Richard Bennett & George Ou filings on network management

I wanted to make sure that everyone saw the filings that Richard Bennett and George Ou made this week to the FCC in the proceedings regarding broadband network management policies. They are excellent. [Richard and George have both been guests on the TLF podcast and discussed these issues here and here in detail.] I thought I’d clip a few of the highlights here, but make sure to read them all the way through.

Here’s some of what Richard had to say:

The four prongs of the Policy Statement do not include a “right to be free of delay” or a “right to
infinite bandwidth”, and in the real world someones ox must be gored when the load offered to a
network segment exceeds its capacity. Hence, the petition for declaratory ruling must be
rejected.
[…]
So this is the choice that Comcast has on its network of today: should it allow a handful of
BitTorrent users to degrade the performance of VoIP and web users to the point of distraction, or
should it limit the bandwidth that BitTorrent users can consume? This is not a hard choice to
make, and the only interesting implications it has concern methods employed and obligations for
disclosure owing to the customer.
[…]
If ISPs have the freedom to experiment with different methods and business models, and
consumers have reasonably broad choices, the market will sort this matter out. Hence the policy
priority should be the promotion of market-based competition between Fiber, DOCSIS, DSL, and
wireless.
[…]
It’s worthwhile to point out that Internet2 schools practice traffic shaping and policing on their
campus networks, for the same reasons that public carriers such as Comcast do: it’s not
economically feasible to build networks around the excessive bandwidth appetites of a few users.
[…]
There are alternative methods and policies that may be employed by ISPs to address problems of network congestion and overload; the market should decide among these, not the government.

Here’s some of what George had to say:

Given the fact that the petitioners don’t actually dispute the right of Comcast or any other network provider to reasonably manage their network and throttle down excessive uploaders, the only thing in dispute is the methodology used to achieve these goals. I’ve highlighted all the proposed alternatives along with the pros and cons of each solution and I’m confident that the one already in use by Comcast is the least intrusive, least expensive, and most practical way of dealing with the realities of a DOCSIS 1.1 broadband network.

Market forces in the form of competition are forcing Comcast to upgrade to a much higher performance and more symmetrical DOCSIS 3.0 network and that is a win for the consumer. But regardless of how fast the network is, there will always be a need for practical network management solutions that ensure per-user fairness and not per-session fairness. The last thing we should do is force Comcast to implement more expensive and/or less fair traffic management schemes that at best wastes money and at worst degrade performance for consumers who are using far less than their fair share of bandwidth.

Again, make sure to read both filings. Also, over on his blog, Richard highlights some of other filings in the matter.

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