Category: Regulation

eComm Spectrum 2.0 Panel Video

Here’s the licensing panel from eComm live and in color. Seeing yourself on TV is weird; my immediate reaction is to fast for about a month.

On a related note, see Saul Hansell’s musings on spectrum.

The issue I wanted to raise at eComm and couldn’t due to lack of time and the meandering speculations about collision-free networks is spectrum sharing. Two-way communications systems all need a shared pipe at some level, and the means by which access to the pipe are mediated distinguish one system from another. So far, the debate on white spaces in particular and open spectrum in general is about coding and power levels, the easy parts of the problem. The hard part is how the system decides which of a number of competing transmitters can access the pipe at any given time. The fact that speculative coding systems might permit multiple simultaneous connections on the same frequency in the same space/time moment doesn’t make this question go away, since they only help point-to-point communications. Internet access is inherently a point-to-multipoint problem as theses system all aggregate wireless systems in order to move them to the fiber backbone.

The advantage of licensing is that it provides the spectrum with an authorized bandwidth manager who can mediate among the desires of competing users and ensure fairness per dollar (or some similar policy.) The idea that we can simply dispense with a bandwidth manager in a wide-area network access system remains to be proved.

So I would submit that one of the principles that regulators need to consider when deciding between licensed and unlicensed uses is the efficiency of access. The notion that efficiency can be discarded in favor of ever-fatter pipes is obviously problematic in relation to wireless systems; they’re not making more spectrum.

Obama’s Missed Opportunity

According to National Journal, Susan Crawford is joining the Obama administration in a significant new role:

Internet law expert Susan Crawford has joined President Barack Obama’s lineup of tech policy experts at the White House, according to several sources. She will likely hold the title of special assistant to the president for science, technology, and innovation policy, they said.

This does not make me happy. Crawford is not a scientist, technologist, or innovator, and the job that’s been created for her needs to be filled by someone who is; and an exceptional one at that, a person with deep knowledge of technology, the technology business, and the dynamics of research and business that promote innovation. A life as a legal academic is not good preparation for this kind of a job. Crawford is a sweet and well-meaning person, who fervently believes that the policy agenda she’s been promoting is good for the average citizen and the general health of the democracy and that sort of thing, but she illustrates the adage that a little knowledge is a dangerous thing.

As much as she loves the Internet and all that it’s done for modern society, she has precious little knowledge about the practical realities of its operation. Her principal background is service on the ICANN Board, where she listened to debates on the number of TLDs that can dance on the head of pin and similarly weighty matters. IETF engineers generally scoff at ICANN as a bloated, inefficient, and ineffective organization that deals with issues no serious engineer wants anything to do with. Her other qualification is an advisory role at Public Knowledge, a big player on the Google side of the net neutrality and copyright debates.

At my recent net neutrality panel discussion at MAAWG, I warned the audience that Crawford’s selection to co-manage the Obama transition team’s FCC oversight was an indication that extreme views on Internet regulation might become mainstream. It appears that my worst fears have been realized. Crawford has said that Internet traffic must not be shaped, managed, or prioritized by ISPs and core networking providers, which is a mistake of the worst kind. While work is being done all over the world to adapt the Internet to the needs of a more diverse mix of applications than it’s traditionally handled, Crawford harbors the seriously misguided belief that it already handles diverse applications well enough. Nothing could be farther from the truth, of course: P2P has interesting uses, but it degrades the performance of VoIP and video calling unless managed.

This is an engineering problem that can be solved, but which won’t be if the constraints on traffic management are too severe. People who harbor the religious approach to network management that Crawford professes have so far been an interesting sideshow in the network management wars, but if their views come to dominate the regulatory framework, the Internet will be in serious danger.

Creating a position for a special adviser on science, technology and innovation gave President Obama the opportunity to to lay the foundation of a strong policy in a significant area. Filling it with a law professor instead of an actual scientist, technologist, or innovator simply reinforces the creeping suspicion that Obama is less about transformational change than about business as usual. That’s a shame.

Cross-posted at CircleID.

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Opting-out of Adsense

Regular readers are aware that this blog used to feature Google ads. We never made serious money from Adsense, so it was easy to decide to drop it when the Terms and Conditions of Google’s new behavioral advertising campaign were relased. Here’s what Google suggests re: a privacy disclosure:

What should I put in my privacy policy?

Your posted privacy policy should include the following information about Google and the DoubleClick DART cookie:

* Google, as a third party vendor, uses cookies to serve ads on your site.
* Google’s use of the DART cookie enables it to serve ads to your users based on their visit to your sites and other sites on the Internet.
* Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

Because publisher sites and laws across countries vary, we’re unable to suggest specific privacy policy language. However, you may wish to review resources such as the Network Advertising Initiative, or NAI, which suggests the following language for data collection of non-personally identifying information:

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

You can find additional information in Appendix A of the NAI Self-Regulatory principles for publishers (PDF). Please note that the NAI may change this sample language at any time.

People don’t come to this site to buy stuff, and they shouldn’t have to undergo a vexing decision-making process before visiting this blog, so we’ve dropped Google as an advertiser. Not because Google is Evil, but simply because this is one too many hoops for our readers to jump through. Plus, the commission rate sucks.

So please continue to read Broadband Politics without fear of being reported to Big Brother.

Digital Britain and Hokey Tools

It’s helpful to see how other countries deal with the typically over-excited accusations of our colleagues regarding ISP management practices. Case in point is the Digital Britain Interim Report from the UK’s Department for Culture, Media and Sport and Department for Business, Enterprise and Regulatory Reform, which says (p. 27):

Internet Service Providers can take action to manage the flow of data – the traffic – on their networks to retain levels of service to users or for other reasons. The concept of so-called ‘net neutrality’, requires those managing a network to refrain from taking action to manage traffic on that network. It also prevents giving to the delivery of any one service preference over the delivery of others. Net neutrality is sometimes cited by various parties in defence of internet freedom, innovation and consumer choice. The debate over possible legislation in pursuit of this goal has been stronger in the US than in the UK. Ofcom has in the past acknowledged the claims in the debate but have also acknowledged that ISPs might in future wish to offer guaranteed service levels to content providers in exchange for increased fees. In turn this could lead to differentiation of offers and promote investment in higher-speed access networks. Net neutrality regulation might prevent this sort of innovation.

Ofcom has stated that provided consumers are properly informed, such new business models could be an important part of the investment case for Next Generation Access, provided consumers are properly informed.

On the same basis, the Government has yet to see a case for legislation in favour of net neutrality. In consequence, unless Ofcom find network operators or ISPs to have Significant Market Power and justify intervention on competition grounds, traffic management will not be prevented.

(Ofcom is the UK’s FCC). Net neutrality is, in essence, a movement driven by fears of hypothetical harm that might be visited upon the Internet given a highly unlikely set of circumstances. Given the fact that 1.4 billion people use the Internet every day, and the actual instances of harmful discrimination by ISPs can be counted on one hand (and pales in comparison to harm caused by malicious software and deliberate bandwidth hogging in any case,) Ofcom’s stance is the only one that makes any sense: keep an eye on things, and don’t act without provocation. This position would have kept us out of Iraq, BTW.

Yet we have lawmakers in the US drafting bills full of nebulous language and undefined terms aimed at stemming this invisible menace.

Are Americans that much less educated than Brits, or are we just stupid? In fact, we have a net neutrality movement in the US simply because we have some well-funded interests manipulating a gullible public and a system of government that responds to emotion.

A good example of these forces at work is the freshly released suite of network test tools on some of Google’s servers. Measurement Lab checks how quickly interested users can reach Google’s complex in Mountain View, breaking down the process into hops. As far as I can tell, this is essentially a dolled-up version of the Unix “traceroute” which speculates about link congestion and takes a very long time to run.

The speed, latency, and consistency of access to Google is certainly an important part of the Internet experience, but it’s hardly definitive regarding who’s doing what to whom. But the tech press loves this sort of thing because it’s just mysterious enough in its operation to invite speculation and sweeping enough in its conclusions to get users excited. It’s early days for Measurement Lab, but I don’t have high expectations for its validity.

Regulation and the Internet

Here’s a little speech I gave to members of the EU Parliament in Brussels on Oct. 14th. The cousins are contemplating a set of Internet access account regulations that would mandate a minimum QoS level and also ban most forms of stream discrimination. This explains why such rules are a bad (and utterly impractical) idea.

The Internet is a global network, and regulating it properly is a matter of global concern. I’d like to share a view of the technical underpinnings of the question, to better inform the legal and political discussion that follows and to point out some of the pitfalls that lie in wait.

Why manage network traffic?

Network management, or more properly network traffic management, is a central focus of the current controversy. The consumer-friendly statements of policy, such as the Four Freedoms crafted by Senator McCain’s technology adviser Mike Powell, represent lofty goals, but they’re constrained by the all-important exception for network management. In fact, you could easily simplify the Four Freedoms as “you can do anything you want except break the law or break the network.” Network management prevents you from breaking the network, which you principally do by using up network resources.

Every networking technology has to deal with the fact that the demand for resources often exceeds supply. On the circuit-switched PSTN, resources are allocated when a call is setup, and if they aren’t available your call doesn’t get connected. This is a very inefficient technology that allocates bandwidth in fixed amounts, regardless of the consumer’s need or his usage once the call is connected. A modem connected over the PSTN sends and receives at the same time, but people talking generally take turns. This network doesn’t allow you to save up bandwidth and to use it later, for example. Telecom regulations are based on the PSTN and its unique properties. In network engineering, we call it an “isochronous network” to distinguish it from technologies like the old Ethernet that was the model link layer technology when the DoD protocol suite was designed.

The Internet uses packet switching technology, where users share communications facilities and bandwidth is allocated dynamically. Dynamic bandwidth allocation, wire-sharing, and asynchrony mean that congestion appears and disappears on random, sub-second intervals. Packets don’t always arrive at switching points at the most convenient times, just as cars don’t run on the same rigorous schedules as trains.
Continue reading “Regulation and the Internet”

The Trouble with White Spaces

Like several other engineers, I’m disturbed by the white spaces debate. The White Space Coalition, and its para-technical boosters, argue something like this: “The NAB is a tiger, therefore the White Spaces must be unlicensed.” And they go on to offer the comparison with Wi-Fi and Bluetooth, arguing as Tom Evslin does on CircleID today that “If we got a lot of innovation from just a little unlicensed spectrum, it’s reasonable to assume that we’ll get a lot more innovation if there’s a lot more [unlicensed] spectrum available.”

According to this argument, Wi-Fi has been an unqualified success in every dimension. People who make this argument haven’t worked with Wi-Fi or Bluetooth systems in a serious way, or they would be aware that there are in fact problems, serious problems, with Wi-Fi deployments.

For one thing, Wi-Fi systems are affected by sources of interference they can’t detect directly, such as FM Baby Monitors, cordless phones, and wireless security cameras. Running Wi-Fi on the same channel as one of these devices causes extremely high error rates. If 2.4 and 5.x GHz devices were required to emit a universally detectable frame preamble much of this nonsense could be avoided.

And for another, we have the problem of newer Wi-Fi devices producing frames that aren’t detectable by older (esp. 802.11 and 802.11b gear) without an overhead frame that reduces throughput substantially. If we could declare anything older than 802.11a and .11g illegal, we could use the spectrum we have much more efficiently.

For another, we don’t have enough adjacent channel spectrum to use the newest version of Wi-Fi, 40 MHz 802.11n, effectively in the 2.4 GHz band. Speed inevitably depends on channel width, and the white spaces offer little dribs and drabs of spectrum all over the place, much of it in non-adjacent frequencies.

But most importantly, Wi-Fi is the victim of its own success. As more people use Wi-Fi, we have share the limited number of channels across more Access Points, and they are not required to share channel space with each other in a particularly efficient way. We can certainly expect a lot of collisions, and therefore packet loss, from any uncoordinated channel access scheme, as Wi-Fi is, on a large geographic scale. This is the old “tragedy of the commons” scenario.

The problem of deploying wireless broadband is mainly a tradeoff of propagation, population, and bandwidth. The larger the population your signal covers, the greater the bandwidth needs to be in order to provide good performance. The nice thing about Wi-Fi is its limited propagation, because it permits extensive channel re-use without collisions. if the Wi-Fi signal in your neighbor’s house propagated twice as far, it has four times as many chances to collide with other users. So high power and great propagation isn’t an unmitigated good.

The advantage of licensing is that the license holder can apply authoritarian rules that ensure the spectrum is used efficiently. The disadvantage is that the license holder can over-charge for the use of such tightly-managed spectrum, and needs to in order to pay off the cost of his license.

The FCC needs to move into the 21st century and develop some digital rules for the use of unlicensed or lightly-licensed spectrum. The experiment I want to see concerns the development of these modern rules. We don’t need another Wi-Fi, we know how it worked out.

So let’s don’t squander the White Spaces opportunity with another knee-jerk response to the spectre of capitalism. I fully believe that people like Evslin, the White Space Coalition, and Susan Crawford are sincere in their belief that unlicensed White Spaces would be a boon to democracy, it’s just that their technical grasp of the subject matter is insufficient for their beliefs to amount to serious policy.

Comcast files their compliance plan

Today was the deadline for Comcast to tell the FCC how its existing congestion management system works, as well as how its “protocol agnostic” replacement is going to work. To the dismay of some critics, they’ve done just that in a filing that was hand-delivered as well as electronically filed today. It will be posted to the Comcast web site shortly.

The filing corrects some of the false allegations made by critics with respect to privacy, making it very clear that the existing system simply inspects protocol headers (“envelopes”) and not personal data. David Reed in particular got himself worked into a tizzy over the idea that Comcast was deciding which streams to delay based on content, but this is clearly not the case. Inside the IP envelope sits a TCP envelope, and inside that sits a BitTorrent envelope. User data is inside the BitTorrent (or equivalent) envelope, and Comcast doesn’t look at it.

The current system sets a bandwidth quota for P2P, and prevents P2P as a group from crossing the threshold from this quota (about 50% of total upstream bandwidth) with new uni-directional upload (AKA, file-server-like) streams by tearing down requested new streams with the TCP Reset bit. The system is a bit heavy-handed, but reserving 50% of the network for one class of application seems pretty reasonable, given that no more than 20% of customers use P2P at all.

Nonetheless, the new system will not look at any headers, and will simply be triggered by the volume of traffic each user puts on the network and the overall congestion state of the network segment. If the segment goes over 70% utilization in the upload direction for a fifteen-minute sample period, congestion management will take effect.

In the management state, traffic volume measurement will determine which users are causing the near-congestion, and only those using high amounts of bandwidth will be managed. The way they’re going to be managed is going to raise some eyebrows, but it’s perfectly consistent with the FCC’s order.

High-traffic users – those who’ve used over 70% of their account’s limit for the last fifteen minutes – will have all of their traffic de-prioritized for the next fifteen minutes. While de-prioritized, they still have access to the network, but only after the conforming users have transmitted their packets. So instead of bidding on the first 70% of network bandwidth, they’ll essentially bid on the 30% that remains. This will be a bummer for people who are banging out files as fast as they can only to have a Skype call come in. Even if they stop BitTorrent, the first fifteen minutes of Skyping are going to be rough. A more pleasant approach would be to let excessive users out of QoS jail with credit for good behavior – if their utilization drops to Skype level, let them out in a few seconds, because it’s clear they’ve turned off their file sharing program. This may be easier said than done, and it may raise the ire of Kevin Martin, given how irrational he is with this anti-cable vendetta.

The user can prevent this situation from arising, of course, if he wants to. All he has to do is set the upload and download limits in BitTorrent low enough that he doesn’t consume enough bandwidth to land in the “heavy user” classification and he won’t have to put up with bad VoIP quality. I predict that P2P applications and home gateways are going to incorporate controls to enforce “Comcast friendly” operation to prevent de-prioritization. There are other more refined approaches to this problem, of course.

At the end of the day, Comcast’s fifteen/fifteen system provides users with the incentive to control their own bandwidth appetites, which makes it an “end-to-end” solution. The neutralitarians should be happy about that, but it remains to be seen how they’re going to react.

It looks pretty cool to me.

UPDATE: Comcast-hater Nate Anderson tries to explain the system at Ars Technica. He has some of it right, but doesn’t seem to appreciate any of its implications. While the new system will not look at protocol headers (the evil “Deep Packet Inspection” that gets network neophytes and cranks so excited) , and it won’t use TCP Resets, that doesn’t mean that P2P won’t be throttled; it will.

That’s simply because P2P contributes most of the load on residential networks. So if you throttle the heaviest users, you’re in effect throttling the heaviest P2P users, because the set of heavy users and the set of heavy P2P users is the same set. So the “disparate impact” will remain even though the “disparate treatment” will end.

But the FCC has to like it, because it conforms to all of Kevin Martin’s rabbit-out-the-hat rules. The equipment Comcast had had to purchase for this exercise in aesthetic reform will have utility down the road, but for now it’s simply a tax imposed by out-of-control regulators.

FCC finally issues Comcast memo

Kevin Martin and his Democratic Party colleagues at the FCC have issued their Comcast order, available at this link. They find some novel sources of authority and apply some interesting interpretations of the facts. I’ll have some detailed commentary after I’ve read it all and checked the footnotes. It’s an amusing exercise, if you like that sort of thing.

For a good summary of the order, see IP Democracy.

Kevin Martin’s secret regulations

As the crescendo of criticism builds against the FCC’s pending publication of its new rules for Internet access providers, the New York Times emerges as the sole source of pro-FCC coverage. They publish a bizarre Op-Ed by Free Press chairman Tim Wu equating competing carriers with OPEC and mistaking the general trend in broadband prices – sharply down – with the trend for gas prices, which goes in the opposite direction entirely:

AMERICANS today spend almost as much on bandwidth — the capacity to move information — as we do on energy. A family of four likely spends several hundred dollars a month on cellphones, cable television and Internet connections, which is about what we spend on gas and heating oil.

Here’s what’s happening to broadband prices at Comcast:

High-speed Internet revenue increased 10% to $1.8 billion in the second quarter of 2008 from $1.6 billion in 2007 reflecting a 12% increase in subscribers and a 3% decline in average monthly revenue per subscriber to $42.01, reflecting the impact of additional bundling and the recent introduction of new offers and speed tiers.

I’d love to see a 3% monthly decline in gas prices, even at the same volume level. But the Comcast figures show consumers upgrading to higher speed tiers (like Blast, which I measure at 28 Mb/s download speed) and still seeing an average decline in prices. Wu isn’t talking about life in the Real WorldTM.

Martin himself held a pow-wow with Times reporters, hoping to evoke some of that old-time populism that the nation’s elite daily is so good at. BITS blogger Saul Hansell reports on Martin’s faulty facts and shoddy analysis:

“The network operators can recoup their investment in the network and can charge for access to network services, but consumers have complete control over the devices and content that don’t have anything to do with investment in the underlying network,” he said.

I asked about reports that AT&T now bans all use of peer-to-peer networking software on its wireless data network. It also bans some video services, like the Slingbox feature that lets you watch your home television signal on your cellphone.

Mr. Martin declined to answer. His view is that the commission should not publish explicit regulations. Rather, it should address complaints that are made, as it did with the Comcast case.

“The commission is very careful in that we look at the particular facts that are in front of us. We are not judging the next case,” he said. “Hard and fast rules can actually be over- and under-inclusive, and they can also have adverse impact.”

Mr. Martin was asked whether the commission’s approach will push more Internet providers to start to impose caps on how much bandwidth consumers can use.

He said he wanted to reserve judgment on that trend. He seemed comfortable with Internet providers offering services with limits, so long as they are clearly stated.

So we have this new regime for Internet access providers where every move they make is to be judged according to a list of secret regulations. If ever there was a recipe for stalemate, this is it.

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