Hello, http://www.earn-extramoney.info…

Interesting topic… I’m working in this industry myself and I don’t agree about this in 100%, but I added your page to my bookmarks and hope to see more interesting articles in the future…

I’m for rational discrimination, such as the discrimination against spam, DOS attacks, worms, viruses, and fattest-pipe abusers. “Discrimination” isn’t a dirty word in network engineering, it’s the essence of what we do.

The Internet Protocol has a field in each packet called the “type discriminator” that’s used to specify the payload, with values like TCP, UDP, BootP, and ICMP. Are you against “type discrimination?”

The sensible approach to regulation, in this sphere or in others, is to draft broad principles, set up an enforcement regime, and let case law evolve. The FCC currently has the “Four Freedoms” which were drafted in response to the Madison River case, the only documented case of arbitrary service blocking in the USA. These principles are part of the COPE Act, which also gives the FCC the authority to levy fines up to $500,000 per infraction. The Stevens Senate bill directs the FCC to do a study of provider abuses and report back.

Once we see some actual abuse that isn’t covered by these provisions, Congress will still be in the business of drafting laws and we’ll be able to go ask for whatever approach is necessary to solve the real problems. What you people are proposing is pre-emptive legislation that will most likely do to the Internet what Bush’s pre-emptive war did to Iraq.

I appreciate your sentiments, and firmly believe that you have good intentions. But I’ve worked with legislative bodies before and have seen the unintended consequences that can flow from legislation that’s guided by too much emotion and not enough information.

There’s no immediate crisis here so the best thing course of action is to simply gather information. We all want a “neutral” network that enables innovation to flourish, and the fact that we’ve never really had one shouldn’t discourage us.

Networks are technical artifacts that improve with time, and even the Internet is not so perfect that we should freeze it.

Or are you for discrimination?

Lightweight QoS of the DiffServ variety is an exercise in separating packets that have an actual need for low-jitter delivery from those that don’t have such a need. To put it in terms you might understand better, it’s like Affirmative Action. Some people come from the sorts of background where they need a little help. Others are fat, privileged, white, male, and heterosexual and obviously deserve no help.

Voice packets are like underprivileged black lesbian welfare mothers with disabilities. They’re smaller than bulk download packets, but they have to be delivered quickly or they wilt in the Summer heat. They can never be duplicated, because they’re very special. Download packets, on the other hand, are big and easily replaceable. They don’t care if they have to wait in the lobby for a while because they’re basically lazy and if you’ve seen one you’ve seen them all. Mostly, they’re just patches for Windows security bugs anyway, and it doesn’t matter if you install them today or tomorrow.

That’s what QoS is about.

Wu argues against blanket rules on what the carriers can and can’t do, such as the open access rule. This rule — common carrier treatment of DSL — simply stifled investment in the last mile. Cable was less regulated and it’s a better network. Wu says these issues are so complex that they have to be carefully scrutinized. We may know enough about the 21st Century Internet at some point to draft broad rules, but we certainly don’t today, when all we have to go on is rumor, panic, and hysteria.

I hope this helps you see some of the more egregious drafting errors in your bill, most of which are actually conceptual errors in grasping the requirements of the 21st Century Internet.

If the bill is not making a distinction with the term “public,” I think it is important to understand its affect on NSPs currently providing QoS fees to businesses. As you pointed out, the NSPs would have to stop charging for QoS, but what does that mean? Do NSPs stop providing enhanced QoS? Do they simply adjust their pricing schedule? What happens? (This is an earnest question. I do not know the answer, so please be patient with me.)

As for Professor Wu’s vision of net neutrality: He argues in favor of a nondiscrimination principle that would preclude the ISPs from using their market power in wireline ownership to give them an advantage over competitors in the Internet content/applications/services markets. One way for ISPs to discriminate is to charge QoS fees to their competitiors, which could squeeze out most or even all of them, because their competitors would face higher costs. The ISPs would not have to pay QoS fees (who would they pay QoS fees to?), while their competitors would. Professor Wu has argued in favor of QoS tiering, a practice which could make more efficient use of available bandwidth. However, I have not read where he has endorsed QoS fees. If you think Professor Wu is in favor of QoS fees, it is your burden to reconcile QoS fees with the nondiscrimination principle for which he has advocated.

It’s not specific as to what market the “broadband network provider” serves, is it?

This provision is the most massive over-reach in the name of antitrust in the history of the United States, dude. It doesn’t just say that you can’t charge some applications for a given QoS level and not others - Wu’s issue - it says you can’t charge anybody for QoS anywhere at anytime.

Total baloney.

Do you not know that business Internet users can buy service from a number of NSPs with jitter guarantees today? I’ve listed some of them already, so go re-read my comments. It’s boring to answer the same question over and over just to have you say you don’t understand.

However, you have also touched on another of my concerns about the bill: commercial access. Like I said, the legislation is targeted at “last mile” residential access (based on the congressional hearings), but, as you argue and I hinted at, its language might be too broad. Can you explain how “Business Internet users can buy QoS today” and how the legislation would prevent them from continuing to do so? A word of caution: The answer might involve interpreting the word “public” as it is used in the definition of “broadband service provider.”

You also suggest that the legislation would preclude an ISP from cutting off a user when the user exceeds his subscription for low-latency applications. Could you explain that? Citations to the text would help.

BTW “legislation” is an ambiguous word that can refer to either a bill or enacted law. (Look it up.) I used “draft” to make clear that the bill is still subject to revision and has not been enacted.

This is a very important distinction that goes to the heart of the Save The Internet Coalition’s misunderstanding of network neutrality. There is nothing sacred about bandwidth that should make it the only allowable differentiator for service tiering purposes. It’s simply one of three dimensions of network performance that are crucial to this debate; the other two are latency and jitter.

You say: “The draft legislation is targeted at “last mile” facilities owners, which, without regulation, could filter out, degrade, or charge cost-prohibitively high fees to competitors’ voice and video services (assuming that the FCC has overstated its authority under Title I).”

In the first place, what is this “draft legislation” nonsense? A bill has passed the House Judiciary, and that puts it beyond “draft” stage. In the second place, the plain language of that bill is such that it’s not limited to the “last mile” in residential access, it apples to ALL broadband links, even those run today by NSPs that supply QoS for a fee. It’s a radical change in the way the Internet is regulated, completely unprecedented in its scope and its destructive effects. Business Internet users can buy QoS today, and many do; under this law, that would be prohibited and companies like Global Crossing and WebEx would be out of business. The authors of this bill didn’t practice essential principles of statutory construction and went for an overly broad approach that criminalizes vast swathes of the Internet of today.

Now on the final point, QoS depends on strict traffic limits in the low-latency class, and these are enforced on real networks by adjusting priority when the user over-uses his subscription. The Judiciary bill prohibits this practice and therefore makes QoS illegal, even free QoS.

This poorly-constructed mess of a bill illustrates the danger of trying to regulate a complex system that the would-be regulator doesn’t understand, and it would be a total disaster to the Internet if it were to become law.

You say you want a neutral Internet? Fine, and dandy, so do I. But how can you support Lofgren’s bill when it doesn’t go in that direction at all?

However, he is also opposed to QoS fees. By QoS fees, I mean new fees based on the specific applications or services rather than fees based on bandwidth usage (which are currently charged). Professor Wu supports rules that “ban abusive behavior like tollboothing and outright blocking and degradation.” Hearing on Network Neutrality before House Committee on the Judiciary, 109th Cong. (Apr. 25, 2006) (statement of Professor Wu). Further, he suggested a neutrality principle with Professor Lessig that would prohibit ISPs from filtering specific content except for those who pay a supplemental fee. See Lessig & Wu, Ex Parte Submission in CS Docket No. 02-52 at 15 (Aug. 22, 2003); see also Tim Wu, Network Neutrality, Broadband Discrimination, 2 J. Telecomm. & High Tech. L. 141, 149 (2005). To sum up: prioritization based on application type: good; QoS fees: bad.

Richard, for me to understand, you have to elaborate as to why the legislation would kill QoS for everybody. I understand that in theory if th elegislation passed and everyone decided to provide live video from their home computers, that the QoS-dedicated bandwidth would get jammed, and no one would be able to get quality video. But I am not sure that this concern is warranted. There doesn’t seem to be that many video providers. If and when that happens, perhaps we will have enough platform competition (from satellite, etc.) that we can abandon net neutrality legislation altogether.

rgiskard has begun to answer my question by raising the peering issue. The draft legislation is targeted at “last mile” facilities owners, which, without regulation, could filter out, degrade, or charge cost-prohibitively high fees to competitors’ voice and video services (assuming that the FCC has overstated its authority under Title I). But I am curious as to the draft legislation’s potential effect on Tier 1 relationships. I am not sure whether or how the legislation would impact the arrangements among the various Tier 1 players, and any thoughts would be appreciated.

I also have a few questions about rgiskard’s proposal. Are you suggesting mandating and regulating QoS? For QoS to work well, QoS provisions probably would have to be in the peering agreements, but couldn’t that be worked out without regulation? The ISPs are interested in providing their own content with QoS assurances, and to do so under the draft legislation, they would need to work out QoS arrangements with other Tier 1 providers.

Further, rgiskard suggests voluntary, fee-based QoS agreements. Are those arrangements between (1) ISPs and unaffiliated content providers or (2) among ISPs? If the former, is that only for companies who want priority higher than the government’s standard prioritization for that particular type of content?

The downtime problem in peering relationships is significant, but I would like to defer that discussion for right now and focus on network neutrality.