To: Chairman Tom Wheeler & the FCC Leaders Subject: Proposed Internet “Fast Lane” FCC Rules Mr. Tom Wheeler & FCC Commission, I am writing to you today as a twenty-year veteran of the technology industry in order to express broad and deep concerns that I have with the draft rules from the FCC that would allow internet service providers like Comcast to provide so called “internet fast lane” services. As it is today, customers of internet providers select a package for internet services. In the case of a 4G or cellular provider, often no speed is specified in the packages. However, an amount of data that can be transferred is specified as part of this package. For example, as of this writing, AT&T Wireless offers 5 gigabytes of data for $50. Similarly Comcast, a cable ISP, offers a package with a limit of 250 gigabytes stated in the terms-of-service. Unlike the 4G/cellular offering from AT&T, Comcast specifies a speed to go with the byte count – in this case up to 50 megabits per second. Comcast has stated that it is unable to deliver the service for which their customers have paid. As you are no doubt aware, Comcast and Netflix have negotiated and come to an agreement on this very point. Without directly throttling Netflix traffic in particular, Comcast allowed its network links to become saturated and this degraded the performance of Netflix. As a customer of Comcast, I am paying for a set number of bytes and a particular speed. If I choose to use the bytes for which I have paid on a service such as Netflix, it is by definition no legitimate concern of Comcast. If they’re saying that they cannot provide the level of service for which I have paid, then it is the FCC Commission’s responsibility to force Comcast to use plain and standardized language to indicate to me, the customer, what it is that I am paying for. AT&T also has a history of playing shady games with their data plans. They’ve been found guilty of overcharging for streaming video in at least one case, and the FCC has dealt with them on other issues such as limiting what devices or applications are allowed to use the data plan. Again, AT&T has no legitimate concern on how data that I have paid for is used. As an expert working in several fields, including internetworking services, I am certain that Comcast (and similar companies) are misrepresenting the truth (if not lying) of the situation: As a result of the Netflix/Comcast deal, the Netflix experience improved for Comcast customers literally overnight. That must indicate that Comcast had the network capacity for the Netflix traffic all along; How could they “flip a switch” and suddenly have the network capacity necessary for all those millions of Netflix customers? This is such a complex issue that it should be clear to anyone that it is not possible to properly establish & regulate an “internet fast lane” at this time. Here in this case we can see plainly sociopathic behavior from one of the largest communications companies in America, cleverly done in such a way as to do an end-run around the relatively weak rules the FCC had already established. No, for this “fast lane,” not only do we lack the technology, we lack the law and competency to adequately oversee these companies in these matters. Instead, what we need to focus on is ensuring fair and universal access to the internet for consumers and businesses alike. It isn’t hard to see that, if the speed & byte count numbers on these internet plans are essentially meaningless (as they have been in the Netflix example), then the “regular lane” would similarly and immediately become just as congested exactly as it was in the Comcast/Netflix debacle. There is nothing in the proposed rules that would or could prevent a scenario like this from playing out. Lastly, I would encourage all of you to explore the history and consolidation of these communication companies over the last twenty years; since the 1996 Telecommunications Act signed into law by President Clinton. This act provided direct funding and tax shelters for upgrades to broadband infrastructure in America that has never been realized. As a taxpayer and someone keenly attuned to technology, I would describe the collective behavior of communications companies as dishonest and fraudulent. Many books and articles have been published on this subject. Some authors have referred to this as the $200 billion dollar fraud.
Posted on: Sun, 27 Apr 2014 02:37:15 +0000
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