Thanks for all your efforts to keep the "feedback loop" to the rulemakers functioning!  

I'd like to offer a suggestion for a hopefully politically acceptable way to handle the deluge, derived from my own battles with "email" over the years (decades).

Back in the 1970s, I implemented one of the first email systems on the Arpanet, under the mentorship of JCR Licklider, who had been pursuing his vision of a "Galactic Network" at ARPA and MIT.   One of the things we discovered was the significance of anonymity.   At the time, anonymity was forbidden on the Arpanet; you needed an account on some computer, protected by passwords, in order to legitimately use the network.   The mechanisms were crude and easily broken, but the principle applied.

Over the years, that principle has been forgotten, and the right to be anonymous has become entrenched.   But many uses of the network, and needs of its users, demand accountability, so all sorts of mechanisms have been pasted on top of the network to provide ways to judge user identity.  Banks, medical services, governments, and businesses all demand some way of proving your identity, with passwords, various schemes of 2FA, VPNs, or other such technology, with varying degrees of protection.   It is still possible to be anonymous on the net, but many things you do require you to prove, to some extent, who you are.

So, my suggestion for handling the deluge of "comments" is:

1/ create some mechanism for "registering" your intent to submit a comment.   Make it hard for bots to register.  Perhaps you can leverage the work of various partners, e.g., ISPs, retailers, government agencies, financial institutions, of others who already have some way of identifying their users.

2/ Also make registration optional - anyone can still submit comments anonymously if they choose.

3/ for "registered commenters", provide a way to "edit" your previous comment - i.e., advise that your comment is always the last one you submitted.   I.E., whoever you are, you can only submit one comment, which will be the last one you submit.

4/ In the thousands of pages of comments, somehow flag the ones that are from registered commenters, visible to the people who read the comments.   Even better, provide those "information consumers" with ways to sort, filter, and search through the body of comments.

This may not reduce the deluge of comments, but I'd expect it to help the lawyers and politicians keep their heads above the water.

Anonymity is an important issue for Net Neutrality too, but I'll opine about that separately.....

Jack Haverty


On 10/2/23 12:38, David Bray, PhD via Nnagain wrote:
Greetings all and thank you Dave Taht for that very kind intro...

First, I'll open with I'm a gosh-darn non-partisan, which means I swore an oath to uphold the Constitution first and serve the United States - not a specific party, tribe, or ideology. This often means, especially in today's era of 24/7 news and social media, non-partisans have to "top cover".

Second, I'll share that in what happened in 2017 (which itself was 10x what we saw in 2014) my biggest concern was and remains that a few actors attempted to flood the system with less-than-authentic comments.

In some respects this is not new. The whole "notice and comment" process is a legacy process that goes back decades. And the FCC (and others) have had postcard floods of comments, mimeographed letters of comments, faxed floods of comments, and now this - which, when combined with generative AI, will be yet another flood. 

Which gets me to my biggest concern as a non-partisan in 2023-2024, namely how LLMs might misuse and abuse the commenting process further.

Both in 2014 and 2017, I asked FCC General Counsel if I could use CAPTChA to try to reduce the volume of web scrapers or bots both filing and pulling info from the Electronic Comment Filing System. 

Both times I was told *no* out of concerns that they might prevent someone from filing. I asked if I could block obvious spam, defined as someone filing a comment >100 times a minute, and was similarly told no because one of those possible comments might be genuine and/or it could be an ex party filing en masse for others. 

For 2017 we had to spin up 30x the number of AWS cloud instances to handle the load - and this was a flood of comments at 4am, 5am, and 6am ET at night which normally shouldn’t see such volumes. When I said there was a combination of actual humans wanting to leave comments and others who were effectively denying service to others (especially because if anyone wanted to do a batch upload of 100,000 comments or more they could submit a CSV file or a comment with 100,000 signatories) - both parties said no, that couldn’t be happening. 

Until 2021 when the NY Attorney General proved that was exactly what was happening with 18m of the 23m apparently from non-authentic origin with ~9m from one side of the political aisle (and six companies) and ~9m from the other side of the political aisle (and one or more teenagers). 

So with Net Neutrality back on the agenda - here’s a simple prediction, even if the volume of comments is somehow controlled, 10,000+ pages of comments produced by ChatGPT or a different LLM is both possible and probably will be done. The question is if someone includes a legitimate legal argument on page 6,517 - will FCC’s lawyers spot it and respond to it as part of the NPRM?

Hope this helps and with highest regards,

-d.
--

On Mon, Oct 2, 2023 at 2:15 PM Dave Taht via Nnagain <nnagain@lists.bufferbloat.net> wrote:
All:

I have spent the last several days reaching out to as many people I
know with a deep understanding of the policy and technical issues
surrounding the internet, to participate on this list. I encourage you
all to reach out on your own, especially to those that you can
constructively and civilly disagree with, and hopefully work with, to
establish technical steps forward. Quite a few have joined silently!
So far, 168 people have joined!

Please welcome Dr David Bray[1], a self-described "human flack jacket"
who, in the last NN debate, stood up for the non -partisan FCC IT team
that successfully kept the system up 99.4% of the time despite the
comment floods and network abuses from all sides. He has shared with
me privately many sad (and some hilarious!) stories of that era, and I
do kind of hope now, that some of that history surfaces, and we can
learn from it.

Thank you very much, David, for putting down your painful memories[2],
and agreeing to join here. There is a lot to tackle here, going
forward.

[1] https://www.stimson.org/ppl/david-bray/
[2] "Pain shared is reduced. Joy shared, increased." - Spider Robinson


--
Oct 30: https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
Dave Täht CSO, LibreQos
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