[Ecommerce] Internet Society of New York Comments on FTC's NN Proceeding

[Seth Johnson]

(ISOC-NY's comment in response to the FTC's workshop on "Broadband
Connectivity Competition Policy":
http://www.ftc.gov/opp/workshops/broadband/index.html  -- Seth)


New York Greater Metropolitan Area chapter of the Internet Society
(ISOC-NY)

> http://www.ftc.gov/os/comments/broadbandwrkshop/527031-00046.htm
> http://www.ftc.gov/os/comments/broadbandwrkshop/527031-00046.pdf

Comments:

Please find ISOC-NY's comments in the attached html file. Joly MacFie

---

New York Greater Metropolitan Area chapter of the Internet Society
(ISOC-NY)
http://isoc-ny.org
Feb 28 2007

Comments to FTC Public Workshop on Broadband Connectivity Competition
Policy

Dear Chairman Majoras, Workshop Members,

Here at ISOC-NY we have followed this workshop, and the subsequent
comments with great interest.

The Internet Society (ISOC) was founded in 1992 with the mission 'to
assure the open development, evolution and use of the Internet for the
benefit of all people throughout the world' and is the parent
organization of the Internet Engineering Task Force (IETF) and the
Internet Architecture Board (IAB), which between them set the global
standards upon which the Internet is based.

We appreciate the FTC's efforts to get to grips with issues that
certainly threaten that 'open-ness' with respect to the USA.

Our members have raised the following points:

   That the bodies that oversee the processes of Internet
   standards-making have not been given appropriate participation
   in the discussion.

   That the very process of Internet standards-making is at risk
   in the Network Neutrality debate, because the flexibility of
   the Internet transport and the diversity of applications that
   are made possible by it may very easily be affected by
   practices that would affect the transport.

   That the advantages of the existing protocols -- in particular
   the application flexibility of the Internet Protocol -- have
   not been acknowledged adequately in the debate.

   That in order to address policy questions related to Network
   Neutrality a distinction needs to be drawn between the nature
   and advantages of existing protocols and practices, and
   various practices that are being proposed.

It is generally agreed that one reason Network Neutrality is an issue
at all is due to past policies that have diminished robust competition
in high-speed internet access, and we would encourage the FTC to do
their best to promote such competition, including Municipal Access,
and the development of new technologies such as 'Broadband over Power
Lines' (BPL) and WIMAX.

The comments to the workshop by R. Bancroft, suggesting that the FTC
encourage ISP's to voluntarily disclose their existing packet
management practices, were well received.


Thanks for your attention,

Joly MacFie