Etheric's Stand on Net Neutrality to the Federal Communications Commission

Etheric’s Stand on Net Neutrality to the Federal Communications Commission

We recommend that ISPs not be able to discriminate based on off-net location. That means that Comcast cannot route traffic on a worse path to a competitor than it does to a premium partner. However, direct connections between providers that do not experience congestion should always be permitted.

Typically, a Service Provider has three types of an end to end paths, as follows:

  • The Last Mile (e.g. customer home on cable to the local Comcast neighborhood box)
  • The last mile, the fiber, cable, copper or wireless connection to the customer premises.
  • An ISP should not discriminate inside their last mile network based on the end destination. They could tell by the (article missing here?) of service (QoS).

For example, Voice Calls which take little bandwidth might have reserved bandwidth priority, but for all VoIP services; not solely the ISPs or the ISP partner. These last mile paths could be sold as transit or as transport.

Providers should be permitted to have different priorities for different service plans. It is normal for a small ISP to boost priority for a platinum account customer and a bronze account customer. It is hard to offer a mass market product with low cost without providing some help.

For National Monopolies, the bar should raise slightly higher. Perhaps they should not increase priority based on service plan level, or this should be an area of oversight. Higher level plans offer higher speeds by nature, but not implicitly higher prioritization on the last mile.

The Middle Mile: (e.g. Local Neighborhood Telecom Box to the Main Data Center in your region (e.g. where Comcast might connect with the other service providers to send and receive traffic on the public internet).

From a facility where the customer last mile links is an aggregated weather outdoor box or a data center to the point where the provider hands off to other service providers, traditionally at the Data Center where all the local facilities in the surrounding area are “homed to.”

The middle mile for small service providers should have the same rules as the last mile. The provider should not discriminate by lowering speeds on a customer’s destination, and Comcast should not be permitted to slow down traffic to Netflix deliberately.

Whatever speed bundle the client received, the customer should have the same chance to receive it regardless of end destination on the internal middle mile ISP network.

Transit: From your ISP to End Destination on Other Service Provider Network

ISP’s hand off their traffic at the data center to the large national carriers or connect directly to the end carrier by “cross connecting” or connecting to a “peering exchange.” While a carrier is free to purchase arrangements as they see fit, there should be no deliberate slowing to end destinations or based on the type of traffic.

Providers may want to craft advanced schemes for maintaining a quality of service for applications, and there is no reason that traffic management to support the Service Level Agreement in the form of shaping traffic should be entirely forbidden.

It is our view that a small percentage of traffic, perhaps 10% could be prioritized over the public Internet from the customer ISP to the end server or remote connection ends such as a cell phone or computer. We would suggest this be mandatory for national carriers, which is a minority of mission-critical traffic over the public Internet prioritized as long as the majority is in a single class (not de-prioritization specifically).

For ISP’s under 100 million sales or so, waive this. I believe allowing them more breathing room in innovating with what resources they have should be more aggressive. Players in the 100 million sales or less category still live by their reputation and online rating. They will be more adversely affected than the national carriers by bad reviews.

This simple set of guidelines should govern neutrality.

Transport: from your ISP to ISP Service on Net (e.g. Comcast XFINITY video at a Comcast direct connected Data Center (Traffic never touches the public Internet).

ISP’s will not have latency to their services, unless they are fools, or under very unusual circumstances. Their services will be hosted in their data centers, or at locations directly connected to a high-speed backbone, such as fiber or p2p microwave.

As long as the ISP does not deliberately slow the last mile traffic based on its destination, the ISP is free to adopt its shaping policies connecting their customer to their servers. It would be against their interests to degrade their services.

To the lay audience; providers lay down internal pipes. If they do not deliberately slow down based on going to a competitor network, they can use whatever traffic engineering schemes they want. It ends destination neutral.

What rules does this impose?

You cannot throttle or slow traffic based on customer-end destination.

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