I've been on wireless lists and watched discussions about network management, traffic management, and "damage control" for what's almost a decade now. What I can say with confidence can be summed up as follows: "We in this industry have absolutely no common agreement on a vast array of network management issues". While we agree generally that such network manage must be done, we're as diverse in our approach, methods, philosophy and even goals, as we are in number.
I doubt that any random pickings of 100 WISP's would, if each management approach is studied carefully, would find that there would be any "system" or "common approach" with numbers higher than 10, of WISP's who use very similar approaches to ANYTHING. Can ANYONE, with confidence, read the below statement of ideas, and come away believing the the FCC people (and far less likely Congress) could write the rules and end up even the below IDEAS in play, much less actually accomplish what they're after, while at the same time not causing any of us monster headaches, and major issues due to the fact that they just haven't any idea what the bloody heck they're doing? WE COULD NOT DO IT FOR EACH OTHER. I don't know if you'd dispute that, but that's my take. I could not write a legalese network administration rule set that wouldn't eventually result in havoc for most of you. And vice versa. "Confidence they'll make it work out well.."??? Great... what kind of supermen do they have? They can walk on water, never fart, and their feet don't stink, as well? I'd really like to meet these supermen who can not only build an all encompassing set of regulations that allow us to have full flexibility for network management, but manage to write in in LEGALESE that we can understand and implement, while keeping all the technical aspects fully transparent and intact. NOWHERE and in no place is there any evidence of this type of approach. Rather, the system becomes tightly chained down, legally codifying design, mechanism, and methods, along with legal standards and mechanisms designed to measure and define the outcomes. It has taken... errr... nearly a decade, to get INFORMAL AGREEMENT from the FCC concerning antenna substitution, and it's not ACTUALLY in the legal language of the rules, just advised as a policy concerning ENFORCEMENT. We have "de facto" modular approval to build our own stuff... But again, it's... "enforcement policy", not coded into the rules. I note with some humor that the FCC has considered itself to be 'highly flexible" and adaptable when it comes to technological change. Yet, compared to how WE need to function, it's iron bound rigidity. Let's not go fooling ourselves that net neutrality is going to be "reasonable and wise". That's the stuff of fantasies. There is no real life example to exist, and no reason to believe any earthshaking change is on the way on behalf of our Swamp on the Potomac. It's going to end up being fine grained, and will be specifying mechanisms, procedure, methods, and even defining how to arrive at a comply/not comply via detailed and specific testing. They don't have the enforcement capacity, the courts will not have "judgment" to determine what is and isn't reasonable. There will be no "reasonable" standard, it will be much like the rigidity of every other mandate. The rules will be written for THEIR convenience, and our cost and headaches are of no concern and never will be. There's no federal agency with the expertise which can understand and analyze our networks to comply with "philosophical" goals. Instead, there will be specific and detailed mandates and compliance will be... well, just don't think it'll be ... flexible. Perhaps by their standards, but that's still a rigidity and regimentation that would put the Army to shame. Somewhere, somehow, we need to make a stand... "NO more intrusion into what we do". Period. We should have been doing this before the "more" needed to be inserted into that statement, but that chance was lost before it even technically, since founding WISPA members ASKED the FCC to get involved in our business in the first place, before there was actually a WISPA. This rejection of regulatory excess isn't limited to internet provider folks. It's being thrown at EVERYONE. From very onerous rules about family farms and small producers of anything edible, to requiring you to buy a type of insurance just to be allowed to breath, and many, many other items, there's no reason to think that "reasonable" is anywhere within this government's vocabulary - at least not in a form that any of us would recognize. It's time to take a phrase from that OTHER Reagan... and "Just say no!". -------------------------------------------------- From: "Glenn Kelley" <gl...@hostmedic.com> Sent: Friday, February 05, 2010 12:03 AM To: "WISPA General List" <wireless@wispa.org> Subject: Re: [WISPA] Common Carrier or what: The FCC's role in regulationofnet-neutrality... > > They get locked into this pattern of either mortgaging to pay for their > lifestyle - or... > > Title II of the Communications Act—the section that regulates > telecommunications common carriers is now being considered by the FCC to > oversee broadband. FCC Commissioner Robert M. McDowell during a talk he > gave to the Free State Foundation asked: (see First Do No Harm: A > broadband plan for Amercia) > “Exactly what kind of companies might get tangled up into this regulatory > Rubik’s Cube?…Any Internet company that offers a voice application?” … > “With this newfound authority, why stop at voice apps? Isn’t voice just > another type of data app? As the distinction between network operators and > application providers continues to blur at an eye-popping rate, how will > the government be able to keep up?” > Is Broadband able to be classified as a common carrier service? The FCC > most assuredly believes this is well within its authority – and is > exercising these “policies” not just over the agency’s ability to regulate > the NET – but if it can be classified as a common carrier service. > Comcast is suing the FCC over its Order sanctioning the company for P2P > blocking – so their ability to “regulate” needs to be clearly defined – of > course re-defining a government entity is not an easy task… however > defining ISPs as common carriers would seem suited to the FCC’s purposes, > especially if given Title II’s clear definition of what a common carrier > can’t do: > “It shall be unlawful for any common carrier to make any unjust or > unreasonable discrimination in charges, practices, classifications, > regulations, facilities, or services for or in connection with like > communication service, directly or indirectly, by any means or device, or > to make or give any undue or unreasonable preference or advantage to any > particular person, class of persons, or locality, or to subject any > particular person, class of persons, or locality to any undue or > unreasonable prejudice or disadvantage.” > McDowell stated, “At the same time, broadband companies create and > maintain software with millions of lines of code inside their systems. > They also own app stores that are seamlessly connected to their networks. > As technology advances, will the government be able to make the > distinctions between applications and networks necessary under a new > regulatory regime?… Will it (the government) be able to do so in Internet > Time?” > One thing is clear - If we were able to agree on some basic tenets > providers could utilize to ensure all accounts are serviceable based upon > not only “bandwidth” but also “throughput” most of these arguments would > simply be a mute point. > This past October (2009) The FCC laid out its draft for network neutrality > rules which appears to allow to the greater extent a “free and open > Internet.” The principles already existing from 2005: > Consumers are entitled to access the lawful Internet content of their > choice > Consumers are entitled to run applications and use services of their > choice, subject to the needs of law enforcement > Consumers are entitled to connect their choice of legal devices that do > not harm the network > Consumers are entitled to competition among network providers, application > and service providers, and content providers. > Those principles along with two new additional principles are now going to > be made “binding: > A provider of broadband Internet access service must treat lawful content, > applications, and services in a nondiscriminatory manner > A provider of broadband Internet access service must disclose such > information concerning network management and other practices as is > reasonably required for users and content, application, and service > providers to enjoy the protections specified in this rulemaking > In this ever changing world of the INTERNET - I do not think it is > reasonable to agree ISP’s are able to perform Network management: > To manage congestion on networks > To address harmful traffic (viruses, spam) > To block unlawful content (child porn) > To block unlawful transfers of content (copyright infringement) > For “other reasonable network management practices” > The ambiguity of that last item is alarming to both camps in the war for > “net-neutrality.” The FCC is going to at some point – have to define the > other reasonable network practices” for this to have any real meaning > after all. The question remains: Congress has never given the FCC any > authority to regulate the Internet for the purpose of ensuring net > neutrality has it? > > > > > > -------------------------------------------------------------------------------- > WISPA Wants You! Join today! > http://signup.wispa.org/ > -------------------------------------------------------------------------------- > > WISPA Wireless List: wireless@wispa.org > > Subscribe/Unsubscribe: > http://lists.wispa.org/mailman/listinfo/wireless > > Archives: http://lists.wispa.org/pipermail/wireless/ -------------------------------------------------------------------------------- WISPA Wants You! Join today! http://signup.wispa.org/ -------------------------------------------------------------------------------- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
