to send such datagrams. At least in the US, that is the exception, not the rule.

Owen




Hi Owen,

You only need to match the video stream bandwidth, not the full download 
speed of the link.


Given that current multicore CPUs are now fast enough to decode HEVC in 
software, and with HEVC being roughly twice as efficient as H.264, that 
means you should be able to do quite decent full HDTV quality video with 
an average bandwdith of about 5 Mbps, given sufficient buffering to 
smooth out the traffic. Less, if you're willing to compromise on picture 
quality a bit, and go for, say, 720p.


So, given an HEVC-capable decoder, this strategy should work for any 
connection with an upstream speed of better than about 4 to 5 Mbps, 
which is becoming more and more common on cable Internet service, as 
DOCSIS 3.0 is rolled out and faster links become more common,


Neil

Re: net neutrality and peering wars continue

[Matthew Petach]

On Sat, Jun 22, 2013 at 12:06 PM, Neil Harris n...@tonal.clara.co.ukwrote:

 On 22/06/13 16:34, Owen DeLong wrote:

 That's easily solved by padding the ACK to 1500 bytes as well.

 Matt

  Or indeed by the media player sending large amounts of traffic back to
 the CDN via auxiliary HTTP POST requests?

 Neil

  That would assume that the client has symmetrical upstream bandwidth
 over which to send such datagrams. At least in the US, that is the
 exception, not the rule.

 Owen


 Hi Owen,

 You only need to match the video stream bandwidth, not the full download
 speed of the link.


Nah.  For peering purposes, you only need to match half the video
stream bandwidth to be within compliance.   Generating 2.5M back
upstream in response to a 5M video stream would be more than
sufficient to keep the ratio-watchers happy.

Matt

Re: net neutrality and peering wars continue

[Bill Woodcock]

On Jun 20, 2013, at 1:39 PM, Niels Bakker niels=na...@bakker.net wrote:
 You're mistaken if you think that CDNs have equal number of packets going in 
 and out.

I'm aware that neither the quantity nor the size of packets in each direction 
are equal.  I'm just hard-pressed to think of a reason why this matters, and so 
tend to hand-wave about it a bit…  To a rough approximation, flows are 
balanced.  Someone requests something, and an answer follows.  Requests tend to 
be small, but if someone requests something large, a large answer follows.  
Conversely, people also send things, which are followed by small 
acknowledgements.  Again, this only matters if you place a great deal of 
importance both on the notion that size equals fairness, and that fairness is 
more important than efficiency.  I would argue that neither are true.  I'm far 
more interested in seeing the cost of Internet service go down, than seeing two 
providers saddled with equally high costs in the name of fairness.  And costs 
go down most quickly when each provider retains the full incentivization of its 
own ability to minimize costs.  Not when they have to worry about fairness in 
an arbitrary metric, relative to other providers.

The only occasion I can think of when traffic flows of symmetric volume have an 
economic benefit are when a third party is imposing excess rent on circuits, 
such that the cost of upgrading capacity is higher than the cost of traffic 
engineering flows to fill reverse paths.  And that's hardly the sort of mental 
pretzels I want carriers to be having to worry about, instead of moving bits to 
customers.

 I think the point is here that networks are nudging these decisions by making 
 certain services suck more than others by way of preferential network access.

I agree completely that that's the problem.  But it didn't appear to be what 
Benson was talking about.

-Bill

Re: net neutrality and peering wars continue

[Benson Schliesser]

On 2013-06-21 4:54 AM, Bill Woodcock wrote:

Again, this only matters if you place a great deal of importance both on the 
notion that size equals fairness, and that fairness is more important than 
efficiency.
...

I think the point is here that networks are nudging these decisions by making 
certain services suck more than others by way of preferential network access.

I agree completely that that's the problem.  But it didn't appear to be what 
Benson was talking about.



It's clear to me that you don't understand what I've said. But whether 
you're being obtuse or simply disagreeing, there is little value in 
repeating my specific points. Instead, in hope of encouraging useful 
discussion, I'll try to step back and describe things more broadly.


The behaviors of networks are driven (in almost all cases) by the needs 
of business. In other words, decisions about peering, performance, etc, 
are all driven by a PL sheet.


So, clearly, these networks will try to minimize their costs (whether 
fair or not). And any imbalance between peers' cost burdens is an easy 
target. If one peer's routing behavior forces the other to carry more 
traffic a farther distance, then there is likely to be a dispute at some 
point - contrary to some hand-wave comments, carrying multiple gigs of 
traffic across the continent does have a meaningful cost, and pushing 
that cost onto somebody else is good for business.


This is where so-called bit mile peering agreements can help - 
neutralize arguments about balance in order to focus on what matters. Of 
course there is still the P side of a PL sheet to consider, and 
networks will surely attempt to capture some of the success of their 
peers' business models. But take away the legitimate fairness excuses 
and we can see the real issue in these cases.


Not that we have built the best (standard, interoperable, cheap) tools 
to make bit-mile peering possible... But that's a good conversation to have.


Cheers,
-Benson

Re: net neutrality and peering wars continue

[Owen DeLong]

On Jun 21, 2013, at 4:20 PM, Benson Schliesser bens...@queuefull.net wrote:

 On 2013-06-21 4:54 AM, Bill Woodcock wrote:
 Again, this only matters if you place a great deal of importance both on the 
 notion that size equals fairness, and that fairness is more important than 
 efficiency.
 ...
 I think the point is here that networks are nudging these decisions by 
 making certain services suck more than others by way of preferential 
 network access.
 I agree completely that that's the problem.  But it didn't appear to be what 
 Benson was talking about.
 
 
 It's clear to me that you don't understand what I've said. But whether you're 
 being obtuse or simply disagreeing, there is little value in repeating my 
 specific points. Instead, in hope of encouraging useful discussion, I'll try 
 to step back and describe things more broadly.
 
 The behaviors of networks are driven (in almost all cases) by the needs of 
 business. In other words, decisions about peering, performance, etc, are all 
 driven by a PL sheet.

This isn't exactly true and it turns out that the subtle difference from this 
fact is very important.

They are driven not by a PL sheet, but by executive's opinions of what will 
improve the PL sheet.

There is ample evidence that promiscuous peering can actually reduce costs 
across the board and increase revenues, image, good will, performance, and even 
transit purchases.

There is also evidence that turning off peers tends to hamper revenue growth, 
degrade performance, create a negative image for the organization, reduce good 
will, etc.

One need look no further than the history of SPRINT for a graphic example. In 
the early 2000's when SPRINT started depeering, they were darn near the 
epicenter of internet transit. Today, they're yet another also ran among major 
telco-based ISPs.

Sure, their peering policy alone is likely not the only cause of this decline 
in stature, but it certainly contributed.

 So, clearly, these networks will try to minimize their costs (whether fair 
 or not). And any imbalance between peers' cost burdens is an easy target. If 
 one peer's routing behavior forces the other to carry more traffic a farther 
 distance, then there is likely to be a dispute at some point - contrary to 
 some hand-wave comments, carrying multiple gigs of traffic across the 
 continent does have a meaningful cost, and pushing that cost onto somebody 
 else is good for business.

Reasonable automation means that it costs nearly nothing to add peers at public 
exchange points once you are present at that exchange point. The problem with 
looking only at the cost of moving the bits around in this equation is that it 
ignores where the value proposition for delivering those bits lies.

In reality, if an eyeball ISP doesn't maintain sufficient peering relationships 
to deliver the traffic the eyeballs are requesting, the eyeballs will become 
displeased with said ISP. In many cases, this is less relevant than it should 
be because the eyeball network is either a true monopoly, an effective monopoly 
(30/10Mbps cable vs. 1.5Mbps/384k DSL means that cable is an effective monopoly 
for all practical purposes), or a duopoly where both choices are nearly equally 
poor.

In markets served by multiple high speed providers, you tend to find that 
consumers gravitate towards the ones that don't engage in peering wars to the 
point that they degrade service to those customers.

On the other hand, if a content provider does not maintain sufficient capacity 
to reach the eyeball networks in a way that the eyeball networks are willing to 
accept said traffic, the content provider is at risk of losing subscribers. 
Since content tends to have many competitors capable of delivering an 
equivalent service, content providers have less leverage in any such dispute. 
Their customers don't want to hear You're on Comcast and they don't like us 
as an excuse when the service doesn't work. They'll go find a provider Comcast 
likes.

The bottom line is that these ridiculous disputes are expensive to both sides 
and degrade service for their mutual customers. I make a point of opening 
tickets every time this becomes a performance issue for me. If more consumers 
did, then perhaps that cost would help drive better decisions from the 
executives at these providers.

The other problem that plays into this is, as someone noted, many of these 
providers are in the internet business as a secondary market for revenue added 
to their primary business. They'd rather not see their primary business 
revenues driven onto the internet and off of their traditional services. As 
such, there is a perceived PL gain to the other services by degrading the 
performance of competing services delivered over the internet. Attempting to 
use this fact to leverage (extort) money from the content providers to make up 
those revenues also makes for an easy target in the board room.

 This is where so-called bit mile peering agreements 

Re: net neutrality and peering wars continue

[Bill Woodcock]

On Jun 19, 2013, at 7:21 PM, Benson Schliesser bens...@queuefull.net wrote:
 The sending peer (or their customer) has more control over cost. 

I'll assume that, by sending peer, you mean the content network.  If so, I 
disagree.  The content network has no control whatsoever over the location of 
the eyeball customer.  The eyeball customer has sole control over his or her 
own location, while the content network has sole control over the location from 
which they reply to requests.

Therefore, control is shared between the two sides.  And both are incentivized 
to minimize costs.  If both minimize their costs, overall costs are minimized.  
That's why this system works.

-Bill

Re: net neutrality and peering wars continue

[Martin Barry]

On 20 June 2013 13:07, Bill Woodcock wo...@pch.net wrote:


 On Jun 19, 2013, at 7:21 PM, Benson Schliesser bens...@queuefull.net
 wrote:
  The sending peer (or their customer) has more control over cost.

 I'll assume that, by sending peer, you mean the content network.  If so,
 I disagree.  The content network has no control whatsoever over the
 location of the eyeball customer.  The eyeball customer has sole control
 over his or her own location, while the content network has sole control
 over the location from which they reply to requests.

 Therefore, control is shared between the two sides.  And both are
 incentivized to minimize costs.  If both minimize their costs, overall
 costs are minimized.  That's why this system works.


I think his point was that the receiving side can massage their BGP
announcements all they like but the sending network has more instantaneous
control over how the traffic will flow. This is before analysis,
communication, application of policies / contractual arrangements,
de-peering etc.etc. kick in.

cheers
Marty

Re: net neutrality and peering wars continue

[Benson Schliesser]

On Jun 20, 2013, at 8:09, Martin Barry ma...@supine.com wrote:

 On 20 June 2013 13:07, Bill Woodcock wo...@pch.net wrote:

 On Jun 19, 2013, at 7:21 PM, Benson Schliesser bens...@queuefull.net
 wrote:
 The sending peer (or their customer) has more control over cost.

 I'll assume that, by sending peer, you mean the content network.  If so,
 I disagree.  The content network has no control whatsoever over the
 location of the eyeball customer.
 ...
 I think his point was that the receiving side can massage their BGP
 announcements all they like but the sending network has more instantaneous
 control over how the traffic will flow. This is before analysis,
 communication, application of policies / contractual arrangements,
 de-peering etc.etc. kick in.

Right. By sending peer I meant the network transmitting a packet,
unidirectional flow, or other aggregate of traffic into another
network. I'm not assuming anything about whether they are offering
content or something else - I think it would be better to talk about
peering fairness at the network layer, rather than the business /
service layer.

Cheers,
-Benson

Re: net neutrality and peering wars continue

[Benson Schliesser]

On Jun 19, 2013, at 23:41, Siegel, David david.sie...@level3.com wrote:

 Well, with net flow Analytics, it's not really the case that we don't have a 
 way of evaluating the relative burdens.  Every major net flow Analytics 
 vendor is implementing some type of distance measurement capability so that 
 each party can calculate not only how much traffic they carry for each peer, 
 but how far.

Admittedly, it's been a few years since I looked at such tools... So
please help me understand: does the tool evaluate distance (and
therefore burden) as it extends into the peer's network, or just into
the local network? And in either case, is this kind of data normalized
and shared between peers? It seems like there could be a mechanism
here to evaluate fairness of burdens, but I'm skeptical that these
tools are used in such a way. I'd be glad to be incorrect. ;)

Cheers,
-Benson

RE: net neutrality and peering wars continue

[Siegel, David]

The tools cannot estimate burden into the peers network very well, particularly 
when longest-exit routing is implement to balance the mileage burden, so each 
party shares their information with each other and compares data in order to 
make decisions.

It's not common, but there are a handful of peers that share this information 
with each other.

Dave


-Original Message-
From: Benson Schliesser [mailto:bens...@queuefull.net] 
Sent: Thursday, June 20, 2013 6:45 AM
To: Siegel, David
Cc: North American Network Operators' Group
Subject: Re: net neutrality and peering wars continue

On Jun 19, 2013, at 23:41, Siegel, David david.sie...@level3.com wrote:

 Well, with net flow Analytics, it's not really the case that we don't have a 
 way of evaluating the relative burdens.  Every major net flow Analytics 
 vendor is implementing some type of distance measurement capability so that 
 each party can calculate not only how much traffic they carry for each peer, 
 but how far.

Admittedly, it's been a few years since I looked at such tools... So please 
help me understand: does the tool evaluate distance (and therefore burden) as 
it extends into the peer's network, or just into the local network? And in 
either case, is this kind of data normalized and shared between peers? It seems 
like there could be a mechanism here to evaluate fairness of burdens, but I'm 
skeptical that these tools are used in such a way. I'd be glad to be incorrect. 
;)

Cheers,
-Benson

Re: net neutrality and peering wars continue

[Bill Woodcock]

On Jun 20, 2013, at 5:37 AM, Benson Schliesser bens...@queuefull.net wrote:
 Right. By sending peer I meant the network transmitting a packet,
 unidirectional flow, or other aggregate of traffic into another
 network. I'm not assuming anything about whether they are offering
 content or something else - I think it would be better to talk about
 peering fairness at the network layer, rather than the business /
 service layer.

In that case, it's essentially never an issue, since essentially every packet 
in one direction is balanced by a packet in the other direction, so rotational 
symmetry takes care of the fairness.  I think you may be taking your argument 
too far, though, since by this logic, the sending and receiving networks also 
have control over what they choose to transit and receive, and I think that 
discounts too far the reality that it is in fact the _customers_ that are 
making all of these decisions, and the networks are, in the aggregate, 
inflexible in their need to service customers.  What a customer will pay to do, 
a service provider will take money to perform.  It's not really service 
providers (in aggregate) making these decisions.  It's customers.

-Bill

Re: net neutrality and peering wars continue

[Randy Bush]

 The tools cannot estimate burden into the peers network very well,
 particularly when longest-exit routing is implement to balance the
 mileage burden, so each party shares their information with each other
 and compares data in order to make decisions.
 
 It's not common, but there are a handful of peers that share this
 information with each other.

i have not been able to find it easily, but some years back rexford and
others published on a crypto method for peers to negotiate traffic
adjustment between multiple peering points with minimal disclosure.  it
was a cool paper.

randy

Re: net neutrality and peering wars continue

[Niels Bakker]

* wo...@pch.net (Bill Woodcock) [Thu 20 Jun 2013, 16:59 CEST]:

On Jun 20, 2013, at 5:37 AM, Benson Schliesser bens...@queuefull.net wrote:


Right. By sending peer I meant the network transmitting a 
packet, unidirectional flow, or other aggregate of traffic into 
another network. I'm not assuming anything about whether they are 
offering content or something else - I think it would be better 
to talk about peering fairness at the network layer, rather than 
the business / service layer.
In that case, it's essentially never an issue, since essentially 
every packet in one direction is balanced by a packet in the other 
direction, so rotational symmetry takes care of the fairness.


You're mistaken if you think that CDNs have equal number of packets 
going in and out.



I think you may be taking your argument too far, though, since by 
this logic, the sending and receiving networks also have control 
over what they choose to transit and receive, and I think that 
discounts too far the reality that it is in fact the _customers_ 
that are making all of these decisions, and the networks are, in the 
aggregate, inflexible in their need to service customers.  What a 
customer will pay to do, a service provider will take money to 
perform.  It's not really service providers (in aggregate) making 
these decisions.  It's customers.


I think the point is here that networks are nudging these decisions by 
making certain services suck more than others by way of preferential 
network access.



-- Niels.