Roycroft attacks strawman

Yesterday I posted a brief note on the Trevor Roycroft “study” promoted by Free Press as if it were some sort of substantial piece of the Internet regulation debate, stressing the inappropriateness of the telephone monopoly regulatory model to the Internet. I didn’t pay much attention to Roycroft’s economic analysis, preferring to leave that sort of thing to experts. The Phoenix Center has done such an analysis:

Shortly thereafter, Dr. Trevor Roycroft, of Roycroft Consulting released a critical response to the paper. Upon our request, Dr. Roycroft agreed to allow the Phoenix Center to post his comments on our website In his critical review of our work, Dr. Roycroft’s analysis is “an examination of our economic model.” Dr. Roycroft lists what he believes are four “fatal” flaws in our economic model:

1. the “economic modeling does not address economies of scale in last-mile broadband access networks”;

2. the “economic modeling assumes policy makers, by pursuing a policy of network neutrality, can completely eliminate product differentiation among broadband access providers”;

3. the model “fails to acknowledge the impact of the abandonment of network neutrality on the consumption and production of Internet content, service, and applications”;

4. “the conclusions depend on the existence of low levels of sunk costs associated with constructing new last-mile access networks.”

In an effort to ensure the accuracy and legitimacy of all analysis performed and released by the Phoenix Center, we have evaluated carefully Dr. Roycroft’s response to see if he presents any legitimate criticisms or offers any material improvements to the analysis in POLICY PAPER NO. 24. At the Phoenix Center, we appreciate criticism and comment, since such review can be used to either affirm or improve our analysis, thereby making our work more useful for policy decisions. In some cases, comments on our work provide direction for future research. By all accounts, Dr. Roycroft’s comments confirm the relevance and importance of the general theme of POLICY PAPER NO. 24.

Curiously, none of the “flaws” claimed by Dr. Roycroft are actually present in our analysis. In fact, all of the alleged errors and omissions claimed by Dr. Roycroft are dealt with squarely in our paper. For example, the very purpose of our model is to argue that because scale economies are present, service differentiation is necessary for entrants to successfully enter the market. Yet Dr. Roycroft claims we “do not address economies of scale” and that we “ignored the fact that new entrants will likely need to charge higher prices than incumbents.” As such, this criticism has no merit. Dr. Roycroft’s other arguments, to the extent they address key issues in the Network Neutrality debate, are in fact not criticisms of our model at all and are, in fact, specifically incorporated into our analysis, either formally or informally.

Read the whole thing if you want cool broadband someday, and the original study here.

I never cease to be amazed at the dishonesty of the neuts.

Roycroft’s Nonsensical Neutrality Study

The Network Neutrality consumer groups are flogging a study by one Trevor Roycroft attacking Christopher Yoo’s arguments in favor of Network Diversity. Roycroft is an economist whose grasp of communications technology is virtually non-existent. The study, ECONOMIC ANALYSIS AND NETWORK NEUTRALITY: SEPARATING EMPIRICAL FACTS FROM THEORETICAL FICTION consistently confuses the Internet with the telephone lines that parts of it use for consumer access.

But the meaning of Network Neutrality finally comes across: these people want to force-fit the Internet into the regulatory framework that was devised for the old monopoly analog telephone network back in the 1930s. It’s a great example of the old saw “if the only tool you have is a hammer every problem looks like a nail.”

The differences between the Internet and old telephone network are so vast I hardly know where to begin in pointing them out, but here’s a stab:

1. The Internet is not a single network, it’s a meeting place for large number of private networks, some of which sell access to the public.

2. The Internet isn’t a single-service, analog network or a digital clone of one. It’s a multi-purpose packet-switched network formed by loose agreements of thousands of carriers and supporting dozens of applications.

3. Packet-switched networks manage resources in a dynamic way and have to deal with loads that are highly variable. Consequently, forcing resource management schemes on packet networks that originated in the circuit-switching world is asinine and counter-productive.

4. It’s almost impossible to define “discrimination” in packet network management practice because every packet affects every other packet. It’s more like a market than a centrally controlled and rigorously predictable telephone network,

5. Misapplication of the telephone regulatory framework to the Internet will certainly make the Internet behave more like a telephone network than it does today: limited services, low speeds, and no capital investment.

Network neutrality is a colossally stupid idea. The Internet is cool because it’s not the telephone network; it’s way more powerful and way more capable of doing new and interesting things because it construction applies more intelligence to more dynamic conditions. Forcing it into a regulatory straitjacket devised for analog monopoly is the surest way to kill it.

Google’s Quest for Power

I recommend a report in the New York Times on the massive super-computer complex Google has built on the banks of the Columbia River in order to control Internet search and download:

THE DALLES, Ore., June 8 — On the banks of the windswept Columbia River, Google is working on a secret weapon in its quest to dominate the next generation of Internet computing. But it is hard to keep a secret when it is a computing center as big as two football fields, with twin cooling plants protruding four stories into the sky.

The complex, sprawling like an information-age factory, heralds a substantial expansion of a worldwide computing network handling billions of search queries a day and a growing repertory of other Internet services.

And odd as it may seem, the barren desert land surrounding the Columbia along the Oregon-Washington border — at the intersection of cheap electricity and readily accessible data networking — is the backdrop for a multibillion-dollar face-off among Google, Microsoft and Yahoo that will determine dominance in the online world in the years ahead.

Google Plex

Oddly, the site is close to the former headquarters of the Bhagwan Sree Rajneesh cult, best known for its criminal activities:

In 1981 Rajneesh’s cult purchased a dilapidated ranch in Oregon, U.S., which became the site of Rajneeshpuram, a community of several thousand orange-robed disciples. Rajneesh was widely criticized by outsiders for his private security force and his ostentatious display of wealth. By 1985 many of his most trusted aides had abandoned the movement, which was under investigation for multiple felonies including arson, attempted murder, drug smuggling, and vote fraud in the nearby town of Antelope. In 1985 Rajneesh pleaded guilty to immigration fraud and was deported from the United States.

Is history repeating itself? Naw, Google’s a business, not an insane cult set on world domination. I used to live a stone’s throw from the Columbia, downstream in the Portland area, and I visited the Bonneville Dam a couple of times. They have a nice fish hatchery and a place where you can see some huge sturgeons up close. The dam is a massive public works project capable of generating enormous amounts of power relatively cheaply, although my power bill didn’t reflect any cost savings.

This article puts the lie to the claim that Google supports the misapplication of the old telecom regulatory framework to Internet routing because they want to preserve low entry barriers for their competitors. The only way for them to hang on to their dwindling share of the search business is to outspend Microsoft and Yahoo. Keeping a lid on corporate Internet access fees is obviously vital to their survival.

Killer provision in Snowe-Dorgan

Here’s the essence of the Snowe-Dorgan kill the Intenet bill:

`(5) only prioritize content, applications, or services accessed by a user that is made available via the Internet within the network of such broadband service provider based on the type of content, applications, or services and the level of service purchased by the user, without charge for such prioritization; and

If your concern is free speech, why attack the revenue base for VoIP and IPTV?

This makes no sense unless there’s a hidden agenda.

Isenberg vs. The World of Engineering

David Isenberg is in a tizzy to explain why the Washington Post got it wrong on Internet neutrality regulation and this is what he comes up with:

C’mon! If we see an innovative artist, do we need to balance that innovation with better paint? If we can buy innovative cars, does this demand better roads? If we like innovative electronics, do we need better electricity?

Actually, yes. Before we had paved roads, cars were engineered like the Model T, and with the advent of highways we got faster and more comfortable cars. So yes, there is a very strong relationship between the design of a car and the road it runs on. And a lot of that modern art stuff isn’t possible without acrylic paint, and the electronics we use depend on clean and stable power. These things are very much related, thank you very much.

Isenberg, you see, doesn’t go in for all that engineering mumbo-jumbo. Like most of the passionate voices on the pro-regulation side, he’s worried about free speech. That’s a legitimate thing to worry about in an era where the FCC fines TV networks for showing Janet Jackson’s breast, but there’s actually no connection between that issue and the Quality of Service provisions banned by the Markey Amendment and similar legislation.

Unfortunately, Isenberg’s claim to fame is a deep spiritual understanding of the Internet’s technical infrastructure. As far as I can tell, that claim is based on gaseous vapors.

Vint Cerf forgot he said this

This is hilarious. Go look at Internet RFC 3271, The Internet is for Everyone by Dr. Vint Cerf:

Internet is for everyone – but it won’t be if Governments restrict access to it, so we must dedicate ourselves to keeping the network unrestricted, unfettered and unregulated. We must have the freedom to speak and the freedom to hear.

Internet is for everyone – but it won’t be if it cannot keep up with the explosive demand for its services, so we must dedicate ourselves to continuing its technological evolution and development of the technical standards the [sic] lie at the heart of the Internet revolution.

Unfortunately, the dude has changed his mind.

Note: Cerf was an employee of WorldCom when he wrote this, and now he’s an employee of Google. I’m not saying his opinions are for sale, because I’m sure the Father of the Internet is a man of honor and integrity.

Brutus was an honorable man.

Quick note to Boxer

I sent this to my US Senator.

Dear Senator Boxer,

I’m a constituent and a network engineer. I invented key parts of the communications systems used by your personal computers (Ethernet and WiFi,) and I’m against net neutrality regulations.

Net neutrality sounds like it’s as wonderful as motherhood and organically-grown, fair-trade apple pie. We all want our Internet to be free, fair, and open, and nobody wants any heinous tollbooths in the Info Super Highway, gatekeepers in Cyberspace, or Big Brothers deciding what blogs we can read. If the issue were that simple there wouldn’t be a debate, net neutrality laws would pass both houses by acclamation and be signed by our President with flourish and fanfare and peace would rule the planet, etc.

But public policy is not so simple, especially in a case that involves the regulation of the single most complicated machine ever built, the Internet.

The Snowe-Dorgan and Markey Amendments contain a poison pill that will stifle the evolution of the Internet, in the form of a prohibition against a Quality of Service surcharge:

If a broadband network provider prioritizes or offers enhanced quality of service to data of a particular type, it must prioritize or offer enhanced quality of service to all data of that type (regardless of the origin or ownership of such data) without imposing a surcharge or other consideration for such prioritization or enhanced quality of service.

The argument in favor of this provision says that it’s needed in order to prevent the formation of a two-tier Internet, where one tier has Quality of Service and the other doesn’t, and this is somehow bad for Daily Kos and Google.

This is a false claim, because the engineering math behind Quality of Service says it can’t be applied to every stream from every user. In Lake Woebegon all the children can be above average, but on the Internet all packets can’t.

We have a two-tier Internet today where commercial customers have a full range of service plans available to them, but consumers have a very limited menu. The provision would guarantee that the consumer menu will always be severely limited. We don’t need a single- or dual-tier Internet but a multi-tiered one where every new application can get the services it needs from the network and nobody has to pay for services they don’t want. As Tim Berners-Lee, inventor of the World Wide Web said:

We pay for connection to the Net as though it were a cloud which magically delivers our packets. We may pay for a higher or a lower quality of service. We may pay for a service which has the characteristics of being good for video, or quality audio.

That view cannot be reconciled with the provision cited.

Perhaps ironically, the old monopolists – AT&T, Verizon, Bell South – advocate expansion of consumer choice while the new monopolists – Google, et. al. – advocate for restriction of choice.

Consumers benefit from the choice that the Stevens Bill offers them, and I hope you will reverse your public position and reject the special-interest-benefiting amendments offered by the agents of the New Monopolists.

The Internet has never been regulated in the manner of the cited provision, and anyone who tells you otherwise is trying to bamboozle you. Don’t be misled.

In 2002, Internet framer Vint Cerf said: …we must dedicate ourselves to keeping the network unrestricted, unfettered and unregulated. That’s as true today as it was then.

Respectfully,

Richard Bennett

Facts vs. Fictions

Have you ever seen Free Press’ list of supposed facts about Net Neutrality? Most of them aren’t facts at all, not surprisingly.

PSEUDO-FACT #1: Network Neutrality protections have existed for the entire history of the Internet.

REAL FACT: Actually, there is no legal precedent at all for the anti-QoS provision of the Neutrality regulations, and many commercial Internet customers use QoS today. Even the Internet2 Abilene network tried to use it.

PSEUDO-FACT #2: Network discrimination through a “tiered Internet” will severely curtail consumer choice.

REAL FACT: How can the expansion of service plans be a curtailment of choice? The QoS plan doesn’t affect web surfing, it’s something that opens broadband up to alternate uses, as the Cable network has for ten years with Triple Play.

PSEUDO-FACT #3: Network discrimination will undermine innovation, investment and competition.

REAL FACT: All networks discriminate, that’s how they manage traffic and prevent overload. A richer service space frees innovation by providing it with the necessary support in the network for new things.

PSEUDO-FACT #4: Network discrimination will fundamentally alter the consumer’s online experience by creating fast and slow lanes for Internet content.

REAL FACT: The Internet has always had fast and slow lanes for content, that’s why the round-trip-time to the nearest Yahoo! portal is so much faster than for a generic web site. The two main tiers today separate the consumer Internet from the commercial one. COPE narrows the gap, and Free Press wants to increase it. Key point.

PSEUDO-FACT #5: No one gets a “free ride” on the Internet.

REAL FACT: Not all riders pay the same price per bit today. Google pays wholesale and I pay retail. Google is not paying a “fair share”.

PSEUDO-FACT #6: Phone companies have received billions of dollars in public subsidies and private incentives to support network build-out.

REAL FACT: That’s given us a nice copper network, but now we want a fiber optic one, and that’s going to cost more.

PSEUDO-FACT #7: There is little competition in the broadband market.

REAL FACT: Yes and no. Most consumers have four choices, two of which are wireless, but most choose wire because it works better. The laws of physics aren’t neutral.

PSEUDO-FACT #8: Consumers will bear the costs for network infrastructure regardless if there is Network Neutrality.

REAL FACT: So let’s drop the corporate income tax, OK? The same logic applies, you see.

PSEUDO-FACT #9: Investing in increased bandwidth is the most efficient way to solve increased network congestion problems.

REAL FACT: It’s part of the solution, but not the total solution. There is more bandwidth in the access network than in any one internal path, so the billion users on the Internet can always overload any one interior link. That’s why we need both fast pipes and QoS.

PSEUDO-FACT #10: Network owners have explicitly stated their intent to build business models based on discrimination.

REAL FACT: All business models depend on discrimination, as do all tax laws and all criminal laws. It’s not a bad thing when we discriminate rationally.

PSEUDO-FACT #11: The COPE Act will not deter discrimination, but it will tie the hands of the FCC from preventing it.

REAL FACT: It gives the FCC the power to levy fines up to $500,000 for denial of access or degradation of access. That’s not peanuts.

PSEUDO-FACT #12: Supporters of Network Neutrality represent a broad, nonpartisan coalition that joins right and left, commercial and noncommercial interests.

REAL FACT: You’re basically a bunch of no-nothing kooks from both fringes who agree on an issue just like Pat Buchanan and Ralph Nader agree on their opposition to NAFTA, for different reasons. Show me somebody who’s: A) Knowledgeable; and B) Not a fringe figure who supports your regulations and I’ll buy him a beer. I haven’t seen that person yet. And no, Moby doesn’t meet my requirements.

Thanks for asking.

Senate Telecom Hearing

Tomorrow is the hearing on the telecom reform bill in the Senate Commerce, Science, & Transportation Committee. Ben Scott of Free Press represents the pro-regulation side of the neutrality debate, and an array of speakers on various sides of the ISP and Telco spectrum. Scott’s a good choice to speak for the neuts because he’s easily confused. Here’s some nonsense he spewed in a sound bite on a fictitious report his employers released recently:

“The issue of Network Neutrality is about who will control the future of the Internet,” said Ben Scott, policy director of Free Press, who will testify on behalf of the consumer groups at the Senate hearing. “Will a handful of phone and cable behemoths dominate an anti-competitive marketplace and do away with the Internet as we know it? Or will consumers, content creators, educators and small businesses continue to enjoy a free, open and competitive Internet? Every major consumer organization in the country is committed to meaningful, enforceable Network Neutrality.”

The Big Lie here is that the COPE Act expands consumer choice, while his bill restricts it. It should be a good hearing. His organization funnels the money into the Save the Internet campaign, and one of their employees, Tim Karr, runs their Astro-blog.

Yesterday, I happened the see a video clip from the Annual Kos event in which Matt Stoller of MyDD tried to make a rousing argument in favor of regulation. He had to admit that he knows nothing about the issue of Telecom policy, which was interesting because the regulations he proposes don’t actually relate to telecom policy. They’re a new and unprecedented intervention into Internet routing and service plan regulation, a totally virgin territory for government regulators. Stoller admitted that it’s just a good guys vs. bad guys issue for him, one that’s lots of “fun”. You can see the video clip at Link TV’s web site by clicking here.

So my question is this: “should the US Congress take advice on virgin regulatory territory from someone who admits to knowing nothing about the subject matter?”

I’ve got a list of questions I’d ask if I were a member the Senate panel, which I’ll post later just for fun.

One of the more interesting things that’s come to the surface recently is that the high-profile Internet guys who are listed on the pro-regulation side have said things that indicate they’re actually opposed to the specific provisions of the Markey and Snowe-Dorgan bills. Tim Berners-Lee, for example, wrote on his blog that he believes it should be OK for ISPs to offer service plans optimized for QoS or not:

We may pay for a higher or a lower quality of service. We may pay for a service which has the characteristics of being good for video, or quality audio.

…but these bills forbid that level of consumer choice.

And then there’s the Vint Cerf paradox, where a guy who hasn’t worked as an actual engineer for over twenty years wants specific engineering regulations on the Internet, oh, and they just happen to benefit his current employer. He’s a Good Guy, so Matt Stoller loves him.

See Matt Sherman for some good links on today’s news, including a story on News.com and an editorial in the Washington Post.

Best explanation ever

Writing on ZDNet in response to some mad ravings by Huffington Post blogger Russell Shaw, George Ou offers the best explanation of QoS ever:

I’ll say this loud and clear; QoS is a reordering of packets that is an essential part of network traffic engineering. Take the following example where A represents VoIP packets and b represents webpage packets.

No enhanced QoS policy
AbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbAbAbbbbbbAbA

With enhanced QoS policy
AbbbbbbbbbAbbbbbbbbbbAbbbbbbbbbbAbbbbbbbbbbA

Now note that there are only 5 A packets in the entire stream for either scenario and you still get the exact same throughput for the b packets with or without prioritization for the VoIP A packets. The difference is that the A packets are now a lot more uniform which makes sound quality go up and the webpage b packets don’t really care about uniformity since all they care is that they get there at all intact. With this QoS example, you can improve VoIP without affecting the average throughput of web surfing. More precisely, QoS has ZERO throughput effect on non-prioritized when there is zero congestion on the pipe. If it had been a congested network, then QoS will have minimal effect on non-prioritized traffic.

All those who think “net neutrality” regulations are fine should read this article and try to understand it. He breaks the issues down with great clarity and anybody who thinks he can regulate the Internet had better be able to understand what he’s saying.