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Re: Defining Broadband as General Purpose Platform
From: David Farber <dave () farber net>
Date: Wed, 2 Sep 2009 19:34:35 -0400
Begin forwarded message: From: Seth Johnson <seth.johnson () RealMeasures dyndns org> Date: September 2, 2009 3:38:03 PM EDT To: dave () farber net Subject: Defining Broadband as General Purpose Platform Reply-To: seth.johnson () RealMeasures dyndns org (Hi David -- You can put this out on IP if you wish. -- Seth) Comments - NBP Public Notice #1 GN Docket Nos. 09 47, 09 51, and 09 137 Regarding the Definition of "Broadband" By Seth Johnson The National Broadband Plan must define "broadband" according to a proper and full concept of what capabilities constitute "advanced telecommunications service." Broadband in this conception is constituted of two things: 1. a general purpose platform (in this document generally associated with the term "Internet" and its consensus protocols) which is optimized for maximum flexibility and application innovation, and 2. certain other functions that may optimize particular applications but that may compromise the flexibility of the general purpose platform. See RFC 4924, "Reflections on Internet Transparency" (http://www.rfc-editor.org/rfc/rfc4924.txt): A network that does not filter or transform the data that it carries may be said to be "transparent" or "oblivious" to the content of packets. Networks that provide oblivious transport enable the deployment of new services without requiring changes to the core. It is this flexibility that is perhaps both the Internet's most essential characteristic as well as one of the most important contributors to its success. "Architectural Principles of the Internet" [RFC1958], Section 2 describes the core tenets of the Internet architecture: However, in very general terms, the community believes that the goal is connectivity, the tool is the Internet Protocol, and the intelligence is end to end rather than hidden in the network. The current exponential growth of the network seems to show that connectivity is its own reward, and is more valuable than any individual application such as mail or the World-Wide Web. This connectivity requires technical cooperation between service providers, and flourishes in the increasingly liberal and competitive commercial telecommunications environment. "The Rise of the Middle and the Future of End-to-End: Reflections on the Evolution of the Internet Architecture" [RFC3724], Section 4.1.1 describes some of the desirable consequences of this approach: One desirable consequence of the end-to-end principle is protection of innovation. Requiring modification in the network in order to deploy new services is still typically more difficult than modifying end nodes. The counterargument - that many end nodes are now essentially closed boxes which are not updatable and that most users don't want to update them anyway - does not apply to all nodes and all users. Many end nodes are still user configurable and a sizable percentage of users are "early adopters," who are willing to put up with a certain amount of technological grief in order to try out a new idea. And, even for the closed boxes and uninvolved users, downloadable code that abides by the end-to-end principle can provide fast service innovation. Requiring someone with a new idea for a service to convince a bunch of ISPs or corporate network administrators to modify their networks is much more difficult than simply putting up a Web page with some downloadable software implementing the service. RFC 4924 proceeds to list developments that may affect the advantages of the Internet's general purpose design based on the end-to-end principle and the transmitting of packets without regard for the application they are supporting, including: * Application Restrictions * Quality of Service (QoS) * Application Layer Gateways (ALGs) * IPv6 Address Restrictions * DNS Issues * Load Balancing and Redirection * Security considerations The principle of transmitting Internet datagrams without regard for the applications they support also provides for "network neutrality" as an emergent phenomenon. In addition, RFC 4084, "Terminology for Describing Internet Connectivity" (http://www.rfc-editor.org/rfc/rfc4084.txt) provides a useful description of what constitutes "full Internet connectivity," considering this question with regard to its design for flexibility, including stipulations about functions that should be disclosed to the purchaser if they are deployed. RFCs 1958, 2775, and 3724 more fully describe these issues that arise as various functions are proposed that may affect the Internet's design for greatest flexibility. The Dynamic Platform Standards Project's legislative proposal for an "Internet Platform for Innovation Act" (http://www.dpsproject.com/legislation.html) recognizes the advantages of the design of the Internet Protocol. The DPS proposal provides a technical characterization of the general purpose platform provided by the Internet Protocol, including its provision of uniform treatment of packet flow. Recognizing and treating this general purpose platform as a distinct category allows the particular advantages for which it was designed to be acknowledged and provided for within the regulatory scheme while other telecommunications functions may be offered by network providers under the general term of "broadband" (and may eventually become part of consensus standards). This document only seeks to present some initial comments regarding the relevance of the general purpose platform to the questions raised in this request for public input. Here we refer chiefly to the design of the Internet according to consensus standards. However, it is worth noting that a general purpose platform can also be afforded by means of the principle of common carriage. Indeed, some might hold that the general scheme of digitizing communications into packets delivered on a best efforts basis regardless of application, in accordance with the Internet Protocol, is a natural outcome and a self-evidently necessary means for providing for interoperability and flexibility among the autonomous routers that were originally administered by thousands of competing Internet Service Providers on the basis of a common carriage principle. The general purpose platform must be a key component of the plan for using broadband infrastructure and services in advancing the full range of national purposes enumerated in section 6001 (k) (1) of the ARRA, and must be recognized as a key consideration in what constitutes "broadband capability." The status of deployment of "broadband" in your reporting should present the deployment of a general purpose platform as a distinct category from other types of advanced telecommunications service which may also be deployed, using the consensus definitions given in relevant RFCs as an analytical aid. A flexible, general purpose platform also contributes to the strategy for maximizing utilization since a platform that optimizes flexibility to make possible a proliferation of innovative applications incentivizes participation in connectivity. The general purpose platform should also be borne in mind in relation to the strategy for affordability, which should be developed with consideration of the issues of recourse and enforcement that arise in the context of public expeditures when contractual expectations related to such a platform are not met. A clear distinction should be maintained in your reporting and pursuit of national goals, between this general purpose, neutral platform and optimized telecommunications services that may diverge from the principles that provide for optimum flexibility and neutral transport. As part of the dynamic process of adapting benchmarks over time, the FCC should consult with experts and the public on 1. what constitutes the general purpose platform, 2. what innovations are recognized as not interfering with general purpose, 3. which may interfere with general purpose but are of value to some purchasers, and 4. in this last category, which functions should become a basis for a category of "consumer connectivity" rather than general purpose Internet connectivity. In addition, the FCC should consult with experts and the public on which functions or features should require explicit notice and consent given privacy considerations (as well as what form of consent is adequate for that purpose). Some additional important considerations the FCC should be mindful of are the implications of packet inspection, packet discrimination, data collection and end-user privacy, as well as the question of whether advertised services perform as specified, perhaps taking input from other appropriate agencies. Recourse and enforcement related to these concerns may be appropriate considerations. General comments on Benchmarks: Benchmarks should exhibit and track the rapid evolution both of the general purpose platform of the Internet and of broadband as a general term that may include other types of offerings. The widespread adoption of new Internet-based applications will affect what "advanced" means to purchasers of broadband, but this should not be construed as indicating that special optimization features that some providers may offer must equate with advanced telecommunications without consideration of their impact on the general purpose platform. "Dependability" and "experiential" metrics must be considered carefully in relationship to the advantages of a maximally flexible general purpose communications platform, as some functions that may improve these aspects for particular purposes may impair the general purpose character of the platform. In considering "the availability of advanced telecommunications capability to all Americans", broadband infrastructure data may be more objective than subscriber data, but data should be collected regarding general purpose connectivity as a distinct category, and the analysis should present availability in those terms in addition to the ease with which high speed can be deployed. Similar considerations apply in the analysis of utilization. "Broadband" and "advanced telecommunications capability" may be defined by statute as independent of "any transmission media or technology," but this does not mean that an analysis of advanced telecommunications capability should exclude describing the characteristic of a general purpose platform as a key category. Thank you. Seth Johnson (From http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=7020037177 ) ------------------------------------------- Archives: https://www.listbox.com/member/archive/247/=now RSS Feed: https://www.listbox.com/member/archive/rss/247/ Powered by Listbox: http://www.listbox.com
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- Re: Defining Broadband as General Purpose Platform David Farber (Sep 02)