Brian said it well.
What is needed, and what has been lost over the past decade (at the
instigation of the Bells, who pretty much took total control of the
FCC in 2001), is a clear distinction between the role of "common
carrier" and the role of the "value-added", "enhanced", or
"information" service provider. (Those latter three terms are
historically different but generally cover the same thing.)
A common carrier's job is to carry the bits, no questions asked.
That's what the Bells provide on dial-up calls, since they don't own
the modem, and what they still provide on DS1 and DS3 Special Access
circuits, the last vestiges of common carriage in current rules. Of
course those are all priced very high. "Special Access" got its name
because it was meant to make up for the revenue loss of using leased
lines for voice instead of dialing toll calls. So rural WISPs are
often stuck buying capacity at prices literally based on telephone
toll call rates circa 1990. A DS3 is treated as 672 toll calls!
An information service provider theoretically rides inside the
payload of common (or private) carriage, and is not a carrier
itself. ISPs are thus content, not carriage. So I see ISPs as
today's form of the press, and thus should have the same freedom of
the press as anyone else.
Ben Franklin founded the US post office as a way to distribute
newspapers. (The early US was the most literate country in the world,
at least in the north, and had a lot of newspapers.) It was like
common carriage; the PO didn't care about content, so long as you
weren't cheating by trying to sneak a letter (which was very
expensive before the 1830s) into a newspaper (no writing on the margins!).
If Kevin Martin had been in charge, then he would have privatized the
system, selling the vestiges of the post office to UPS and FedEx,
which would have merged with NewsCorp and Tribune Corp. They would
not have been required to carry competing newspapers, though they
would have made high-priced private carriage deals with specialty
publishers like Forbes and Reed-Elsevier. And the "newspaper
neutrality" movement would be demanding that the NewsCorp and Tribune
newspapers print ALL letters to the editor, unedited, while the FNC
would be promoting "fair and balanced" news.
Hence the position I've taken in various FCC filings (search ECFS for
"Ionary") -- common carriage must be restored, and ISPs should be
unregulated. In such a case, a misbehaving telco-captive ISP would be
met with alternative ISPs on the same wire.
Usage-based pricing does, of course, discourage file service. But
consumers don't like it. The vast majority of Americans would prefer
an unmetered, loosely restricted service. ISPs like SpeakEasy have
sold higher-priced service to customers who wanted the right to run
servers at home. If there were common carriage (and I'm referring to
bit-neutral, below-IP-layer "raw DSL", which was removed from most
Special Access tariffs in 2006), then there would be a choice of ISP,
no pressure on WISPs to support waste, and everyone BUT the Bells
would be happy. But the Bells seem to carry 51%+ of the vote these
days. "Network neutrality", which basically won't affect them
anyway, is their anticompetitive trick.
At 8/4/2010 08:15 AM, Brian Webster wrote:
So just let the market pressures dictate this. A WISP can switch
upstream providers if they are being treated unfairly. It may not be
cheaper but they have that right. Upstream providers are in the
business of selling bandwidth so it is unlikely that they will do
this if you are truly purchasing bandwidth from a wholesale
provider. The purchaser should carefully examine the terms of THEIR
contract and if they are purchasing bandwidth from a competitor they
should understand the risks of doing so. The free market system can
and will work especially with all of the new competitive systems
that are being built with stimulus money. The government does not
need total control of everything with the idea that reasonable
humans can't do it on their own without them.
As much as the whiny consumers can complain, I ask this question, if
every ISP did not work on some sort of oversubscription model then
why is it that a consumer won't go out and buy a 10 meg connection
from an upstream provider and pay the prices all ISP's do? The
business owner should have the right to regulate and manage the
capacity of their network as they see fit. They know what it is
capable of, what is profitable and what they feel they can handle.
Having to deal with outside forces that have no idea what that
individuals business model is working under is plain wrong. Will a
business owner make mistakes in some of their practices, no doubt.
Will they piss off consumers and lose customers if they do?
Certainly. Last time I checked that is still a free market system
and one of the beauties of being an American citizen. Government
cannot and should not try to keep these mistakes from happening.
If government should be in the place of protecting and taking care
of the poor consumer then why don't they start having grocery store
Nazi's dictate what you buy and eat to protect you and your health
and keep the health care costs down. They know what is a better diet
for you so they should dictate what you are allowed to buy and
eat
.just saying that at some point the government needs to stop
thinking they are going to be everyone's savior.
Brian
From: [email protected] [mailto:[email protected]]
On Behalf Of Jack Unger
Sent: Wednesday, August 04, 2010 12:10 AM
To: WISPA General List
Subject: Re: [WISPA] net neutrality, there may be hope yet...
Comments inline.
Fred Goldstein wrote:
At 8/3/2010 09:03 PM, Jack Unger wrote:
Fred,
Many WISPs throttle throughput according to the terms of the
contracted service that each customer purchases. For example, if a
WISP sells 1 Mb down and 512k up then they limit throughput to
somewhere near those levels. Under those conditions, a customer can
have a file or web server and it does not adversely affect the
overall WISP network performance.
Sure it does. Last week's discussion confirmed that the average ISP
retail residential customer generates a load of about 50-100 kbps. A
lot higher when "using" it, near zero at other times. But a file
server can pump an Mbps or more all day and night. The whole trick
to low residential pricing is a high oversubscription ratio, and this
is especially true with wireless.
Then put a monthly bandwidth cap (or caps) into your Terms of
Service and price your service accordingly.
This level of throughput management should come under the
"reasonable network management" definition that service providers
are allowed to perform. This throttling is also
application-independent so no selective throttling by application is
needed. Finally, the throttling is implemented in routing tables
full time and once programmed, it requires no human interaction.
"Reasonable" is a "rule of man", not "rule of law"
construct. Blocking the pirate CDN was not considered "reasonable"
when it was not done by an ILEC. I would rather allow ISPs to do as
they please, at risk of displeasing their customers, rather than
follow rules designed to please a cheapskate pR0n distributor. And
banning servers is a good way to keep the average load and thus the
cost and price down.
With no rules, what are you going to do when your upstream
provider decides to block or throttle your network for whatever the
reason? They are after all just "doing what they please". Without
some kind of network neutrality protection, there's no law against
blocking you, right?
Fred Goldstein wrote:
At 8/3/2010 06:24 PM, Jack Unger wrote:
Why would customers installing file servers cause you a problem if
you limited their throughput to the Terms and Conditions of their
contract where you would specify the amount of bandwidth that you
were supplying them and limiting them to?
You could limit throughput "neutrally", provided that it limited
upstream file service and interactive applications like gaming and
telephony equally. That's basically what Comcast consented to
do. However, those applications usually require a person to be
there; content distribution runs 7x24. Their ToS (I'm a customer)
prohibited file and web servers; the FCC found that unreasonable.
I do believe that if someone had complained about such activities
on Verizon's or ATT's part, the K-Mart FCC would have found it
perfectly desirable.
Fred Goldstein wrote:
At 8/3/2010 04:58 PM, Mike Hammett wrote:
That's what I don't understand... some people are so for Net
Neutrality, but every unhappy incumbent customer is a potential sale.
I've long opposed "network neutrality" rules on grounds that it
could put most WISPs out of business. You'd be forced to live by
the same rules that the urban ILECs and CATVs do, even though
your cost of both last-mile capacity and middle mile (if rural)
is much higher. Thus you'd be required to allow customers to
install file servers at their subscriber locations, even though
it's much cheaper (overall) to have them at a fiber backbone
site. Recall that Vuze, who made the big stink, is a pR0n
distributor using subscriber-site file servers and home-user
computers to undercut other CDNs on price.
I think Verizon actually favors such rules, on grounds that FiOS
is hurt less than most others, including cable, and they'd be
happy to see WISPs go away. (When I see them opposing it, I
think of Bre'r Rabbit and the brier patch.)
--
Fred Goldstein k1io fgoldstein "at" ionary.com
ionary Consulting http://www.ionary.com/
+1 617 795 2701
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