Comcast

For anyone wanting a good forward-looking perspective about the real challenges facing the Internet, look no further than the great new study "Estimating the Exaflood" by Bret Swanson and George Gilder.

Why this study is so timely and relevant is that the real problem facing the Internet is how to keep up with the exploding capacity demands of migrating to a video-driven Internet.

• The net neutrality utopians want to assume that bandwidth is infinite and free -- magically supplied by others for their p2p bandwidth gluttony -- with no costs to, or no affect on, others.
• The real world does not operate that way...

The report also is an important backdrop for why broadband networks must be allowed reasonable network management.

• Without massive investment and reasonable network management, the quality and the responsiveness of the Internet will suffer as the exaflood surges.

In a stunningly naive, parochial, and innacurate opinion piece, "Keeping a lid on broadband," Computerworld national correspondent Kevin Mitchell has scathing criticism of current free market communications policies (that by the way were modeled after the computer sector's free market and innovation successes) and calls for government bureaucrats to regulate most everything of import in the communications sector.   

I am stunned that in the journalistic "world of computers" there could be such a naive and parochial view of the real-world ramifications of technological and digital convergence -- the rapidly blurring lines between computing, communications and storage. Mr. Mitchell writes like the tech sector and computing in general is an impregnable and immutable island that should forever be insulated and protected from competitive and market forces occuring outside the tech sector.

Remarks for the University of San Francisco Net Neutrality Symposium

January 26, 2008

Thank you for including me in this forum and debate on net neutrality.

• I have a very different point of view than most everyone on the panel save for Richard Bennett.
• Full disclosure, I am Chairman of NetCompetition.org which represents broadband companies on the issue of net neutrality.   

I believe net neutrality is largely a contrived issue and a fabricated “problem.”

·         The issue is on political life support in Washington, because it is all slogan and little substance.

We'll soon see if net neutrality proponents are reasonable and responsible. Do they grasp that calling for preemptive, anti-investment, regulation of broadband that would discourage deployment of broadband to all Americans -- is the last thing our Nation needs during this economic downturn?

• The reality is that forward-thinking broadband deregulation has spurred massive investment in broadband and Internet infrastructure in the U.S. and this investment is spurring adoption of broadband faster than any communication service in American history.
• Moreover, an unfettered broadband economy and infrastructure is key to capturing the economic and productivity gains of more universally-adopted broadband.

Broadband deployment, adoption, competition and investment is one of the great success stories of our economy.

• The last thing our teetering economy needs right now is preemptive, anti-investment, net neutrality regulation of our cutting-edge communications sector that would only hurt the overall American economy.
• This is no time for solutions in search of a problem.
• We face real economic problems which require responsible broadband policies.  

Kudos to some straightforward reporting by PC World in: "Comcast Welcomes FCC Traffic Management Inquiry," which is in stark contrast to the "guilty-until-proven-innocent" headline in AP Peter Svensson's story "FCC to Probe Comcast's data discrimination."  

PC World reporters and editors have clearly not made up their mind in advance of the FCC's inquiry, unlike the AP reporter and editors which clearly have. 

• What is most outrageous in the AP coverage of this story is that the reporter set up his own test of Comcast traffic management, concluded "expertly" that traffic management was wrong and should be prosecuted, and judged Comcast to effectively be guilty of "data discrimination."
  • The AP reporter and editors are no longer functioning as news reporters, but apparently have appointed themselves police investigators, prosecutors, judge and jury all in one.

The reason that Comcast welcomes the FCC's traffic management inquiry is that they are confident that they are managing their network reasonably to preserve the quality of service expected by all their users and are within the bounds of acceptable network management.

It is telling that the AP reporter who originally manufactured the story on Comcast's network managment practices, (through his own unscientific test) is the only mainstream reporter resuscitating this non-story.

Peter Svensson's AP story: "FCC to probe Comcast data discrimination" isn't news but an advocacy piece cloaked as a news story (see earlier post).

• At a minimum, the article should have been labeled a "news analysis" or an opinion piece.

It isn't "news" that the FCC investigates petitions.

Comcast's announcement at CES to offer a quicker system for downloading movies and shows as reported by the New York Times is strong proof of why the FreePress petition asking the FCC to not allow Comcast to manage the p2p traffic on its network -- is unreasonable. 

Comcast is innovating to enable its network to offer what it calls "wideband," which will enable Comcast customers to download HD movies on demand -- that previously took up to six hours to download -- to less than 4 minutes.

• This innovative Comcast service will begin to be available to some Comcast customers in 2008 and is planned to offer ~6,000 video on demand titles to the broader Comcast base after that.

The point I am making here is that any network has relative bandwidth chokepoints where traffic must be managed in order to deliver expected quality of service to all customers.

Washington Internet Daily reported that FCC Commissioner Robert McDowell told reporters yesterday:

• that "...he wants ISPs and P2P networks to come to terms on dealing with bandwidth-hogging downloads. Comcast’s approach drew a complaint to the FCC, but McDowell hopes companies can work things out without government intervention..."
• “We’ll just mess it up,” he said. “I strongly encourage private sector resolution.”
• It’s not necessarily anticompetitive for network operators to act to keep P2P traffic from slowing networks, he said. “That's good for consumers, because you don't want your network to shut down.”"

Well said.

Larry Downes produced an outstanding analysis for ZDNet today which he entitled "Save Internet Freedom -- From Regulation."

I strongly recommend it as it is one of the most cogent and persuasive pieces I have read in a long time on the subject.

He does a great service by putting the issue into much clearer context -- vis-a-vis other industries and past attempts to regulate where the government shouldn't have. 

Three times a year the Internet Engineering Task Force meets to discuss and work through major Internet issues.

• To my delight, one of the technical issues they recently discussed has great import to net neutrality and the FreePress petition on Comcast's reasonable network management.
• Kudos to Iljitsch van Beijnum who wrote "Growth of P2P leads IETF to debate "fair" bandwidth use" in ars technica.
  • His excellent article explains a new paper being debated by the IETF that raises the core question, if the voracious bandwidth appetite of P2P is "fair" to non P2P users.

The paper and the article point out that users of "unattended" P2P applications use dramatically more bandwidth than users of "interactive" applications like web browsing -- and then poses the question of whether this excess usage is fair. 

Van Beijnum points out that the paper's authors suggest that P2P users are using 500 times the bandwidth as average interactive users. Moreover, he points out that this assymetric bandwidth dynamic disincents an ISP from upgrading their network because the assymetry would make them even less competitive. 

The fundamental point here is a question of fairness.