What does "prate" mean?

What does "prate" mean?

From http://www.merriam-webster.com/dictionary/prate:
To talk long and idly : CHATTER

Eno River Sunrise

Monday, July 29, 2013

Net Neutrality, Part 3

Note: This was originally published at the Overture Networks "Overtones" blog site at http://www.overturenetworks.com/connect-with-overture/overtones-blog/net-neutrality-part-3/. That site is no longer available.


“Net Neutrality” refers to the FCC  rules regarding the non-discriminatory treatment of services and applications.  While the basics of Net Neutrality are simple, the ramifications are broad and complex.
This blog is the third of a three-part series. 
  • Part 1 describes the basic principles and applicability to residential versus business services.
  • Part 2 covers fixed versus mobile, the impact of competition, and the validity of the order.  It also provides pointers to additional resources.
  • Part 3 explores how the rules impact service providers, and how they could evolve.

Real-World Input

For this part, I talked to some senior people at two major service providers.  They denied being legal experts, but their roles do give them insight into the impact of Net Neutrality, and their opinions are pretty interesting.  These discussions were off the record, so I can’t name them or their employers.  To simplify this blog, I will refer to them by pseudonyms:

  • Indigo is an incumbent service provider that has both local access and backbones, and also provides content.  Indigo is neutral to slightly negative on Net Neutrality.
  • Charlie is a competitive service provider.  They have little local access and do not provide content.  Charlie is supportive of Net Neutrality.

Competition

As discussed in Part 2 of this series, a basic assumption of the FCC was a lack of competition.
Today, many urban and suburban subscribers have a choice of two or three providers using DSL, cable, fiber or fixed wireless. Should the rules take this competition into account?

I asked Indigo about whether there was likely to be any petition to the FCC to recognize the emergence of competition.  They said probably not.  Their thinking was that the current penetration was so geographically spotty that it would be difficult for the SP to show competition and to have different policies in those areas.  Furthermore, it was unlikely that the FCC would consent to providing such specific exemptions.

Charlie pointed out that even when competition is present, it is not always equal.  For example, certain areas may have more than one wireline provider, but the differences in available bandwidth may mean that only one of the providers has a suitable service.

It looks like a lack of effective competition is and will continue to be a factor in the basis of net neutrality.

Impact on Service Planning

One of the assertions of the FCC was that the Open Internet Report and Order would have little or no impact on service providers.  To test this assertion, I asked the folks at Charlie and Indigo
At Charlie the answer was answer was both “yes” and “no”:

  • Yes: Their services rely on third party local access, and the equal treatment of internet traffic is one of their basic assumptions.  They need and assume Net neutrality.
  • No: There is not any thought of creating a service that would run afoul of Net Neutrality due to blocking or prioritization.  They said that they consider it bad business to engage in any preferential treatment of internet traffic on their part, or to engage in a deal to support such priority in the local loop.  Their basic assumption is equal treatment in the backbone and on the part of the local access providers.  Furthermore, they do not expect any FCC action except in the most egregious cases, such as port blocking.


At Indigo the answer was also both “no” and “yes” – but with a very different slant:

  • No: There is little or no impact of Net Neutrality considerations on most services.  The FCC assertion that the rules are consistent with current practice is true in general.  However …
  • Yes: There is always concern that the ambiguity in the rules and/or the changes in technology could cause the FCC to change its interpretations.  Decisions that are OK today from a Net Neutrality standpoint may be called into question down the road. 
With respect to the future possibilities of increased regulation, I want to share Figure 1 from Mercatus that shows the growth of all US Federal regulations from 1997 to 2010.


Figure 1: US Federal Regulatory Growth

Clearly the trend for the amount of US Federal regulations is upward and to the right.  The two viewpoints above (i.e. Net Neutrality is a basic assumption versus Net Neutrality is a potential monkey wrench) reflect the two faces of the same regulatory coin.

What is Being Done?

This concern about regulatory impact is shared by a number industry players.  One example of a response is the Broadband Internet Technical Advisory Group (BITAG),  which was formed to “to discuss and opine on technical issues pertaining to the operation of the Internet, as a means of bringing transparency and clarity to network management processes as well as the interaction among networks, applications, devices and content” and to “provide the best technical information and counsel to policymakers and the public.” 

Some of the work to date serves to provide a technical basis for some current and upcoming trends by the service providers.  One paper is on Large Scale Network Address Translation, which is needed to maximize the efficiency of IPv4 address usage during the transition to IPv6.  However, there is a side effect that may impair some protocols. 

Another paper is on SNMP DDOS attacks.  This study describes the possible deleterious effects due to SNMP-enabled home routers in combination with malicious DDOS attacks.  The study points out that a possible remedy is the blocking of SNMP, noting that this may have a deleterious effect on business users.  We at Overture ran into this at one point when we couldn’t do some troubleshooting over our internet connection because our ISP was blocking SNMP – without clearing informing us.

The issue that we had at Overture underscores the need for accurate disclosure of management practices.

Do NAT and SNMP blocking fall under the allowance for “Reasonable network management?”  The BITAG hopes to make the case that they do so as to minimize the chance of an unfavorable ruling by the FCC.

Monday, July 22, 2013

Net Neutrality, Part 2

Note: This was originally published at the Overture Networks "Overtones" blog site at http://www.overturenetworks.com/connect-with-overture/overtones-blog/net-neutrality-part-2/. That site is no longer available.


“Net Neutrality” refers to the FCC  rules regarding the non-discriminatory treatment of services and applications.  While the basics of Net Neutrality are simple, the ramifications are broad and complex. This blog is the second of a three-part series. 
  • Part 1 describes the basic principles and applicability to residential versus business services.
  • Part 2 covers fixed versus mobile, the impact of competition, and the validity of the order.  It also provides pointers to additional resources.
  • Part 3 explores how the rules impact service providers, and how they could evolve.

Fixed Versus Mobile

The totality of the rules apply to fixed or wireline providers, with some narrowing of applicability for mobile or wireless services.   The table below compares the wired and wireless sections of the section 8.5 “No Blocking” rule.


Fixed / Wireline
Mobile / Wireless
“shall not block” Category
A person engaged in the provision of fixed broadband Internet access service, insofar as such person is so engaged
A person engaged in the provision of mobile broadband Internet access service, insofar as such person is so engaged
Lawful content or sites
Applies, subject to reasonable network management
Applies, subject to reasonable network management
Applications and Services
Applies, subject to reasonable network management
Applies to applications that compete with the provider’s voice or video telephony services, subject to reasonable network management
Non-harmful devices
Applies, subject to reasonable network management
Does not apply. Mobile operators routinely limit the allowed devices.
Reasonable network management
Section 81:
(1) reduce or mitigate the effects of congestion on its network or to address quality-of-service concerns;
(2) address traffic that is unwanted by users or harmful;
(3) prevent the transfer of unlawful content; or
(4) prevent the unlawful transfer of content.
A network management practice is reasonable if it is appropriate and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband Internet access service.
Section 103.
As indicated in Part III.D above, the reasonable network management definition takes into account the particular network architecture and technology of the broadband Internet access service. Thus, in determining whether a network management practice is reasonable, the Commission will consider technical, operational, and other differences between wireless and other broadband Internet access platforms, including differences relating to efficient use of spectrum. We anticipate that conditions in mobile broadband networks may necessitate network management practices that would not be necessary in most fixed networks, but conclude that our definition of reasonable network management is flexible enough to accommodate such differences.

The mobile operators are clearly taking advantage of the ability to restrict what devices are used on their networks, which is allowed as described above.  One of the operators that I talked to pointed out that the reasons for this are 1) supporting different devices is a significant cost to carriers and 2) ensuring that all devices act and behave properly is critical to the proper functioning of the network or other customers, because the impact of a bad actor on the wireless network is large and hard to remedy.

Not as clear are some other policies of wireless operators.  For example, Gogo inflight internet blocks streaming video from providers such as Netflix (BTW – Gogo, I love you!   Please don’t cut off my inflight internet!)  Is this a case of reasonable network management due to the limited bandwidth?  Or is it a case of a service provider blocking a competing service (in this case, competing with Gogo’s own inflight movie offering).

Competition

One of the original drivers of the Open Internet rules was the lack of competition in the access networks.   As described in Section 51 on page 31:

51. We also do not apply these rules to dial-up Internet access service because telephone service has historically provided the easy ability to switch among competing dial-up Internet access services.

143 Contrary to the suggestion of some, neither the Department of Justice nor the FTC has concluded that the broadband market is competitive or that open Internet rules are unnecessary. See McDowell Statement at *4; Baker Statement at *3. In the submission in question, the Department observed that: (1) the wireline broadband market is highly concentrated, with most consumers served by at most two providers; (2) the prospects for additional wireline competition are dim due to the high fixed and sunk costs required to provide wireline broadband service; and (3) the extent to which mobile wireless offerings will compete with wireline offerings is unknown.

Interestingly enough, the order gives more latitude to wireless operators, while at the same time recognizing a higher level of competition in that space.  Section 95 on page 53 and section 96 on page 54 state:

95.   Moreover, most consumers have more choices for mobile broadband than for fixed (particularly fixed wireline) broadband.292 Mobile broadband speeds, capacity, and penetration are typically much lower than for fixed broadband,293 though some providers have begun offering 4G service that will enable offerings with higher speeds and capacity and lower latency than previous generations of mobile service.294 In addition, existing mobile networks present operational constraints that fixed broadband networks do not typically encounter.295 This puts greater pressure on the concept of “reasonable network management” for mobile providers,296 and creates additional challenges in applying a broader set of rules to mobile at this time. Further, we recognize that there have been meaningful recent moves toward openness in and on mobile broadband networks, including the introduction of third-party devices and applications on a number of mobile broadband networks, and more open mobile devices. In addition, we anticipate soon seeing the effects on the market of the openness conditions we imposed on mobile providers that operate on upper 700 MHz C Block (“C Block”) spectrum,297 which includes Verizon Wireless, one of the largest mobile wireless carriers in the U.S.298

96. In light of these considerations, we conclude it is appropriate to take measured steps at this time to protect the openness of the Internet when accessed through mobile broadband. We apply certain of the open Internet rules, requiring compliance with the transparency rule and a basic no-blocking rule.299


Validity of the Order

Starting on page 62, section IV (“THE COMMISSION’S AUTHORITY TO ADOPT OPEN INTERNET RULES”) gives a detailed defense of the validity of the rules.  It details the authority of the FCC to act based on the 1996 Telecommunication Act, and it provides reasoning as to why the order does not violate the First or Fifth Amendments to the US Constitution.  What I find more interesting are the dissenting opinions of commissioners Robert M. McDowell and Meredith Attwell Baker.

Commissioner McDowell makes an interesting point on page 145:

For those who might be tuning in to the FCC for the first time, please know that over 90 percent of our actions are not only bipartisan, but unanimous. I challenge anyone to find another policy making body in Washington with a more consistent record of consensus. We agree that the Internet is, and should remain, open and freedom enhancing. It is, and always has been so, under existing law. Beyond that, we disagree. The contrasts between our perspectives could not be sharper.

He then proceeds to a lengthy analysis based on 4 key points listed on page 146:

1)      Nothing is broken in the Internet access market that needs fixing;
2)      The FCC does not have the legal authority to issue these rules;
3)      The proposed rules are likely to cause irreparable harm; and
4)      Existing law and Internet governance structures provide ample consumer protection in the event a systemic market failure occurs.

Commissioner Attwell also provides a detailed analysis in his dissent.  Here is his summary from page 181:

I have seven principal objections to this decision. First, the factual record does not support government intervention. Second, the majority’s claim that consumers will benefit from this government overreach is unsupported and deeply flawed. Third, the majority’s focus on preserving network operators’ current conditions will distort tomorrow’s Internet. Fourth, the majority puts the Commission in the unworkable role of Internet referee. Fifth, the majority fails to marshal a sustainable legal foundation. Sixth, the majority’s decision to act a legislator, not regulator, is a mistake that may undermine our agency’s mission. And, lastly, opportunity cost. By that I mean, we have squandered months on this effort, diverting resources and political capital away from real problems that lie within our core competencies, like universal service and spectrum reform.

How did a body like the Commission go from near unanimity on decisions to a very divisive 3-2 vote, with such strong dissents from two members?

What’s It Mean?

Next week’s blog will dig more into how Net Neutrality impacts service providers today, how it might affect their plans for advanced services, and what they are doing about it.

Other Resources

Neutral (i.e. Net Neutral2 J):

Pro Net Neutrality

Anti Net Neutrality





Sunday, July 21, 2013

Improving Your Public Speaking

Over the last year or so I have been trying to improve the content and delivery of my public speaking and presentations. Here are two articles that provide good summaries of the principles that have helped me.

The first article is "How To Go From Being a Disaster—To a Great Speaker" by Vivek Wadhwa. It contains a brief summary of what I think are some of the essential points for successful speaking. They are:
  1. Don't try to memorize every line - it is a hopeless cause. Have notes in your hand or use a PowerPoint presentation which highlights the key points that you want to make.
  2. Know your material and rehearse it several times beforehand. Record yourself giving the talk and note what you did right and wrong. Have your friends critique you.
  3. Make it personal. Talk about yourself, what you think about the things you are speaking about, and most importantly - what this means for the audience. This means that you have to know your audience - who they are and what they are interested in. Remember: this is for them - not for you. Don't do what most academics do - impersonalize the material and repeatedly give the same dry, dull, and boring lecture.
  4. Tell a story. Put the material you are presenting into a perspective that connects the pieces together and is a coherent story. Facts and figures are boring. Explain what these mean in an interesting way. Use examples and anecdotes.
  5. If you use a PowerPoint, just put the highlights on it and don’t read from the slides. Have the PowerPoint supplement and substantiate what you are saying and give the audience - and you - a roadmap of what your talk is about. Graphics are better than words.
  6. Be yourself. Relax. Speak to the audience as if you are speaking to a friend. Make eye contact and pause every now and then. It is okay to catch your breath and think. Take a sip of water when you need. If you feel nervous, tell the audience that. They will only like you more and do all they can to help you through.
  7. Add some humor. No, I don't mean the corny, canned one-liners that professional speakers use to open their talks, but funny anecdotes and light hearted comments through your talk. This relaxes and engages the audience and helps you connect.
  8. Don’t hide behind the podium. Be casual, comfortable, and move around a bit. You are there to connect with the audience and engage them - not to recite some facts and figures that they can read in an academic paper or book. 
One thing missing from the list above is the importance of grabbing the audience's attention at the outset.  Dale Carnegie Training has an article called "Presentation Tips Part 1: Opening a Presentation" that emphasizes the importance of a strong beginning to a presentation, and provides four examples of types of openings:
  1. Captivating Statement - Examples of such statements include making an analogy, startling the audience, or presenting good news.
  2. Question - The purpose of the question could be to gain information, to get participation, or to create agreement on a need or interest.
  3. Incident - The story could be from personal experience, that of a third party, or a relevant historical item.
  4. Compliment - The shout out could be to the immediate audience, to the larger organization, or to an individual.
I have had success with 1, 2 and 3.

One item not mentioned in either item is the importance of being brief and finishing on time.  As they say in show biz, leave them wanting more!

Tuesday, July 16, 2013

Engineering Versus Science

Henry Petroski is a professor at Duke and the author of some very interesting books on the topic of engineering.  In today's blog I share some thoughts on an article that he wrote on engineering versus science.

Several years ago Henry Petroski wrote an interesting article on the importance of engineering versus science in achieving change. Here is an excerpt:

        Most people who aren't scientists or engineers seem to think that science and engineering are the same. They're not. Science seeks to understand the world as it is; only engineering can change it.

That's not what most high-school teachers or even college professors tell their science students. But the truth is that full scientific understanding isn't always necessary for technological advancement. Take steam engines: They were pumping water out of mines long before a science of thermodynamics was developed to explain how they worked. The engines were what prompted researchers to look into the nature of steam power in the first place.

This may make me a heretic, but I'll take the argument a step farther: Science can actually get in the way of technology. In the 19th century, some scientists were convinced that even the largest steamship couldn't carry enough coal for transatlantic trips. Only when skeptical engineers designed ships that made this supposedly impossible task possible were the naysaying scientists forced to reconsider.

For those of us in the telecom/datacom space, Petroski's article reinforces the importance of what we are working on. Our primary goal is creating a successful business. The way that we will do that is by driving the continual improvement in the ability of people to communicate, both in terms of lower costs and higher bandwidth. That's the value we as engineers bring to the party.

Monday, July 15, 2013

Net Neutrality, Part 1

Note: This was originally published at the Overture Networks "Overtones" blog site at http://www.overturenetworks.com/connect-with-overture/overtones-blog/net-neutrality-part-1/. That site is no longer available.

“Net Neutrality” refers to the FCC ruling on the fair or non-discriminatory treatment of services and applications.  While the basics of Net Neutrality are simple, the ramifications are broad and complex. This blog is the first of a three part series. 
  • Part 1 describes the basic principles and applicability to residential versus business services.
  • Part 2 covers fixed versus mobile, the impact of competition, and the validity of the order.  It also provides pointers to additional resources.
  • Part 3 explores how the rules impact service providers, and how they could evolve.

Note that parts 1 and 2 will delve heavily into the order itself.  I am doing this because I have found that with legal documents it is best to start with first principles.  Of course, that is a good practice in many other parts of life. 

In this case, the first principles are the FCC order itself.  If you want to explore further, Part 2 provides a list of opinion pieces, and part 3 reflects some conversations with service providers. 

On to first principles!

What is Net Neutrality?

The concept of Net Neutrality has changed over time (see here for a history) and varies per geographic region.  The interpretation in the US today originates in the FCC’s Open Internet Report and Order, which was issued in December 2010.  The Open Internet Report and Order is quite detailed and lengthy, with 194 pages and 855 footnotes.   Fortunately, the meat of the Open Internet Report and Order is in the brief and formal “Rules”.  These are defined in Appendix A on page 88, which adds Part 8 of Title 47 to the Code of Federal Regulations.  They are also summarized online at http://www.fcc.gov/guides/open-Internet.  Here is the meat of Appendix A:

§ 8.3      Transparency.
A person engaged in the provision of broadband Internet access service shall publicly disclose accurate information regarding the network management practices, performance, and commercial terms of its broadband Internet access services sufficient for consumers to make informed choices regarding use of such services and for content, application, service, and device providers to develop, market, and maintain Internet offerings.

§ 8.5      No Blocking.
A person engaged in the provision of fixed broadband Internet access service, insofar as such person is so engaged, shall not block lawful content, applications, services, or non-harmful devices, subject to reasonable network management.

A person engaged in the provision of mobile broadband Internet access service, insofar as such person is so engaged, shall not block consumers from accessing lawful websites, subject to reasonable network management; nor shall such person block applications that compete with the provider’s voice or video telephony services, subject to reasonable network management.

§ 8.7      No Unreasonable Discrimination.
A person engaged in the provision of fixed broadband Internet access service, insofar as such person is so engaged, shall not unreasonably discriminate in transmitting lawful network traffic over a consumer’s broadband Internet access service. Reasonable network management shall not constitute unreasonable discrimination.



§ 8.11    Definitions.
(a) Broadband Internet access service. A mass-market retail service by wire or radio that provides the capability to transmit data to and receive data from all or substantially all Internet endpoints, including any capabilities that are incidental to and enable the operation of the communications service, but excluding dial-up Internet access service. This term also encompasses any service that the Commission finds to be providing a functional equivalent of the service described in the previous sentence, or that is used to evade the protections set forth in this Part.

(b) Fixed broadband Internet access service. A broadband Internet access service that serves end users primarily at fixed endpoints using stationary equipment. Fixed broadband Internet access service includes fixed wireless services (including fixed unlicensed wireless services), and fixed satellite services.

(c) Mobile broadband Internet access service. A broadband Internet access service that serves end users primarily using mobile stations.


(d) Reasonable network management. A network management practice is reasonable if it is appropriate and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband Internet access service.

Sounds straightforward, right?  Maybe.  These apparently simple rules are involved in a multi-party struggle between service providers, content and Over The Top (OTT) providers (such as Google and Netflix), the FCC, the courts and Congress.  The following sections will delve into the FCC’s order to see what it means.

Residential Only?

It is commonly understood that the current Net Neutrality rules apply only to consumer or residential services, and not to business or private services.  Is this understanding is correct?  Sections 45 and 46 on page 28 state:

45. “Mass market” means a service marketed and sold on a standardized basis to residential customers, small businesses, and other end-user customers such as schools and libraries.  … The term does not include enterprise service offerings, which are typically offered to larger organizations through customized or individually negotiated arrangements.


46. “Broadband Internet access service” encompasses services that “provide the capability to transmit data to and receive data from all or substantially all Internet endpoints.”

Section 45 seems to exempt enterprise service offerings if they are customized or negotiated.  Section 46 implies exemption for private services such as VPNs because they don’t provide access to “substantially all Internet endpoints.”  So, it would be accurate to say that typical enterprise or private networking services are not subject to the rules, but a standard internet offering to a commercial enterprise would be.  This is clarified in Section 54 and Footnote 172 on page 133, which state that “end user” and “consumer” also includes businesses:

54. The Open Internet NPRM sought comment on what end users and edge providers need to know about broadband service, how this information should be disclosed, when disclosure should occur, and where information should be available.171 The resulting record supports adoption of the following rule:
A person engaged in the provision of broadband Internet access service shall publicly disclose accurate information regarding the network management practices, performance, and commercial terms of its broadband Internet access services sufficient for consumers to make informed choices regarding use of such services and for content, application, service, and device providers to develop, market, and maintain Internet offerings. 172


172 For purposes of these rules, “consumer” includes any subscriber to the broadband provider’s broadband Internet access service, and “person” includes any “individual, group of individuals, corporation, partnership, association, unit of government or legal entity, however organized,” cf. 47 C.F.R. § 54.8(a)(6).

So, the key is the type of service, not the type of customer.

Come back next week for Part 2, which covers fixed versus mobile and the impact of competition, along with pointers to additional resources.