[A2k] My Comments on Broadband as General Purpose Platform

[Seth Johnson]

Comments - NBP Public Notice #1

GN Docket Nos. 09=AD47, 09=AD51, and 09=AD137


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=3Dpdf&id_docu=
ment=3D7020037177
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