[Bloat] fcc initial comments due sept 10

[Dave Taht]

https://arstechnica.com/information-technology/2018/08/speedier-broadband-standards-pais-fcc-says-25mbps-is-fast-enough/

[d***@deepplum.com]

Just to remind everyone, "Broadband" is a term invented by the cable industry to describe "bundled cable TV, phone, and Internet", pretty much "aka DOCSIS".

The confidence game played on America was to promote the idea that the US would deliver Broadband across the entire country (particularly rural locations where people have not had cable TV, much less bundled with phone and high speed Internet. And it was conflated with recovering from the 2007-2008 economic crash as a "shovel ready" job creation program, enhancing ghe opportunity of rural locations to create "good jobs" in the IT service industries.

Of course, the folks who wanted to see Internet connectivity spread and restructure the economic structure of communications decided not to look this "gift horse" in the mouth. Congress was going to fund rollouts of Cable TV (new and upgrades), and as a side effect, maybe some better Internet. (but no "over the top" TV like Netflix or VoIP telephony, just leave TV alone and use Cable Labs telephony standards at the RF level).

Now it's worth realizing that by accepting this framing of Broadband as the goal, not ubiquitous and interoperable high speed Internet itself, you basically put monopoly/oligoply Cable TV companies in control of the country's communicstions future.

Is this a good plan for thinking about the future of the Internet in the US? I really think it is a bad direction.

Now 25 Mb/sec is totally fine for most standard WWW/email usage, and even a little YouTube watching. But remember, such Internet on DOCSIS 3.1 or on 25 year old Verizon FiOS technology alongside cable TV over Verison FiOS still uses a TINY fraction of the installed cable analog capacity for Internet service. The architecture of the Cable TV service distributes *every* channel simultaneously to every endpoint, consuming outrageous bandwidth compared to the 25 Mb/s diddly squat usage on the "broad band" cable or fiber.

The idea that it is the government's job to "incent" private industry with pretty much oligopoly control of premises connectivity to make money is one of the perverse political arguments in the industry. They "poormouth" how they "can't make money", when in fact their High Speed Internet service has the highest profit margins of any of their service offerings. They are making money hand over fist on the Internet piece, and it costs them next to nothing to provide it. (Prices don't track costs, because there is no competition at all in most places, because the government prevents new competitors.)

So it just seems strange to me that we have this debate about how fast is fast enough, as if the government has to force companies to make money hand over fist.

Nope - what is going on here is something a little subtle. What the cable companies don't want, what they are fighting for, are two things:

1) no competitive entry whatsoever, no way. They have to make sure that state and local governments think they can't afford to upgrade their plants, despite strong customer interest. Of course, no new investment is required if there is no competition, and their story is that if the FCC allows competitors their incentive will vanish and they will stop investing. (that makes it the only industry in history whose incentive vanishes when there is competition on a profitable service. And they are NOT losing money on Internet service, far from it, if you look at the books they show their investors, not the regulators).

2) The right to bill both sides of communications transactions arbitrarily large prices for reachability - they make their customers pay to get access to the public Internet, and also the cloud, web, content servers pay them to provide adequate connections. This is a two-sided market. It arises when the "middle" can create arbitrary scarcity at will. (a "protection racket" is a two sided market, too).

So, in responding to this notice by the FCC of a "standard" for Broadband, just realize that you might want to question the entire proposition that Broadband is a thing that needs a standard.

What "high speed" means in the Internet is a much more meaningful question, but that's a truth in advertising question. And it really has to do with "response time" more than any guarantee of an "up to" speed. How long does it take Netflix to buffer enough content to play the rest of the show without interruption? (that's why you need burst rate) How fast do your trigger pulls on your multiperson VR shooter get reflected on all the other players' displays?

People do pay more for that. But the standard of what "that" is - high speed, very high speed, ... isn't just 25 Mb/sec. It's also bufferbloat, for example.

THink about that, and don't get sucked into comments on what Cable TV should do for minimal Internet quality.






-----Original Message-----
From: "Dave Taht" <***@gmail.com>
Sent: Friday, August 10, 2018 7:47pm
To: "bloat" <***@lists.bufferbloat.net>, cerowrt-***@lists.bufferbloat.net
Subject: [Cerowrt-devel] fcc initial comments due sept 10

https://arstechnica.com/information-technology/2018/08/speedier-broadband-standards-pais-fcc-says-25mbps-is-fast-enough/

[Jan Ceuleers]

Post by d***@deepplum.com
Just to remind everyone, "Broadband" is a term invented by the cable industry to describe "bundled cable TV, phone, and Internet", pretty much "aka DOCSIS".

No, it's not.

Not that's important, but the term was coined many years ago by the
telecoms industry to distinguish high-bandwidth services from
low-bandwidth ones, such as telephony, voice band modems and ISDN, which
were referred to as narrowband services.

For example, ADSL was regarded as a broadband service.

[Livingood, Jason]

Hi David - See some comments inline below. Hope you are well!
- Jason

On 8/10/18, 11:35 PM, "Bloat on behalf of ***@deepplum.com" <bloat-***@lists.bufferbloat.net on behalf of ***@deepplum.com> wrote:

Of course, the folks who wanted to see Internet connectivity spread and restructure the economic structure of communications decided not to look this "gift horse" in the mouth. Congress was going to fund rollouts of Cable TV (new and upgrades), and as a side effect, maybe some better Internet.

[JL] How and when did Congress fund DOCSIS network investments (either in 2007-2008 or before)? Do you have any citations for this?

The architecture of the Cable TV service distributes *every* channel simultaneously to every endpoint, consuming outrageous bandwidth compared to the 25 Mb/s diddly squat usage on the "broad band" cable or fiber.

[JL] This is changing more rapidly than you may realize, through a combination of factors. One is that most cable companies have been deploying IP-based set tops for several years, which enables more unicast delivery using IP, which frees up channels for DOCSIS Internet services (otherwise where would cable companies find the channel space to 24 or 32 downstream channels plus D3.1 OFDM compared to 4 or 8 downstreams a few years ago?). In addition, on the demand side, customers increasingly watch programs via their DVR or On Demand library rather than watching something live (typical exceptions being sports, news, weather, etc.). Finally, they are also watching increasingly on non-set-top devices like tablets and laptops.

So, in responding to this notice by the FCC of a "standard" for Broadband, just realize that you might want to question the entire proposition that Broadband is a thing that needs a standard.

[JL] I thought it was just the usual annual NOI on the definition of "advanced telecommunications capabilities". The use of the word "broadband" just appears to be shorthand for that. See https://docs.fcc.gov/public/attachments/FCC-18-119A1.pdf which says:

"Section 706 of the Telecommunications Act of 1996, as amended (1996 Act), requires us to determine and report annually on “whether advanced telecommunications capability is being deployed to all Americans in a reasonable and timely fashion.”FN1

FN1 47 U.S.C. § 1302(b). For simplicity in past inquiries, the Commission has sometimes used the term “broadband” to refer to “advanced telecommunications capability.” However, “advanced telecommunications capability” is a statutory term with a definition that is narrower than the term “broadband.” See 47 U.S.C. § 1302(d)(1) (“The term ‘advanced telecommunications capability’ is defined, without regard to any transmission media or technology, as high-speed, switched, broadband telecommunications capability that enables users to originate and receive high quality voice, data, graphics, and video telecommunications using any technology.”). As this definition makes clear, while all services providing advanced telecommunications capability are “broadband,” not all broadband services provide advanced telecommunications capability."

What "high speed" means in the Internet is a much more meaningful question, but that's a truth in advertising question. And it really has to do with "response time" more than any guarantee of an "up to" speed. How long does it take Netflix to buffer enough content to play the rest of the show without interruption? (that's why you need burst rate) How fast do your trigger pulls on your multiperson VR shooter get reflected on all the other players' displays?

People do pay more for that. But the standard of what "that" is - high speed, very high speed, ... isn't just 25 Mb/sec. It's also bufferbloat, for example.

THink about that, and don't get sucked into comments on what Cable TV should do for minimal Internet quality.

[JL] Putting aside all the stuff about cable and broadband, it seems your bottom line is that buffer bloat, latency, and latency under load are also meaningful and should be considered in addition to speed/throughput measures in this definition. That seems a worthwhile technical question to raise.

[d***@deepplum.com]

1000/25 is my current low cost service. Due to competition, low cost 1000/1000 is rapidly spreading in the Boston area, on a number of novel tech infrastructures. Sadly, government thinks that Monopoly is the tool to "incent" reluctant incumbents, and/or classification by FCC surveys.

Competition (new entrants, or multiple providers) does it without the FCC even being engaged.

But businesses DONT want competition if they can corrupt the government cheaper.

Look at Pennsylvania... Bought and paid for, Comcast Country. Tax subsidies, laws against Muni Fiber, ... Comcast has great technologists, for sure. So did Bell Labs in its heyday. But touchtone took 20 years and still didn't make it widely, even though it would have allowed advanced switching services.

FCC isn't the place to make things happen.

-----Original Message-----
From: "David Lang" <***@lang.hm>
Sent: Mon, Aug 13, 2018 at 11:45 pm
To: "***@deepplum.com" <***@deepplum.com>
Cc: "Dave Taht" <***@gmail.com>, cerowrt-***@lists.bufferbloat.net, "bloat" <***@lists.bufferbloat.net>
Subject: Re: [Bloat] [Cerowrt-devel] fcc initial comments due sept 10

Post by d***@deepplum.com
Now 25 Mb/sec is totally fine for most standard WWW/email usage, and even a little YouTube watching.

I'm currently doing that fairly comfortably on a 5/1 line, 25mb would be very
nice to be able to get.

David Lang