So we are approaching that time of the year in which Internet Net Neutrality debate regains attention and media coverage, in this post entry, I share my opinion of the subject with an emphasis on QoS for wireless ISP. Three sources serve as foundation to develop my argumentation; BEREC (Body of European Regulators for Electronic Communications) documentation on the matter. FCC Open Internet rule and the correspondent analysis constructed by Prof. Barbara Van Schewick.
In 2009 FCC started its proceedings for the Open Internet, in 2010 rules where adopted which became effective in 2011. On May 25th this year, the FCC announced the composition of Open Internet Advisory Committee (OIAC) formed by various actors of the industry whose purpose is to evaluate the effects of Open Internet rules, to assess the evolution of the industry since the rules were promulgated and lastly to consider the importance of wireless 4G technology adoption in the American market. The BEREC started in 2010 its consultation to explore the regulatory aspects of Net Neutrality, by 2011 defined the key issues to be developed: Transparency, QoS requirements, Discrimination and IP interconnection and by 2012 several draft documents have been produced under this effort; A Framework of QoS in Scope of Net Neutrality, Guidelines of QoS in Scope of Net Neutrality and IP Interconnection Assessment in Scope of Net Neutrality, all available for public consultation at the website. Finally the ITU has published the related agenda framed in the WCIT (World Conference on International Telecommunications) to be held in Dubai in December.
What to agree on
BEREC draft documents state clearly that users must be able to decide the content they want to receive or to send within their contracted Internet service not the ISP, neither Internet service can degrade below a minimum service level; the threshold has to be determined by specific measurement techniques, once set, it must be disclosed by ISP to NRA (National Regulatory Agency). There is a clear distinction between the concepts QoS (Quality of Service), QoE (Quality of Experience) and NP (Network Performance) and it is concluded that the better approach to ensure a minimum level of service is to determine KPI (Key Performance Indicators) on NP. Related to QoS I agree that its applicability must ensure transparency.
FCC rules recognize that there is a difference between mobile and fixed ISP and therefore rules should be considered separately, it is important for the FCC that the end user has total control on the contents he/she receives within a legal framework, also the traffic management techniques must be transparent and to conform to standard best practices. It is remarkable that the rules explicitly prohibit any type of discrimination that is considered anticompetitive and set some guidelines to identify what is considered as unreasonable discrimination. Related to QoS the rules allow different classes of QoS to be applied in the network as long as they can be equally provisioned to all applications and traffic flows.
Prof. Van Schewick states that NN (Network Neutrality) regulation must preserve the open nature of the Internet that allows innovation without permission and free cultural exchange, which in turn also allows low costs of innovation for developers, but the regulation must be clear enough to provide an easy way to determine which are punishable behaviors and which aren’t without incurring on high costs for governments or NRAs, for example, by having to study several cases separately (case by case scenario). Any measure taken by ISP to single out an application or class of application for differential treatment isn’t beneficial for the market and interferes with user decisions about how to use the network. Related to QoS, the professor considers that exclusivity of QoS provision to one application or more applications within a class of “like” applications (applications sharing the same characteristics, like network protocols or usage) should be prohibited, and that applicability of QoS must not be dependent on which applications users run on the network. Charging for any differential service provided by the network should only be allowed to ISP own users. And finally NRA is responsible for the vigilance and compliance of minimum level of service.
Where My Point of View Diverges
Image courtesy of Paola Buelvas (firstname.lastname@example.org)
Findings within the BEREC framework are very loose; the need to perform a case by case study of all presumable infringements of the regulation is inferred, this leads to high costs for governments and NRAs. Results are applicable to both fixed and wireless ISP, but the proposal to measure a mobile operator performance is based on a periodical execution to produce geographical and accumulated results… that means more costs!
FCC rules for mobile/wireless ISP give them permission for a reasonable traffic management but there is no way to determine what is reasonable and what is not, this also leads to high costs and as commented above its not beneficial for the industry.
According to Prof. Van Schewick the network must be application blind because this condition has enabled the development of the Internet in the past and users can get exactly the QoS that meet their preferences in a network that is completely blind to applications. The control of network resources can be completely perform by using application agnostic network management and user control prioritization, and it is possible to prevent aggressive users from overwhelming the network by allocating bandwidth among users in application-agnostic ways. The concept of “like” applications is not well defined, and network providers have broad discretion to decide which applications are alike, also “like” treatment violates the principle of user choice.
I’m willing to Support My Views
The increasing usage of mobile internet along the rapid adoption of 4G across the world is an important factor to include wireless/mobile ISP in the network neutrality regulation debate, according to Cisco VNI the number of mobile-connected devices will exceed the world’s population by 2012. The main issue is that wireless ISP are bounded by a big restriction called government regulated electromagnetic spectrum usage, (at least for those interested in serving through the regulated portion of the spectrum), while for a fixed ISP in order to expand its capacity it has almost complete autonomy across the network, it cannot be said the same for wireless providers, so for them to expand capacity, government auctions have to be conducted, accompanied by a thorough frequency planning and continuous optimization. The other issue is the network blindness convenience; an intelligent network, aware of the applications running on top, can better protect user personal information, it can help improve user experience through complicated statistics gathering, it can provide exactly the type of quality of service that the user wants for the application he wants how he wants it, it can help innovate through collaboration with Internet Content Providers (ICP) sharing information and analytics about usage patterns. Since the nature of mobile broadband usage is dynamic, subject to the environment, to the amount of users and their positioning in the cell, to the technology employed by the ISP, to the type of terminal running user applications and to other factors, the congestion control rarely can be effective by performing fixed bandwidth allocation let alone using only application-agnostic ways.
The concept of “like” applications although can be viewed as not entirely well defined, it cannot be defined as totally misleading; it is hard to believe that an ISP can convince a NRA that for example a P2P application behaves like a VoIP application, sure, there might be occasions where an application can behave like many, but Internet has a standard stack of protocols. On the other hand the statement that an ISP that treats equally applications behaving alike violates the user choice is only true if the user cannot choose otherwise, there are savvy users that will benefit greatly from “like” QoS treatments, and ISP must be ready to offer that choice. Finally, transparency must be the key in the regulation starting from the establishment of the baseline level of the service, it cannot be expensive or complicated so it can be used globally as a guideline. The IEEE paper from Doctor Scott Jordan gives a technical deep sustentation within a regulation framework.
Wireless QoS offering proposal within a NN framework
Considering all the factors presented in this blog, my proposal for a wireless ISP to provide and provision QoS includes thoughs for the ISP the ICP (Internet Content Provider) and the users.
The proposal complies with the following principles:
The proposal leaves out the following principle:
The Wireless/Mobile ISP must:
Content providers can:
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