LARIAT comments to the FCC regarding Comcast

[David Farber <dave () farber net>]

________________________________________
From: Brett Glass [brett () lariat net]
Sent: Thursday, February 14, 2008 2:18 PM
To: David Farber; Ip ip
Subject: LARIAT comments to the FCC regarding Comcast

Dave:

For IP, if you will. The following comments were submitted by me and my company, LARIAT, in response to the FCC's 
Notice of Inquiry regarding network management practices, P2P mitigation, and the Vuze and Free Press petitions.

--Brett Glass

P.S. -- You may be amused to find that several of the comments (e.g. Qwest's) quote you or refer to your work. Some 
also quote or cite publications by your colleague Jon Peha at CMU.

BEFORE THE
Federal Communications Commission
WASHINGTON, D.C.

In the matter of                 ) WC Docket No. 07-52
Broadband Industry Practices    )

Laurence Brett (“Brett”) Glass, a sole proprietor doing business as LARIAT, a wireless Internet service provider in 
Albany County, Wyoming,  responds to the Public Notices issued by the FCC’s Wireline Competition Bureau on January 13, 
20081 with the following comments. He further prays for dismissal of the Petition for Declaratory Ruling and Petition 
for Rulemaking filed by Free Press et al and Vuze, Inc., respectively.2 This document, which contains corrections of 
minor typographical and grammatical errors, supercedes and replaces an earlier comment also submitted on February 13, 
2008.

1. INTRODUCTION AND SUMMARY

LARIAT was among the first, if it was not the very first, of the approximately 8000 wireless Internet service providers 
(WISPs) now doing business within the continental United States. With more than 15 years of experience and an 
Electrical Engineer (MSEE Stanford 1985) at the helm, LARIAT provides high quality broadband Internet to a large and 
growing service area, less than 5% of which has access to “wired” broadband options (e.g. DSL or cable modem service). 
It also competes gamely with much larger providers – including Bresnan Communications and Qwest – in the few more 
densely populated areas of Albany County where these services are deployed.

While LARIAT has been severely disadvantaged by current spectrum allocation policies, which make it impossible for any 
small ISP to obtain licensed radio spectrum at a reasonable cost, it has nonetheless been able to employ careful 
engineering and unlicensed (Part 15) spectrum to provide service to areas which other providers cannot reliably reach.  
It likewise employs sophisticated technological solutions – including P2P mitigation, traffic prioritization, and 
caching – to provide customers with fast, economical service despite the extremely high cost of Internet backbone 
bandwidth in Albany County, where wholesale monthly charges range from $100 per megabit per second (Mbps) to several 
hundred dollars per Mbps.

Petitioners, as well as commenters who advocate of an overly expansive definition of  “network neutrality,” are in 
essence asking the FCC to ban these technologies. However, these technologies constitute reasonable network management 
and are vital to keeping networks running smoothly – often in the face of attempts, by computer hardware and software, 
to monopolize and/or abuse them.

Should the FCC mandate that small, independent, and/or rural ISPs cease to employ these and similar technological 
measures to ensure the quality of their service,  many or most small, local operators would have to raise prices 
dramatically or quit business.

47 USC § 230(b) states that it is the policy of the United States to “promote the development of the Internet and other 
interactive computer services and other interactive media” – and also “to preserve the vibrant and competitive free 
market that presently exists for the Internet and other interactive computer services, unfettered by Federal or State 
regulation.” Regulation and micromanagement of Internet service providers would be contrary to this policy and would 
hinder innovation and broadband deployment.

2. DISCUSSION

Both the Vuze Petition and the Free Press Petition ask the FCC to prohibit network management practices such as the 
prioritization of certain forms of traffic and restrictions on the use of so-called peer-to-peer (P2P) protocols – 
including, but not limited to, BitTorrent. This discussion will explain why prohibitions on reasonable network 
management could hobble or preclude the deployment of many useful Internet applications, such as VoIP. It will also 
explain the economic motivations of Vuze and similar companies who may petition the Commission to force ISPs to allow 
unfettered use of P2P.

....

Full text:

http://tinyurl.com/2wf6nd

Other noteworthy comments:

Time Warner Cable
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519841176

CTIA
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519841180

-------------------------------------------
Archives: http://www.listbox.com/member/archive/247/=now
RSS Feed: http://www.listbox.com/member/archive/rss/247/
Powered by Listbox: http://www.listbox.com