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"network operators
provide free and non-discriminatory transport on their
networks"
This is the
key phrase. This basically says that every corparate LAN, must allow any
consumer to steal access from that corporation's LAN, and open up their LAN to
the security threats by giving access to the Consumers. It means that
Business owners can't control what content an employee views, while they are
supposed to be working.
The key is the definition of "Network Operator" and
"broadband networks". By the definition of "Broadband" most every
corporate or even home network is technically broadband, doing symetrical data
throughput above 200K speed.
Whats most important is the the major conduit and
pipes that interconnect the "Internet" are not allowed to block traffic. The
rules below should apply. Could you imagine what would happen if Verizon
decided to block VOIP after they purchased MCI?
However, we have got to draw the line and not get
carried away, by over burdening the world by encompasing every person that owns
and operates a private network to follow the same rules of the "Internet".
At what point is a network considered the Internet versus private network.
We need to be very careful how that is defined. The secret lies in the
definiton of the key terms involved, not the rules them selves. Its easy
to determine what rules are fair for consumers, the hard part is defining who
should be ruled by those laws.
>4. Consumers are entitled to competition among network
providers, application and service providers, and content
providers. Some other issues related to this. What are we
saying by saying consumers are entitled to competition? Are we saying that
if Comcast and Verizon get to the buidling first, their is infact competition,
and to bad for the wireless provider when the landlord does not allow them on
the roof. What we really need to be saying is consumers should have their
choice of network provider or network technology. If a consumer wants
wireless, they should have the right to chose wireless. Quote from
this month Business Wireless page 1 " I wanted wireless but cable got their
first". And people always have the choice for a T1 if they have cooper
phones. Thats still competition. Or we should be saying that all
technologies should have the same non-discrimination access to consumers, so the
consumers have the option for choice. How can a wireless carrier that pays
a mandatory 25% revenue share out to a landlord able to compete against Verizon
that is allowed easement-fee-free access?
>3. Consumers are entitled to connect their choice of legal
devices that do not harm the network; and
Also a problem. What about devices that potential
could conflict. Should it be required to wait for a conflict to restrict it? How
could that ever be managed on a wide scale with the thousand of vendors.
"do not harm the network", how do you know if it will harm? The only safe way is
to pre-test the device, and if the device tests not to harm then it is OK.
We have a legal obligation to guarantee performance of our network for our
subscribers, I can't wait for a disaster to define what will and won't harm a
network. The only way to control this is to define upfront which devices
you've approved for use on your network. I'd argue that text needs to be added
that states, Consumer has choice of device to install on network, after first
submitting device to network operator for their testing and approval of
compatibilty ofthe device on their network. What this says is if you let
one person on the net with a LinksysG router, you then need to allow another,
which is OK, but if you let nobody on the network with a wireless-g router, than
its OK.
I'd also say just because its OK to allow a consumer
to install a device of their choice on the network does not necessarilly mean
they should be allowed to use the device any way that they want on your network.
If they use that Linksys-G wireless router to serve their neighbor or free
hotspot, that should be something that permission is needed from the
provider. I sell broadabnd for a purpose not necessarilly just a specific
amount of broadband. I sell an experience on the INternet not broadband.
Every person that takes advanatage of that experience should have to pay, if
that is my policy. If I buy arecord album, should I be allowed to copy and
duplicate that record album across the country? If I have Windows XP, should I
be able to give it to my neighbor when I'm done with the CD? No I bought a
license to use the software for a specific purpose, I did not sell them a
plastiv CD, nor anyone else the use of it. Basically these Network
Neutrality suggestions basically contradict every licensing and copyright rule
in the book. Maybe we should not be selling broadband, but instead selling
a license to use broadband off of our service. Can we all just start
sellling licenses to get around network neutrality legislation? If one
person can buy a license in other trades, why can we not sell it as a
license?
>2. Consumers are entitled to run applications and services
of their choice, subject to the needs of law enforcement;
This is OK, because it does not state the QOS
guarantee that the provider woyuld need to provide for that application.
Therefore slowing down some traffic as the provider felt appropriate would be
allowed.
>1. Consumers are entitled to access the lawful Internet
content of their choice;
I fully agree with this except, it needs to be further
defined to include who is classified as someone offering Internet access.
Are you saying that from a Most Money Machine, I should be allowed to check my
Email? Its is a network to. What makes my WISP any different than the
MOney Machine Most network? I do not think "Broadband" and "network" should be
bundled into the same thing as Internet Access. Internet access is just
one value added service that a network provider may elect to add to its services
for its subscribers. Internet access is not required for a network. The network
may be done for other purposes. I'm actually aware of many networks that
specifically restrict their users from being connected to the Internet from the
same PC that uses their service, if they connect to their network, for security
reasons. I believe that if a provider brands themselves as selling
"Internet Access" then maybe they need to conform to a set of guideline
that rule what they can and can not block, because they are a "internet Access"
provider. What this means though is, I can sell a customer access to my
network to pass VOIP between their offices or to the PSTN network through my
termination provider, as long as I'm not selling them Internet access
also. And then if by default I route all VOIP traffic across my
private VOIP section of my network I should be able to get away with jsutifying
a technical reason why I can't pass the subscribers VOIP data to the Internet,
because otherwise I could not share the same network with my VOIP only services
that don't use the Internet. I can't have the port routing two palces at
once at the same time, unless I added a huge management headache of also
tracking source and destination routing with the port. By I could argue
that technology does not exist yet and would possible cause unbearable latency
that would prevent the service from working. What this section says is
that I can not be jsut a phone company anymore that only does VOICE. I now
am requireed to be an Internet provider also. Power companies have
networks. Are they now going to be forced to offer INternet access as well
because they are a network operator?
This should be changed to Consumers should be entitled
to access the lawful INternet content of their choice, when purchasing "internet
Access" from their network provider, provided that there is not a technical
limitation preventing that or doing so does not unnecessarily restrict the
other "non-Internet" services offered by the provider. This being done
with the point that the same network may be sued for different purposes and
service offering, and should be required to not require providers to
unnecessarilly build two parallel network in the same area, when it can be
shared, and with the undetstanding that TCP/IP protocols have been adopted for
network operators regardless of wether they are offering "Internet
Services".
>Network
Neutrality Broadband Challenge
>Network Neutrality is the concept that network operators provide free and non-discriminatory transport on their networks between the endpoints >of the Internet. This has been a basic concept and function of the Internet since it was invented, and is adopted by the FCC in these four >principles to ensure that broadband networks are widely deployed, open, affordable and accessible to all consumers: >1. Consumers are entitled to access the lawful Internet
content of their choice;
>2. Consumers are entitled to run applications and services
of their choice, subject to the needs of law enforcement;
>3. Consumers are entitled to connect their choice of legal
devices that do not harm the network; and
>4. Consumers are entitled to competition among network
providers, application and service providers, and content
providers.
Now, lets open the floor for discussion...
Tom DeReggi
RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband
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