NNSquad - Network Neutrality Squad
[ NNSquad ] Some Comments on the National Broadband Plan (Part 1 and 2)
(Part 1:)
This is the single part of the National Broadband Plan that most
matters:
Broadband as a Transformative General Purpose Technology:
> http://broadband.gov/plan/innovation-and-investment.html
"As economists Timothy Bresnahan and Manuel Trajtenberg
explained in a 1995 paper, ?Whole eras of technical
progress and economic growth appear to be driven by a few
key technologies, which we call General Purpose
Technologies (GPTs). [. . .] GPTs are characterized by
pervasiveness [. . .], inherent potential for technical
improvements, and innovational complementarities [. . .]
Thus, as GPTs improve they spread throughout the economy,
bringing about generalized productivity gains.? The report
continued, ?As use of the GPT grows, its effects become
significant at the aggregate level, thus affecting overall
growth.? [. . .] The Internet has the characteristics of a
GPT."
However, the Plan simply calls "broadband" in general a
"Transformative General Purpose Technology" and shows no indication of
distinguishing general purpose connectivity from other types of
connectivity that would also fall under "broadband."
If the FCC were really committed to "network neutrality" they would
draw this distinction, and would take this opportunity to articulate
how NN is affected by and relates to numerous concerns which I list
below from their document. All of their network innovation
recommendations are astroturf/con job friendly.
See the recommendations at:
http://broadband.gov/plan/4-broadband-competition-and-innovation-policy/
No mention is made of distinguishing general purpose connectivity from
other kinds of connectivity in relation to:
1) collecting data on availability, penetration, prices,
churn and bundles
2) technical broadband measurement standards to be
developed with NIST. The technical issue they present
is not of how general purpose connectivity compares to
other kinds, but instead how to measure public
Internet, middle mile, 2nd mile and last mile sections
generally. They propose establishing a Broadband
Measurement Advisory Council, but they make no mention
of distinguishing a general purpose platform and other
types of connectivity in relation to that body's
purpose
3) measuring and publishing data on actual performance of
fixed broadband services
4) performance disclosure requirements (their presentation
on this is distinctively painful, as the "Broadband
Performance Label" they present actually presents
"typical uses" -- i.e., what applications a particular
"broadband" service is optimal for)
5) broadband performance standards (for categories such as
mobile, multi-unit buildings and small businesses)
6) competition in wholesale broadband markets and a
proposed comprehensive review of wholesale competition
regulations
This is simply not the sort of document an administration really
committed to "network neutrality" would have taken this opportunity to
present.
There is a sort of light in Recommendation 4.10, on clarifying
interconnection rights:
http://broadband.gov/plan/4-broadband-competition-and-innovation-policy/#r4-10
"The FCC should confirm that all telecommunications
carriers, including rural carriers, have a duty to
interconnect their networks."
. . . and the FCC actually signals their intent to contest a court
ruling contrary to this conclusion!
HOWEVER, unfortunately, this is presented in connection with a
transition to IP-to-IP (as in away from copper, addressed in
Recommendation 4.9), so we have a NBP that is weak on NN while also
continuing to facilitate the elimination of shared-line copper.
Valorizing a transition to IP-to-IP in the context of this plan is
therefore troubling, not encouraging. Remember that the Internet
exploded when it went public *because of those shared lines.*
This is Kevin Werbach's Title II interconnection point, but it's being
used to rationalize removal of the vestiges of the line-sharing
regulatory framework. In a plan that does not adequately articulate
what's at stake.
Wasn't it interesting how the media started putting out those stories
about how the incumbents want to and need to unburden themselves of
copper? Remember, we're living in an astroturf/disinfo world!
(Above notes prepared yesterday, Part 2 follows:)
---
Benchmarking: "Broadband" Performance Dashboard
> http://broadband.gov/plan/17-implementation-and-benchmarks/#s17-2
"The FCC needs to collect more detailed and accurate data
on actual broadband availability, penetration, pricing and
network performance in order to accurately benchmark
progress toward plan goals. Only with these data inputs
can the FCC publish a Broadband Performance Dashboard."
All the FCC had to do to set the course right and set the discourse on
the right terms, was to state that the general purpose nature of the
Internet was critical and needs to be a key goal of the plan. General
purpose connectivity is the *most advanced* "telecommunications
service." "Managed services" are optimized for particular
applications, like graphics cards, whereas the Internet is like your
computer, a general purpose logic device.
All they had to do. Then the NN debate would no longer be a source of
confusion. They didn't have to set it as a specific goal (given that
their enabling legislation didn't necessarily call for that), but they
certainly could have stated that that was the stakes so we need to
measure that.
Nothing in the benchmarks (or goals) says anything about the general
purpose nature of the Internet platform. No attempt is made to make
that distinction.... See More
Instead, they call "broadband" in general "Transformational General
Purpose Technology" -- setting the stage for lumping everything with
overall speed over 4Mb together as if it were all "general purpose."
They can clearly cite characteristics such as permissionlessness,
application-independent transmission of packets, best efforts
delivery, servers allowed, all ports open, congestion management by
packet drop signaling and provision of capacity, etc. as designating a
general purpose platform. The key is to understand that general
purpose connectivity is what's at stake in the NN debate, and make the
task about identifying what defines general purpose connectivity and
what doesn't. The FCC didn't have to do anything more than say that --
recommend that we track general purpose connectivity -- and let the
discourse proceed from that point, with all the slings and arrows the
disinfo practitioners can attempt to muster.
To their credit, I did note one mention of permissionlessness
somewhere, I think in the network innovation recommendations.
The "NN" movement should now be pressing full court for that line: the
NBP needs to have a goal of fostering, or at minimum tracking, a
*general purpose platform" -- not blankly expostulate about
"broadband" being "transformational general purpose technology" --
especially with no practical component connected to that.
I see nothing about the general purpose nature of the Internet
platform in any other section, either. There's just that one box about
"broadband" in general on the Innovation and Investment page. Nothing
in Availability, Utilization, Economic Opportunity. Network
Innovation, as I described. Etc.
Nothing at all under Current State of the Ecosystem, in all the talk
about specific types applications (lots of talk about video) and
devices (and networks, adoption and utilization) about how the
("transformational!") general purpose nature of the platform is the
key to the proliferation of all these applications. The network
section is all about speed. The talk about "actual" speed being about
enduser experience is troubling, as it may signal QoS ("managed
services") reasoning.
Research and Development mentions a National Academies roadmap, but
says nothing about what's at stake beyond an abstract call to develop
metrics for Internet "health." It does talk about establishing a
Research Center that should be governed by FCC open network
principles.... See More
It's weird -- like they just stuck that "Transformational General
Purpose Technology" box in under Innovation and Investment as an
afterthought.
Let's hold them to it! This is how to win! :-)
Seth