A Lack of Understanding August 23rd, 2010

Google and Verizon’s open Internet legislative proposal has prompted a flurry of media attention, even earning a spot on Comedy Central’s The Daily Show with Jon Stewart.

Some members of the tech press and self-proclaimed tech pundits are doing a disservice to their readers and viewers by mischaracterizing the proposal. One wonders if some reporters have even read the seven principles the companies laid out in their joint policy proposal.

For instance, over the weekend, CNN’s Max Kellerman invited Luria Petrucci (AKA Cali Lewis) , a Dallas-based social media and technology blogger, on to appear on a segment to discuss net neutrality.

Petrucci seemed not to have read or understood the Google-Verizon proposal. During the segment, Petrucci was asked by Kellerman why ISPs might be opposed to net neutrality. She replied: “Companies that own the fiber that we use to connect to the Internet want to prioritize traffic and take money from people who can afford it.”

If Petrucci had read the Google-Verizon proposal, she would have found it recommended that blocking or degrading of content be prohibited, non-discrimination of content be enforced and prioritization of Internet connections be banned.

In reality, the proposal embraces much of what net-neutrality activists have demanded.  In fact, the non-discrimination provisions and bans against prioritization in the proposal are stronger than the principles already in place at the FCC that the ISP community has already agreed to follow.

The debate over regulating the Internet is challenging enough that we should all take the time to be sure we fully understand all the proposals that are out there.

Global Telecoms to Become a Cloud Computing Force August 20th, 2010

Independent telecom analyst Ovum predicts that the major global telecommunications providers will become a powerful force in cloud computing.  AT&T, Verizon Business, British Telecom, Orange Business services and several other global providers have already made significant strides in building out their cloud computing data centers and backbone networks.

These global providers are now able to compete with the leading IT cloud computing firms and will be in a position to attract previously cautious cloud computing end users. Peter Hall, the report’s author, states: “The major telecoms have a long heritage in providing managed data center services. They have combined this with their networking and security expertise to meet the needs of customers for cloud computing services.”  However, many of these providers are still in the midst of developing their cloud computing strategies and service road maps. Ovum expects to see a rapid rise in cloud computing interest over the next 2-3 years, so the time is right for telecom providers to be entering the cloud computing market.

Read more about the report here.

Long Live the Web August 19th, 2010

Chris Anderson, the editor in chief of Wired magazine, recently made waves with a cover story titled, “The Web Is Dead. Long Live the Internet.”, which claims that the web is dying, replaced by apps that run on semi-proprietary platforms instead.  Not surprisingly, the story has generated considerable reaction and commentary, much of it critical of Anderson’s basic premise.

Even the accompanying chart in the story– characterizing web use in sharp decline, and depicting video as a separate category that has spiked in recent years — is being challenged.  As many critics of the article point out, video has ascended quickly, but it is websites like YouTube and Hulu that support much of this traffic.  Also, in most cases, apps rely on the Internet to operate – and are thus inextricably intertwined.  So the data in the Wired chart is misrepresented, showing web traffic as a declining portion of overall Internet traffic in the United States.  In reality, the data shows rapid growth of online traffic across the spectrum over the past two decades, including the Web.

As with the evolution of other industries, the Internet and its many functions and applications are becoming increasingly specialized.  Need a map?  You can check a website on your laptop or use an app designed for the purpose that connects to the Internet to deliver directions to your destination.  Want to read a book or catch up on the news?  There are specialized devices today that can help with that, downloading those resources from the Internet.

So in essence innovators have cast a wider web, one that is connecting to the Internet in new and different ways.  That certainly doesn’t mean the web is going away.  Rather, it’s evolving in leaps and bounds.

New Outage Reporting Rules Not Needed August 4th, 2010

The FCC’s proposal to expand reporting requirements for broadband service outages would duplicate existing rules that assure vital telecommunications links during emergencies, USTelecom told the Commission in comments filed this week. The rules now in place require traditional telephone service providers to report outage incidents to the FCC bureau that is in charge of making sure the telecommunications services are available during public emergencies. The FCC would like to expand reporting requirements to broadband Internet service providers (ISPs) and voice-over-Internet protocol (VoIP) providers.

In its submission, USTelecom noted mandatory reporting rules for broadband providers are an unnecessary and wasteful burden because the proposed reporting requirements would essentially be duplicative to measures already taken by our members.

The industry believes it is essential that consumers have reliable broadband services during national emergencies, local disasters and public health crises. Broadband providers are committed to meeting this goal, and have spent billions of dollars to build networks that are resilient. Disruptions not only cause inconvenience, they can cost businesses to lose customers and money. This is why guarantees of service are routinely included in service level agreements between network providers and enterprise customers.

Today’s broadband networks have a strong track record of reliability. The Department of Homeland Security said in a 2007 report that 9/11 and the 2005 hurricanes proved the overall resiliency of the national communications network. The report said that “[d]espite the enormity of these incidents, the network backbone remained intact.”

Broadband providers have strong incentives to make sure networks are reliable. Instead of adopting additional rules that are not needed, the commission should become more involved in collaborative forums with industry and expert agencies working on security and network efficiency strategies.

Cybersecurity and the FCC August 3rd, 2010

The Department of Commerce has just begun what promises to be a fascinating look at the intersection of cybersecurity and Internet innovation, recognizing the threat that cyberattacks play to the growth and usefulness of the Internet. The Department’s Internet Policy Task Force includes experts on cybersecurity, communications policy, intellectual property, international trade and business who will take a deep dive into evaluating how to harness governmental, industry and academic resources to improve cybersecurity consistent with enabling continued growth in Internet innovation and commerce.

The Department’s broad and thoughtful approach to this issue is to be commended. Something that could upset the apple cart, however, is the current FCC’s rush to judgment that may effectively strip intelligence and computing power from broadband Internet service.  This includes the intelligence necessary to defend consumers and businesses against cyberattacks.

A recent FCC notice that proposes to apply old-fashioned telecommunications regulations to the Internet depends on classifying a “transmission component” of broadband Internet service as a “telecommunications service,” which, under the governing statute, must exclude computer processing capabilities as well as any capabilities to store, process or transform information. Yet it is only because of sophisticated computer analysis, information storage, processing and transformation that cyberthreats can be identified and mitigated. Tomorrow’s broadband Internet consumers are likely to require more and more tightly integrated security as threats evolve.

The “Title II” proposal, which appears to have substantial support among FCC commissioners, raises some difficult and complex questions.  If security can’t be included in their broadband service, how and where will consumers obtain security capabilities?  Will broadband providers be allowed to bundle any free security software with the broadband service they offer consumers and businesses?

The Department of Commerce is rightly enquiring into whether businesses and consumers have sufficient incentives today to invest in the right levels of Internet security.  Can it really be in the public interest to shift more of the security burden to consumers to cobble together, maintain and pay separately for their own security solutions?  And won’t this shift make it more likely that those consumers that cite security concerns as a reason not to adopt broadband will continue not to participate in the broadband Internet?

Surely the FCC needs to provide more details and ask more than a single question about security features and spam filtering in a 48-page notice to receive the informed public comment that it needs to understand how this proposed course may affect the security of the Internet today and in the future. The Department of Commerce is investing in a thorough and thoughtful approach to these difficult cybersecurity issues, an approach the FCC would do well to emulate.

Uphill Climb for FCC on Broadband Internet Regulation July 16th, 2010

As it embarks on a radical restructuring of regulation on broadband Internet services, the FCC claims it is NOT regulating the Internet. This begs the question of how you define “Internet.”

According to our analysis, recently provided to the FCC in comments on its proposed new regulations, broadband service and networks are an integral part of the Internet. Regulating broadband service separately, as the FCC proposes, IS regulating the Internet.

To justify its plan, the commission engages in “semantics,” our comments say. The agency is attempting to draw arbitrary lines between “Internet connectivity service,” and a host of other things it says it won’t regulate. These include applications and content, backbone infrastructure, content delivery networks, video services and voice-over-Internet-Protocol telephony services.

This approach “ignores countless and well-established definitions of what constitutes the Internet,” to quote our comments. Nearly every available definition of the Internet settles on the premise that whatever the Internet “is” – it includes broadband networks and Internet connectivity service. So if you are taking a regulatory aim at broadband networks, your target encompasses what is understood to be the Internet.

Why go down this road?  It’s not clear. Abundant economic data suggest the broadband market is doing just fine. A regulatory response is understandable when there is a clear market failure, but none of the available data suggest the broadband market is failing.  To the contrary, private capital investment has been consistently growing since the beginning of the decade. The FCC’s own National Broadband Plan found that 95 percent of the U.S. population has access to broadband services, and 82 percent have a choice of providers.

We advise proceeding very cautiously.  The commission is introducing needless complexity and confusion, rather than creating certainty in the broadband marketplace. Our advice to the FCC:  “The proposal to change regulatory frameworks must face a very high bar in demonstrating how the public interest in jobs, economic growth and social welfare could possibly be served by changing a regulatory paradigm that has been so successful for consumers and the United States economy.”

Illinois Urges Smart Grid Collaboration June 23rd, 2010

The Illinois Commerce Commission (ICC) is urging power companies and communications service providers to work together to write network proposals before any public utility sends the ICC a smart grid cost recovery filing, according to a recent story in Smart Grid Today. While at the DOE’s headquarters in Washington, DC, Illinois Commissioner Sherman Elliott said that regulators prefer a menu of communications options, rather than a summary of how much it would cost a utility to build a smart grid communications network on its own.

“Determining the “least-cost option” for a smart grid rollout often proves difficult if a regulator is not given sufficient data,” he said.  A regulator’s job is made much easier in these types of rate proceedings when telecom firms join with a utility to provide information on how they could install a smart grid communications network and at what cost, he asserted.  “This type of dialogue and information is extremely important for regulators,” he added.

DOE General Counsel Scott Harris said he often hears that power utilities need to build their own networks because of their need for reliability and security.  However, when he talks to telecom firms, they argue that commercial networks, both wired and wireless, are the most cost-effective means for utilities to gather and use data for consumers, he said. DOE published a request for information on utilities’ smart-grid related communications requirements last month and set a July 12 deadline for interested parties to submit comments.

Industry Techies to Study Network Management June 9th, 2010

A new work group of engineers and technical experts launches today, headed by former Federal Communications Commission Chief Technologist Dale Hatfield. Initial members of the Broadband Internet Technical Advisory Group, or TAG, include AT&T, Cisco, Comcast, DISH, EchoStar, Google, Intel, Level 3 Communications, Microsoft, Time Warner Cable and Verizon. Technical experts from the companies will develop case studies around network management practices. The goal is to exchange ideas on creating the best user experience. TAG will share its findings with policymakers, and act as a sounding board for new ideas.

Hatfield, a renowned technical expert, says he sees TAG providing a neutral forum for promoting consensus around technical practices in the industry.  Specifically, TAG will take a close look at whether certain practices are workable across platforms, and examine the impact on content, applications and companies.  Hatfield, who is highly respected in technology circles, serves as adjunct professor at the University of Colorado and executive director of the Silicon Flatirons Center. More details on TAG’s activities are to come.

FCC Broadband Proposal at Odds with Investment Goals May 19th, 2010

A New York Times editorial calls the FCC’s proposed regulation of broadband services a “measured attempt” to give government oversight of the communications network. But in fact, the agency’s proposal reverses a decade or more of bipartisan policies keeping Internet services free from legacy phone service regulation. Starting with the 1996 Telecom Act, Congress and the FCC have affirmed this view of light-handed oversight. Now the Obama administration, which has prided itself on its tech savvy, wants to reverse course and impose regulations on an industry that has been at the center of technological innovation.

The FCC says it’s only going to apply a handful of provisions in rules that would classify broadband under common carrier regulation, a strategy it apparently believes can be done seamlessly. But the process of sifting through which of the 48 provisions to enforce could provoke years of legal proceedings. Worse, the FCC has not yet ruled out regulation dealing with pricing and classification of services. Analysts widely agree that price regulations would chill investment and job growth, the opposite of the Obama administration’s stated goals.

As Bret Swanson points out in commentary published in Forbes, the FCC’s proposal could quash potential partnerships between content providers and networks that would benefit consumers. They also could prevent use of innovative technologies for efficiently routing packets to their destinations. “Price controls on the chief investors” are not the way to drum up the $350 billion the FCC estimates it will take to achieve the goals of its national broadband plan, Swanson says.

Black Market For IP Addresses May 13th, 2010

It appears that the depletion of IPv4 addresses has accelerated much faster than predicted. As with many other resources that are in high demand, the possibility of a ‘Black Market’ is of growing concern to several Internet notables. Kevin Oberman, a well-known Internet Engineering and economic subject matter expert, believes the black market already exists in a small form, but could get much worse very quickly.  “If you have a commodity that has value and is required for commerce, the price will rise to whatever buyers are willing to pay”. “ If people have legitimate rules that permit (IP) address transfers, they’ll use them instead of a black market” stated Oberman.

The American Registry for Internet Numbers (ARIN) predicts that, at the current rate of IPv4 assignments, these addresses will be exhausted by the end of 2010, almost a full year ahead of earlier predictions. Richard Jimmerson, the CIO of ARIN notes that the ARIN community has adopted policies that permit address transfer from an IPv4 registrant to another party, through ARIN.  Jimmerson is hopeful that this will mitigate the likelihood of a growing black market for IPv4 addresses.

Of course, as the entire Internet engineering community has been touting since 2004, the networks that make up the Internet will need to migrate fully to IPv6 addressing in order to keep up and serve the explosive growth of the Internet as a whole. Both Oberman and Jimmerson agree that there is very little time left for IPv4 users to fully migrate to IPv6, and that most new computing servers will soon be shipped as IPv6-only machines, thus isolating any holdover IPv4-only Internet users.