From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from mail-oi1-x231.google.com (mail-oi1-x231.google.com [IPv6:2607:f8b0:4864:20::231]) (using TLSv1.2 with cipher ECDHE-RSA-AES128-GCM-SHA256 (128/128 bits)) (No client certificate requested) by lists.bufferbloat.net (Postfix) with ESMTPS id C4ACB3B29D for ; Tue, 10 Oct 2023 11:53:41 -0400 (EDT) Received: by mail-oi1-x231.google.com with SMTP id 5614622812f47-3ae1916ba69so4012595b6e.2 for ; Tue, 10 Oct 2023 08:53:41 -0700 (PDT) DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=shinkuro-com.20230601.gappssmtp.com; s=20230601; t=1696953221; x=1697558021; darn=lists.bufferbloat.net; h=cc:to:subject:message-id:date:from:in-reply-to:references :mime-version:from:to:cc:subject:date:message-id:reply-to; bh=n21fwJDJjViW2kL1eqSTIY532JHbuvEbtZGpHL2wZik=; b=TZUYr/t0+Qz2WJSnigVU6YU+T44WS0Uh3ib6xUOaXXOeeDg7Q4HFgjkklIfXKO4N2M NDqutRHyyHh6gmv0pwYEpn41cGVNx4ONvt1N/Ag63/sukr0fBe3rmjGtGo6MRpmYKAxS naUlKzB1xBi8/V3ViSj/QqSVOoDbC5dyl7Rsj/nIEXgtFBm36kJLTmx8zPe/Vd2Pv7zJ fbfeJZ7ArCYaG7kwSP9ruURqRHuR9SRVsxnMHhbAsMVZObm3kS/zbPrwLfmjosgIP++s L4kHliWML0EJny0x8EYtuX9FejPCR1NcggStPBp2AJdndvC+BsGhFuZLJqyIvK8FaeeV GElA== X-Google-DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=1e100.net; s=20230601; t=1696953221; x=1697558021; h=cc:to:subject:message-id:date:from:in-reply-to:references :mime-version:x-gm-message-state:from:to:cc:subject:date:message-id :reply-to; bh=n21fwJDJjViW2kL1eqSTIY532JHbuvEbtZGpHL2wZik=; b=bOmHht5sdZziI+93RDQqSsPyTxoqs7IhH+DGaLFhBKbmac+z0XxILOr6LzPHlp15xZ Q4XjWlOySWQNDHErfJQ6451laOpTKHwJtmWsK1h5II4Rx+adz8AisuffHK+VNFGUUI9G oH9lWIHfJjVFrCE1pXMCK4tfUkZAHnE40pogPoG+mpXWRuQzufvBvCKLo+B5X0s2pMb4 KJs6r3uwWC9kpZwM6xDhkuXMFBr2PNLy++jI191OYxy1VZjxKD3PRETLa0XmgubVdJAm A7rtwd+N/ir+A0x38Bi8LP2au9A+rXPhF5Hqlm+mWIxxrbq6rOgFYdHOgT/UcUjFjv97 7awg== X-Gm-Message-State: AOJu0YxyAYP8JzTtpkNnZX5LQqhcuWCKCaDqPu//5pxaY8zoymQQg8xl lpCBY7cGBPYVvftH1tP/D5L5ruifwieSae9u/wmeIDH8bwVHGksp/X4= X-Google-Smtp-Source: AGHT+IHo7myonbz/goJDPQbkQtzF3SM+zp8iU1A2wv+IOM2nxYADJSyQgEjbegfbH0yXcQMoSiNbhRYweW2KlWJ4qWo= X-Received: by 2002:a05:6808:2028:b0:3a7:2570:dcfc with SMTP id q40-20020a056808202800b003a72570dcfcmr24746024oiw.43.1696953220448; Tue, 10 Oct 2023 08:53:40 -0700 (PDT) MIME-Version: 1.0 References: <028f61d7-be24-4fe3-82d3-6eca0386d0d0@3kitty.org> <10976208-a880-4974-9f13-d84a7b5ebb6b@3kitty.org> <319cc107-f753-4e2a-8b72-6595117ae37b@3kitty.org> In-Reply-To: From: Steve Crocker Date: Tue, 10 Oct 2023 11:53:29 -0400 Message-ID: To: =?UTF-8?Q?Network_Neutrality_is_back=21_Let=C2=B4s_make_the_technical_asp?= =?UTF-8?Q?ects_heard_this_time=21?= Content-Type: multipart/alternative; boundary="000000000000e7f1b206075eb5ea" Subject: Re: [NNagain] somewhat OT: Licklidder X-BeenThere: nnagain@lists.bufferbloat.net X-Mailman-Version: 2.1.20 Precedence: list List-Id: =?utf-8?q?Network_Neutrality_is_back!_Let=C2=B4s_make_the_technical_aspects_heard_this_time!?= List-Unsubscribe: , List-Archive: List-Post: List-Help: List-Subscribe: , X-List-Received-Date: Tue, 10 Oct 2023 15:53:42 -0000 --000000000000e7f1b206075eb5ea Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Lots of good stuff here and I missed the earlier posts, but one small thing caught my attention: > About 10 years ago, I accidentally got involved in a patent dispute to be an "expert witness", for a patent involving downloading new programs over a communications path into a remote computer (yes, what all our devices do almost every day). In the seminal period of late 1968 and early 1969 when we were thinking about Arpanet protocols, one idea that was very much part of our thinking was downloading a small program at the beginning of an interactive session. The downloaded program would take care of local interactions to avoid the need to send every character across the net only to have it echoed remotely. Why not always use local echo? Because most of the time-shared systems in the various ARPA-supported research environments had distinct ways of interpreting each and every character. Imposing a network-wide rule of local echoing would have compromised the usability of most of the systems on the Arpanet. I think Multics was the only "modern" line-at-a-time system at the time. In March 1969 we decided it was time to write down the ideas from our meetings in late 1968 and early 1969. The first batch of RFCs included Rulifson's RFC 5. He proposed DEL, the Decode-Encode Language. Elie's RFC 51 a year later proposed the Network Interchange Language. In both cases the basic concept was the creation of a simple language, easily implementable on each platform, that would mediate the interaction with a remote system. The programs were expected to be short -- hence downloadable quickly -- and either interpreted or quickly translated. There was a tiny bit of experimental work along this line, but it was far ahead of its time. I think it was about 25 years before ActiveX came along, followed by Java. Steve On Tue, Oct 10, 2023 at 11:30=E2=80=AFAM Dave Taht via Nnagain < nnagain@lists.bufferbloat.net> wrote: > On Mon, Oct 9, 2023 at 7:56=E2=80=AFPM Jack Haverty via Nnagain > wrote: > > For starters it is an honor to be conversing with folk that knew Bob > Taylor, and "Lick", and y'all made me go back and re-read > > http://memex.org/licklider.pdf > > For inspiration. I think everyone in our field should re-read that, > periodically. For example he makes an overgeneralization about the > thinking processes of men, as compared to the computers of the time, > and not to women... > > But I have always had an odd question - what songs did Lick play on > guitar? Do any recordings exist? > > Music defines who I am, at least. I love the angularness and surprises > in jazz, and the deep storytelling buried deep in Shostakovich's > Fifth. Moving forward to modern music: the steady backbeat of Burning > Man - and endless repetition of short phrases - seems to lead to > groupthink - I can hardly stand EDM for an hour. > > I am "maked" by Angela' Lansbury's Sweeny Todd, and my religion, > forever reformed by Monty Python's Life of Brian, One Flew over the > Cookoos nest, 12 Angry Men, and the 12 Monkees, Pink Floyd and punk > music were the things that shaped me. No doubt it differs > significantly for everyone here, please share? > > Powerful tales and their technologies predate the internet, and > because they were wildly shared, influenced how generations thought > without being the one true answer. Broadcast media, also, was joint, > and in school we > > We are in a new era of uncommonality of experience, in part from > bringing in all the information in the world, while still separated by > differences in language, exposure, education, and culture, although > nowadays it has become so easy and natural to be able to use computer > assisted language translation tools, I do not know how well they truly > make the jump between cultures. > > In that paper he talked about 75% of his time being spent setting up > to do analytics, where today so much information exists as to be > impossible to analyze. > > I only have a few more small comments below, but I wanted to pick out > the concepts of TOS and backpressure as needing thought on another > day, in another email (what was licks song list??? :)). The internet > has very little Tos or backpressure, and Flow Queuing based algorithms > actually function thusly: > > If the arrival rate of a flow is less than the departure rate of all > other flows, it goes out first. > > To some extent this matches some of Nagles' "every application has a > right to one packet in the network", and puts a reward into the system > for applications that use slightly less than their fair share of the > bandwidth. > > > IMHO, the problem may be that the Internet, and computing technology in > general, is so new that non-technical organizations, such as government > entities, don't understand it and therefore can't figure out whether or h= ow > to regulate anything involved. > > > > In other, older, "technologies", rules, procedures, and traditions have > developed over the years to provide for feedback and control between > governees and governors. Roberts Rules of Order was created 150 years ag= o, > and is still widely used to manage public meetings. I've been in local > meetings where everyone gets a chance to speak, but are limited to a few > minutes to say whatever's on their mind. You have to appear in person, > wait your turn, and make your comment. Doing so is free, but still has t= he > cost of time and hassle to get to the meeting. > > > > Organizations have figured out over the years how to manage meetings. > [Vint - remember the "Rathole!" mechanism that we used to keep Internet > meetings on track...?] > > PARC had "Dealer". > > > From what David describes, it sounds like the current "public comment" > mechanisms in the electronic arena are only at the stage where the loudes= t > voices can drown out all others, and public debates are essentially usele= ss > cacophonies of the loudest proponents of the various viewpoints. There > are no rules. Why should anyone submit their own sensible comments, > knowing they'll be lost in the noise? > > > > In non-electronic public forums, such behavior is ruled out, and if it > persists, the governing body can have offenders ejected, adjourn a meetin= g > until cooler heads prevail, or otherwise make the discourse useful for > informing decisions. Courts can issue restraining orders, but has any > court ever issued such an order applying to an electronic forum? > > > > So, why haven't organizations yet developed rules and mechanisms for > managing electronic discussions....? > > > > I'd offer two observations and suggestions. > > > > ----- > > > > First, a major reason for a lack of such rules and mechanisms may be an > educational gap. Administrators, politicians, and staffers may simply no= t > understand all this newfangled technology, or how it works, and are > drowning in a sea of terminology, acronyms, and concepts that make no sen= se > (to them). In the FCC case, even the technical gurus may have deep > knowledge of their traditional realm of telephony, radio, and related > issues and policy tradeoffs. But they may be largely ignorant of > computing and networking equivalents. Probably even worse, they may > unconsciously consider the new world as a simple evolution of the old, no= t > recognizing the impact of incredibly fast computers and communications, a= nd > the advances that they enable, such as "AI" - whatever that is... > > > > About 10 years ago, I accidentally got involved in a patent dispute to > be an "expert witness", for a patent involving downloading new programs > over a communications path into a remote computer (yes, what all our > devices do almost every day). I was astounded when I learned how little > the "judicial system" (lawyers, judges, legislators, etc.) knew about > computer and network technology. That didn't stop them from debating th= e > meaning of technical terms. What is RAM? How does "programming" differ > from "reprogramming"? What is "memory"? What is a "processor"? What i= s > an "operating system"? The arguments continue until eventually a judge > declares what the answer is, with little technical knowledge or expertise > to help. So you can easily get legally binding definitions such as > "operating system" means "Windows", and that all computers contain an > operating system. > > > > I spent hours on the phone over about 18 months, explaining to the > lawyers how computers and networks actually worked. In turn, they taugh= t > me quite a lot about the vagaries of the laws and patents. It was > fascinating but also disturbing to see how ill-prepared the legal system > was for new technologies. > > > > So, my suggestion is that a focus be placed on helping the non-technica= l > decision makers understand the nuances of computing and the Internet. I > don't think that will be successful by burying them in the sea of technic= al > jargon and acronyms. > > > > Before I retired, I spent a lot of time with C-suite denizens from > companies outside of the technology industry - banks, manufacturers, > transportation, etc. - helping them understand what "The Internet" was, a= nd > help them see it as both a huge opportunity and a huge threat to their > businesses. One technique I used was simply stolen from the early days o= f > The Internet. > > > > When we were involved in designing the internal mechanisms of the > Internet, in particular TCPV4, we didn't know much about networks either. > So we used analogies. In particular we used the existing transportation > infrastructure as a model. Moving bits around the world isn't all that > different from moving goods and people. But everyone, even with no > technical expertise, knows about transportation. > > > > It turns out that there are a lot of useful analogies. For example, we > recognized that there were different kinds of "traffic" with different > needs. Coal for power plants was important, but not urgent. If a coal > train waits on a siding while a passenger train passes, it's OK, even > preferred. There could be different "types of service" available from t= he > transportation infrastructure. At the time (late 1970s) we didn't know > exactly how to do that, but decided to put a field in the IP header as a > placeholder - the "TOS" field. Figuring out what different TOSes there > should be, and how they would be handled differently, was still on the > to-do list. There are even analogies to the Internet - goods might trav= el > over a "marine network" to a "port", where they are moved onto a "rail > network", to a distributor, and moved on the highway network to their fin= al > destination. Routers, gateways, ... > > > > Other transportation analogies reinforced the notion of TOS. E.g., if > you're sending a document somewhere, you can choose how to send it - norm= al > postal mail, or Priority Mail, or even use a different "network" such as = an > overnight delivery service. Different TOS would engage different behavio= rs > of the underlying communications system, and might also have different > costs to use them. Sending a ton of coal to get delivered in a week or t= wo > would cost a lot less than sending a ton of documents for overnight > delivery. > > > > There were other transportation analogies heard during the TCPV4 design > discussions - e.g., "Expressway Routing" (do you take a direct route over > local streets, or go to the freeway even though it's longer) and > "Multi-Homing" (your manufacturing plant has access to both a highway and= a > rail line). > > > > Suggestion -- I suspect that using a familiar infrastructure such as > transport to discuss issues with non-technical decision makers would be > helpful. E.g., imagine what would happen if some particular "net > neutrality" set of rules was placed on the transportation infrastructure? > Would it have a desirable effect? > > > > ----- > > > > Second, in addition to anonymity as an important issue in the electroni= c > world, my experience as a mentee of Licklider surfaced another important > issue in the "galactic network" vision -- "Back Pressure". The notion > is based in existing knowledge. Economics has notions of Supply and > Demand and Cost Curves. Engineering has the notion of "Negative Feedbac= k" > to stabilize mechanical, electrical, or other systems. > > > > We discussed Back Pressure, in the mid 70s, in the context of electroni= c > mail, and tried to get the notion of "stamps" accepted as part of the ema= il > mechanisms. The basic idea was that there had to be some form of "back > pressure" to prevent overload by discouraging sending of huge quantities = of > mail. > > > > At the time, mail traffic was light, since every message was typed by > hand by some user. In Lick's group we had experimented with using email = as > a way for computer programs to interact. In Lick's vision, humans would > interact by using their computers as their agents. Even then, computers > could send email a lot faster and continuously than any human at a > keyboard, and could easily flood the network. [This epiphany occurred > shortly after a mistake in configuring distribution lists caused so many > messages and replies that our machine crashed as its disk space ran out.] > > > > "Stamps" didn't necessarily represent monetary cost. Back pressure > could be simple constraints, e.g., no user can send more than 500 (or > whatever) messages per day. This notion never got enough support to > become part of the email standards; I still think it would help with the > deluge of spam we all experience today. > > > > Back Pressure in the Internet today is largely non-existent. I (or my > AI and computers) can send as much email as I like. Communications > carriers promote "unlimited data" but won't guarantee anything. Memory > has become cheap, and as a result behaviors such as "buffer bloat" have > appeared. > > > > Suggestion - educate the decision-makers about Back Pressure, using > highway analogies (metering lights, etc.) > > > > ----- > > > > Education about the new technology, but by using some familiar analogs, > and introduction of Back Pressure, in some appropriate form, as part of a > "network neutrality" policy, would be the two foci I'd recommend. > > > > My prior suggestion of "registration" and accepting only the last > comment was based on the observations above. Back pressure doesn't have = to > be monetary, and registered users don't have to be personally identified. > Simply making it sufficiently "hard" to register (using CAPTCHAs, 2FA, > whatever) would be a "cost" discouraging "loud voices". Even the law > firms submitting millions of comments on behalf of their clients might ba= lk > at the cost (in labor not money) to register their million clients, even > anonymously, so each could get his/her comment submitted. Of course, th= ey > could always pass the costs on to their (million? really?) clients. But = it > would still be Back Pressure. > > > > One possibility -- make the "cost" of submitting a million electronic > comments equal to the cost of submitting a million postcards...? > > > > Jack Haverty > > > > > > On 10/9/23 16:55, David Bray, PhD wrote: > > > > Great points Vint as you're absolutely right - there are multiple > modalities here (and in the past it was spam from thousands of postcards, > then mimeographs, then faxes, etc.) > > > > The standard historically has been set by the Administrative Conference > of the United States: https://www.acus.gov/about-acus > > > > In 2020 there seemed to be an effort to gave the General Services > Administration weigh-in, however they closed that rulemaking attempt > without publishing any of the comments they got and no announcement why i= t > was closed. > > > > As for what part of Congress - I believe ACUS was championed by both th= e > Senate and House Judiciary Committees as it has oversight and > responsibility for the interpretations of the Administrative Procedure Ac= t > of 1946 (which sets out the whole rulemaking procedure). > > > > Sadly there isn't a standard across agencies - which also means there > isn't a standard across Administrations. Back in 2018 and 2020, both with > this group of 52 people here https://tinyurl.com/letter-signed-52-people > - as well as individually - I did my darnest to encourage them to do a > standard. > > > > There's also the National Academy of Public Administration which is > probably the latest remaining non-partisan forum for discussions like thi= s > too. > > > > > > On Mon, Oct 9, 2023 at 7:46=E2=80=AFPM Vint Cerf wrot= e: > >> > >> David, this is a good list. > >> FACA has rules for public participation, for example. > >> > >> I think it should be taken into account for any public commenting > process that online (and offline such as USPS or fax and phone calls) tha= t > spam and artificial inflation of comments are possible. Is there any > specific standard for US agency public comment handling? If now, what > committees of the US Congress might have jurisdiction? > >> > >> v > >> > >> > >> On Tue, Oct 10, 2023 at 8:22=E2=80=AFAM David Bray, PhD via Nnagain < > nnagain@lists.bufferbloat.net> wrote: > >>> > >>> I'm all for doing new things to make things better. > >>> > >>> At the same time, I used to do bioterrorism preparedness and response > from 2000-2005 (and aside from asking myself what kind of crazy world > needed counter-bioterrorism efforts... I also realized you don't want to > interject something completely new in the middle of an unfolding crisis > event). If something were to be injected now, it would have to have > consensus from both sides, otherwise at least one side (potentially > detractors from both) will claim that whatever form the new approaches ta= ke > are somehow advantaging "the other side" and disadvantaging them. > >>> > >>> Probably would take a ruling by the Administrative Conference of the > United States, at a minimum to answer these five questions - and even the= n, > introducing something completely different in the midst of a political > melee might just invite mudslinging unless moderate voices on both sides > can reach some consensus. > >>> > >>> 1. Does identity matter regarding who files a comment or not =E2=80= =94 and > must one be a U.S. person in order to file? > >>> > >>> 2. Should agencies publish real-time counts of the number of comments > received =E2=80=94 or is it better to wait until the end of a commenting = round to > make all comments available, including counts? > >>> > >>> 3. Should third-party groups be able to file on behalf of someone els= e > or not =E2=80=94 and do agencies have the right to remove spam-like comme= nts? > >>> > >>> 4. Should the public commenting process permit multiple comments per > individual for a proceeding =E2=80=94 and if so, how many comments from a= single > individual are too many? 100? 1000? More? > >>> > >>> 5. Finally, should the U.S. government itself consider, given public > perceptions about potential conflicts of interest for any agency performi= ng > a public commenting process, whether it would be better to have third-par= ty > groups take responsibility for assembling comments and then filing those > comments via a validated process with the government? > >>> > >>> > >>> > >>> On Sat, Oct 7, 2023 at 4:10=E2=80=AFPM Jack Haverty = wrote: > >>>> > >>>> Hi again David et al, > >>>> > >>>> Interesting frenzy...lots of questions that need answers and > associated policies. I served 6 years as an elected official (in a smal= l > special district in California), so I have some small understanding of th= e > government side of things and the constraints involved. Being in charge > doesn't mean you can do what you want. > >>>> > >>>> I'm thinking here more near-term and incremental steps. You said > "These same questions need pragmatic pilots that involve the public ..." > >>>> > >>>> So, how about using the current NN situation for a pilot? Keep all > the current ways and emerging AI techniques to continue to flood the syst= em > with comments. But also offer an *optional* way for humans to "register= " > as a commenter and then submit their (latest only) comment into the melee= . > Will people use it? Will "consumers" (the lawyers, commissioners, etc.) > find it useful? > >>>> > >>>> I've found it curious, for decades now, that there are (too many) > mechanisms for "secure email", that may help with the flood of > disinformation from anonymous senders, but very very few people use them. > Maybe they don't know how; maybe the available schemes are too flawed; > maybe ...? > >>>> > >>>> About 30 years ago, I was a speaker in a public meeting orchestrated > by USPS, and recommended that they take a lead role, e.g., by acting as a > national CA - certificate authority. Never happened though. FCC issues > lots of licenses...perhaps they could issue online credentials too? > >>>> > >>>> Perhaps a "pilot" where you will also accept comments by email, some > possibly sent by "verified" humans if they understand how to do so, would > be worth trying? Perhaps comments on "technical aspects" coming from > people who demonstrably know how to use technology would be valuable to t= he > policy makers? > >>>> > >>>> The Internet, and technology such as TCP, began as an experimental > pilot about 50 years ago. Sometimes pilots become infrastructures. > >>>> > >>>> FYI, I'm signing this message. Using OpenPGP. I could encrypt it > also, but my email program can't find your public key. > >>>> > >>>> Jack Haverty > >>>> > >>>> > >>>> On 10/5/23 14:21, David Bray, PhD wrote: > >>>> > >>>> Indeed Jack - a few things to balance - the Administrative Procedure > Act of 1946 (on which the idea of rulemaking is based) us about raising > legal concerns that must be answered by the agency at the time the > rulemaking is done. It's not a vote nor is it the case that if the agency > gets tons of comments in one direction that they have to go in that > direction. Instead it's only about making sure legal concerns are > considered and responded to before the agency before the agency acts. > (Which is partly why sending "I'm for XYZ" or "I'm against ABC" really > doesn't mean anything to an agency - not only is that not a legal argumen= t > or concern, it's also not something where they're obligated to follow the= se > comments - it's not a vote or poll). > >>>> > >>>> That said, political folks have spun things to the public as if it i= s > a poll/vote/chance to act. The raise a valid legal concern part of the AP= A > of 1946 is omitted. Moreover the fact that third party law firms and othe= rs > like to submit comments on behalf of clients - there will always be a thi= rd > party submitting multiple comments for their clients (or "clients") becau= se > that's their business. > >>>> > >>>> In the lead up to 2017, the Consumer and Government Affairs Bureau o= f > the FCC got an inquiry from a firm asking how they could submit 1 million > comments a day on an "upcoming privacy proceeding" (their words, astute > observers will note there was no privacy proceeding before the FCC in > 2017). When the Bureau asked me, I told them either mail us a CD to uploa= d > it or submit one comment with 1 million signatures. To attempt to flood u= s > with 1 million comments a day (aside from the fact who can "predict" havi= ng > that many daily) would deny resources to others. In the mess that followe= d, > what was released to the public was so redacted you couldn't see the > legitimate concerns and better paths that were offered to this entity. > >>>> > >>>> And the FCC isn't alone. EPA, FTC, and other regulatory agencies hav= e > had these hijinks for years - and before the Internet it was faxes, mass > mimeographs (remember blue ink?), and postcards.The Administrative > Conference of the United States (ACUS) - is the body that is supposed to > provide consistent guidance for things like this across the U.S. > government. I've briefed them and tried to raise awareness of these issue= s > - as I think fundamentally this is a **process** question that once > answered, tech can support. However they're not technologies and updating > the interpretation of the process isn't something lawyers are apt to do > until the evidence that things are in trouble is overwhelming. > >>>> > >>>> 52 folks wrote a letter to them - and to GSA - back in 2020. GSA had > a rulemaking of its own on how to improve things, yet oddly never publish= ed > any of the comments it received (including ours) and closed the rulemakin= g > quietly. Here's the letter: https://tinyurl.com/letter-signed-52-people > >>>> > >>>> And here's an article published in OODAloop about this - and why > Generative AI is probably going to make things even more challenging: > https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development= -is-not-the-answer-an-insiders-perspective/ > >>>> > >>>> [snippet of the article] Now in 2023 and Beyond: Proactive Approache= s > to AI and Society > >>>> > >>>> Looking to the future, to effectively address the challenges arising > from AI, we must foster a proactive, results-oriented, and cooperative > approach with the public. Think tanks and universities can engage the > public in conversations about how to work, live, govern, and co-exist wit= h > modern technologies that impact society. By involving diverse voices in t= he > decision-making process, we can better address and resolve the complex > challenges AI presents on local and national levels. > >>>> > >>>> In addition, we must encourage industry and political leaders to > participate in finding non-partisan, multi-sector solutions if civil > societies are to remain stable. By working together, we can bridge the ga= p > between technological advancements and their societal implications. > >>>> > >>>> Finally, launching AI pilots across various sectors, such as work, > education, health, law, and civil society, is essential. We must learn by > doing on how we can create responsible civil environments where AIs can b= e > developed and deployed responsibly. These initiatives can help us better > understand and integrate AI into our lives, ensuring its potential is > harnessed for the greater good while mitigating risks. > >>>> > >>>> In 2019 and 2020, a group of fifty-two people asked the > Administrative Conference of the United States (which helps guide > rulemaking procedures for federal agencies), General Accounting Office, a= nd > the General Services Administration to call attention to the need to > address the challenges of chatbots flooding public commenting procedures > and potentially crowding out or denying services to actual humans wanting > to leave a comment. We asked: > >>>> > >>>> 1. Does identity matter regarding who files a comment or not =E2=80= =94 and > must one be a U.S. person in order to file? > >>>> > >>>> 2. Should agencies publish real-time counts of the number of comment= s > received =E2=80=94 or is it better to wait until the end of a commenting = round to > make all comments available, including counts? > >>>> > >>>> 3. Should third-party groups be able to file on behalf of someone > else or not =E2=80=94 and do agencies have the right to remove spam-like = comments? > >>>> > >>>> 4. Should the public commenting process permit multiple comments per > individual for a proceeding =E2=80=94 and if so, how many comments from a= single > individual are too many? 100? 1000? More? > >>>> > >>>> 5. Finally, should the U.S. government itself consider, given public > perceptions about potential conflicts of interest for any agency performi= ng > a public commenting process, whether it would be better to have third-par= ty > groups take responsibility for assembling comments and then filing those > comments via a validated process with the government? > >>>> > >>>> These same questions need pragmatic pilots that involve the public t= o > co-explore and co-develop how we operate effectively amid these > technological shifts. As the capabilities of LLMs continue to grow, we ne= ed > positive change agents willing to tackle the messy issues at the > intersection of technology and society. The challenges are immense, but s= o > too are the opportunities for positive change. Let=E2=80=99s seize this m= oment to > create a better tomorrow for all. Working together, we can co-create a > future that embraces AI=E2=80=99s potential while mitigating its risks, i= nformed by > the hard lessons we have already learned. > >>>> > >>>> Full article: > https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development= -is-not-the-answer-an-insiders-perspective/ > >>>> > >>>> Hope this helps. > >>>> > >>>> > >>>> On Thu, Oct 5, 2023 at 4:44=E2=80=AFPM Jack Haverty via Nnagain < > nnagain@lists.bufferbloat.net> wrote: > >>>>> > >>>>> 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 w= e > discovered was the significance of anonymity. At the time, anonymity wa= s > forbidden on the Arpanet; you needed an account on some computer, protect= ed > 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 hav= e > 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 t= o > 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 t= he > work of various partners, e.g., ISPs, retailers, government agencies, > financial institutions, of others who already have some way of identifyin= g > 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 tha= t > 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 State= s > - 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 a= nd > 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 b= e > 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 E= T > at night which normally shouldn=E2=80=99t see such volumes. When I said t= here was a > combination of actual humans wanting to leave comments and others who wer= e > effectively denying service to others (especially because if anyone wante= d > 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=E2=80=99t be happening. > >>>>> > >>>>> Until 2021 when the NY Attorney General proved that was exactly wha= t > was happening with 18m of the 23m apparently from non-authentic origin wi= th > ~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=E2=80=99s 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 legitima= te > legal argument on page 6,517 - will FCC=E2=80=99s lawyers spot it and res= pond to it > as part of the NPRM? > >>>>> > >>>>> Hope this helps and with highest regards, > >>>>> > >>>>> -d. > >>>>> -- > >>>>> > >>>>> Principal, LeadDoAdapt Ventures, Inc. & Distinguished Fellow > >>>>> > >>>>> Henry S. Stimson Center, Business Executives for National Security > >>>>> > >>>>> > >>>>> > >>>>> On Mon, Oct 2, 2023 at 2:15=E2=80=AFPM 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 silentl= y! > >>>>>> 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 wi= th > >>>>>> 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 ca= n > >>>>>> 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 T=C3=A4ht CSO, LibreQos > >>>>>> _______________________________________________ > >>>>>> Nnagain mailing list > >>>>>> Nnagain@lists.bufferbloat.net > >>>>>> https://lists.bufferbloat.net/listinfo/nnagain > >>>>> > >>>>> > >>>>> _______________________________________________ > >>>>> Nnagain mailing list > >>>>> Nnagain@lists.bufferbloat.net > >>>>> https://lists.bufferbloat.net/listinfo/nnagain > >>>>> > >>>>> > >>>>> _______________________________________________ > >>>>> Nnagain mailing list > >>>>> Nnagain@lists.bufferbloat.net > >>>>> https://lists.bufferbloat.net/listinfo/nnagain > >>>> > >>>> > >>> _______________________________________________ > >>> Nnagain mailing list > >>> Nnagain@lists.bufferbloat.net > >>> https://lists.bufferbloat.net/listinfo/nnagain > >> > >> > >> > >> -- > >> Please send any postal/overnight deliveries to: > >> Vint Cerf > >> Google, LLC > >> 1900 Reston Metro Plaza, 16th Floor > >> Reston, VA 20190 > >> +1 (571) 213 1346 > >> > >> > >> until further notice > >> > >> > >> > > > > _______________________________________________ > > Nnagain mailing list > > Nnagain@lists.bufferbloat.net > > https://lists.bufferbloat.net/listinfo/nnagain > > > > -- > Oct 30: > https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html > Dave T=C3=A4ht CSO, LibreQos > _______________________________________________ > Nnagain mailing list > Nnagain@lists.bufferbloat.net > https://lists.bufferbloat.net/listinfo/nnagain > --000000000000e7f1b206075eb5ea Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable
Lots of good stuff here and I misse= d the earlier posts, but one small thing caught my attention:

> About 10 years ago, I accidentall= y got involved in a patent dispute to be an "expert witness", for= a patent involving downloading new programs over a communications path int= o a remote computer (yes, what all our devices do almost every day).=C2=A0<= /span>

In the seminal period of late 1968 and early 1969 when we w= ere thinking about Arpanet protocols, one idea that was very much part of o= ur thinking was downloading a small program at the beginning of an interact= ive session.=C2=A0 The downloaded program would take care of local interact= ions to avoid the need to send every character across the net only to have = it echoed remotely.=C2=A0 Why not always use local echo?=C2=A0 Because most= of the=C2=A0time-shared systems in the various ARPA-supported research env= ironments had distinct ways of interpreting each and every=C2=A0character.= =C2=A0 Imposing a network-wide rule of local echoing would have compromised= the usability of most of the systems on the Arpanet.=C2=A0 I think Multics= was the only "modern" line-at-a-time system at the time.

In March 1969 w= e decided it was time to write down the ideas from our meetings in late 196= 8 and early 1969.=C2=A0 The first batch of RFCs included Rulifson's=C2= =A0RFC 5.=C2=A0 He proposed DEL, the Decode-Encode Language.=C2=A0 Elie'= ;s RFC 51 a year later proposed the Network Interchange Language.=C2=A0 In = both cases the basic concept was the creation of a simple language, easily = implementable on each platform, that would mediate the interaction with a r= emote system.=C2=A0 The programs were expected to be short -- hence downloa= dable quickly -- and either interpreted or quickly translated.=C2=A0 There = was a tiny bit of experimental work along this line, but it was far ahead o= f its time.=C2=A0 I think it was about 25 years before ActiveX came along, = followed by Java.

Steve


On Tue, Oct 10, 2023 at 11:30=E2=80=AFAM Dave Taht= via Nnagain <nnagain@lists.bufferbloat.net> wrote:
On Mon, Oct 9, 2023 at 7:56=E2=80=AFP= M Jack Haverty via Nnagain
<nnag= ain@lists.bufferbloat.net> wrote:

For starters it is an honor to be conversing with folk that knew Bob
Taylor, and "Lick", and y'all made me go back and re-read

http://memex.org/licklider.pdf

For inspiration. I think everyone in our field should re-read that,
periodically. For example he makes an overgeneralization about the
thinking processes of men, as compared to the computers of the time,
and not to women...

But I have always had an odd question - what songs did Lick play on
guitar? Do any recordings exist?

Music defines who I am, at least. I love the angularness and surprises
in jazz, and the deep storytelling buried deep in Shostakovich's
Fifth. Moving forward to modern music: the steady backbeat of Burning
Man - and endless repetition of short phrases - seems to lead to
groupthink - I can hardly stand EDM for an hour.

=C2=A0I am "maked" by Angela' Lansbury's Sweeny Todd, and= my religion,
forever reformed by Monty Python's Life of Brian, One Flew over the
Cookoos nest, 12 Angry Men, and the 12 Monkees, Pink Floyd and punk
music were the things that shaped me. No doubt it differs
significantly for everyone here, please share?

Powerful tales and their technologies predate the internet, and
because they were wildly shared, influenced how generations thought
without being the one true answer. Broadcast media, also, was joint,
and in school we

We are in a new era of uncommonality of experience, in part from
bringing in all the information in the world, while still separated by
differences in language, exposure, education, and culture, although
nowadays it has become so easy and natural to be able to use computer
assisted language translation tools, I do not know how well they truly
make the jump between cultures.

In that paper he talked about 75% of his time being spent setting up
to do analytics, where today so much information exists as to be
impossible to analyze.

I only have a few more small comments below, but I wanted to pick out
the concepts of TOS and backpressure as needing thought on another
day, in another email (what was licks song list??? :)). The internet
has very little Tos or backpressure, and Flow Queuing based algorithms
actually function thusly:

If the arrival rate of a flow is less than the departure rate of all
other flows, it goes out first.

To some extent this matches some of Nagles' "every application has= a
right to one packet in the network", and puts a reward into the system=
for applications that use slightly less than their fair share of the
bandwidth.

> IMHO, the problem may be that the Internet, and computing technology i= n general, is so new that non-technical organizations, such as government e= ntities, don't understand it and therefore can't figure out whether= or how to regulate anything involved.
>
> In other, older, "technologies", rules, procedures, and trad= itions have developed over the years to provide for feedback and control be= tween governees and governors.=C2=A0 Roberts Rules of Order was created 150= years ago, and is still widely used to manage public meetings.=C2=A0 I'= ;ve been in local meetings where everyone gets a chance to speak, but are l= imited to a few minutes to say whatever's on their mind.=C2=A0 You have= to appear in person, wait your turn, and make your comment.=C2=A0 Doing so= is free, but still has the cost of time and hassle to get to the meeting.<= br> >
> Organizations have figured out over the years how to manage meetings.= =C2=A0 [Vint - remember the "Rathole!" mechanism that we used to = keep Internet meetings on track...?]

PARC had "Dealer".

> From what David describes, it sounds like the current "public com= ment" mechanisms in the electronic arena are only at the stage where t= he loudest voices can drown out all others, and public debates are essentia= lly useless cacophonies of the loudest proponents of the various viewpoints= .=C2=A0 =C2=A0There are no rules.=C2=A0 =C2=A0Why should anyone submit thei= r own sensible comments, knowing they'll be lost in the noise?
>
> In non-electronic public forums, such behavior is ruled out, and if it= persists, the governing body can have offenders ejected, adjourn a meeting= until cooler heads prevail, or otherwise make the discourse useful for inf= orming decisions.=C2=A0 =C2=A0Courts can issue restraining orders, but has = any court ever issued such an order applying to an electronic forum?
>
> So, why haven't organizations yet developed rules and mechanisms f= or managing electronic discussions....?
>
> I'd offer two observations and suggestions.
>
> -----
>
> First, a major reason for a lack of such rules and mechanisms may be a= n educational gap.=C2=A0 Administrators, politicians, and staffers may simp= ly not understand all this newfangled technology, or how it works, and are = drowning in a sea of terminology, acronyms, and concepts that make no sense= (to them).=C2=A0 =C2=A0In the FCC case, even the technical gurus may have = deep knowledge of their traditional realm of telephony, radio, and related = issues and policy tradeoffs.=C2=A0 =C2=A0But they may be largely ignorant o= f computing and networking equivalents.=C2=A0 =C2=A0Probably even worse, th= ey may unconsciously consider the new world as a simple evolution of the ol= d, not recognizing the impact of incredibly fast computers and communicatio= ns, and the advances that they enable, such as "AI" - whatever th= at is...
>
> About 10 years ago, I accidentally got involved in a patent dispute to= be an "expert witness", for a patent involving downloading new p= rograms over a communications path into a remote computer (yes, what all ou= r devices do almost every day).=C2=A0 =C2=A0I was astounded when I learned = how little the "judicial system" (lawyers, judges, legislators, e= tc.) knew about computer and network technology.=C2=A0 =C2=A0That didn'= t stop them from debating the meaning of technical terms.=C2=A0 What is RAM= ?=C2=A0 How does "programming" differ from "reprogramming&qu= ot;?=C2=A0 What is "memory"?=C2=A0 What is a "processor"= ;?=C2=A0 =C2=A0What is an "operating system"?=C2=A0 =C2=A0The arg= uments continue until eventually a judge declares what the answer is, with = little technical knowledge or expertise to help.=C2=A0 =C2=A0So you can eas= ily get legally binding definitions such as "operating system" me= ans "Windows", and that all computers contain an operating system= .
>
> I spent hours on the phone over about 18 months, explaining to the law= yers how computers and networks actually worked.=C2=A0 =C2=A0In turn, they = taught me quite a lot about the vagaries of the laws and patents.=C2=A0 It = was fascinating but also disturbing to see how ill-prepared the legal syste= m was for new technologies.
>
> So, my suggestion is that a focus be placed on helping the non-technic= al decision makers understand the nuances of computing and the Internet.=C2= =A0 I don't think that will be successful by burying them in the sea of= technical jargon and acronyms.
>
> Before I retired, I spent a lot of time with C-suite denizens from com= panies outside of the technology industry - banks, manufacturers, transport= ation, etc. - helping them understand what "The Internet" was, an= d help them see it as both a huge opportunity and a huge threat to their bu= sinesses.=C2=A0 One technique I used was simply stolen from the early days = of The Internet.
>
> When we were involved in designing the internal mechanisms of the Inte= rnet, in particular TCPV4, we didn't know much about networks either.= =C2=A0 So we used analogies.=C2=A0 In particular we used the existing trans= portation infrastructure as a model.=C2=A0 =C2=A0Moving bits around the wor= ld isn't all that different from moving goods and people.=C2=A0 =C2=A0B= ut everyone, even with no technical expertise, knows about transportation.<= br> >
> It turns out that there are a lot of useful analogies.=C2=A0 For examp= le, we recognized that there were different kinds of "traffic" wi= th different needs.=C2=A0 Coal for power plants was important, but not urge= nt.=C2=A0 If a coal train waits on a siding while a passenger train passes,= it's OK, even preferred.=C2=A0 =C2=A0There could be different "ty= pes of service" available from the transportation infrastructure.=C2= =A0 =C2=A0At the time (late 1970s) we didn't know exactly how to do tha= t, but decided to put a field in the IP header as a placeholder - the "= ;TOS" field.=C2=A0 Figuring out what different TOSes there should be, = and how they would be handled differently, was still on the to-do list.=C2= =A0 =C2=A0There are even analogies to the Internet - goods might travel ove= r a "marine network" to a "port", where they are moved = onto a "rail network", to a distributor, and moved on the highway= network to their final destination.=C2=A0 Routers, gateways, ...
>
> Other transportation analogies reinforced the notion of TOS.=C2=A0 E.g= ., if you're sending a document somewhere, you can choose how to send i= t - normal postal mail, or Priority Mail, or even use a different "net= work" such as an overnight delivery service.=C2=A0 Different TOS would= engage different behaviors of the underlying communications system, and mi= ght also have different costs to use them.=C2=A0 Sending a ton of coal to g= et delivered in a week or two would cost a lot less than sending a ton of d= ocuments for overnight delivery.
>
> There were other transportation analogies heard during the TCPV4 desig= n discussions - e.g., "Expressway Routing" (do you take a direct = route over local streets, or go to the freeway even though it's longer)= and "Multi-Homing" (your manufacturing plant has access to both = a highway and a rail line).
>
> Suggestion -- I suspect that using a familiar infrastructure such as t= ransport to discuss issues with non-technical decision makers would be help= ful.=C2=A0 E.g., imagine what would happen if some particular "net neu= trality" set of rules was placed on the transportation infrastructure?= =C2=A0 =C2=A0Would it have a desirable effect?
>
> -----
>
> Second, in addition to anonymity as an important issue in the electron= ic world, my experience as a mentee of Licklider surfaced another important= issue in the "galactic network" vision -- "Back Pressure&qu= ot;.=C2=A0 =C2=A0 =C2=A0The notion is based in existing knowledge.=C2=A0 = =C2=A0Economics has notions of Supply and Demand and Cost Curves.=C2=A0 =C2= =A0Engineering has the notion of "Negative Feedback" to stabilize= mechanical, electrical, or other systems.
>
> We discussed Back Pressure, in the mid 70s, in the context of electron= ic mail, and tried to get the notion of "stamps" accepted as part= of the email mechanisms.=C2=A0 The basic idea was that there had to be som= e form of "back pressure" to prevent overload by discouraging sen= ding of huge quantities of mail.
>
> At the time, mail traffic was light, since every message was typed by = hand by some user.=C2=A0 In Lick's group we had experimented with using= email as a way for computer programs to interact.=C2=A0 In Lick's visi= on, humans would interact by using their computers as their agents.=C2=A0 = =C2=A0Even then, computers could send email a lot faster and continuously t= han any human at a keyboard, and could easily flood the network.=C2=A0 [Thi= s epiphany occurred shortly after a mistake in configuring distribution lis= ts caused so many messages and replies that our machine crashed as its disk= space ran out.]
>
> "Stamps" didn't necessarily represent monetary cost.=C2= =A0 Back pressure could be simple constraints, e.g., no user can send more = than 500 (or whatever) messages per day.=C2=A0 =C2=A0This notion never got = enough support to become part of the email standards; I still think it woul= d help with the deluge of spam we all experience today.
>
> Back Pressure in the Internet today is largely non-existent.=C2=A0 I (= or my AI and computers) can send as much email as I like.=C2=A0 =C2=A0Commu= nications carriers promote "unlimited data" but won't guarant= ee anything.=C2=A0 =C2=A0Memory has become cheap, and as a result behaviors= such as "buffer bloat" have appeared.
>
> Suggestion - educate the decision-makers about Back Pressure, using hi= ghway analogies (metering lights, etc.)
>
> -----
>
> Education about the new technology, but by using some familiar analogs= , and introduction of Back Pressure, in some appropriate form, as part of a= "network neutrality" policy, would be the two foci I'd recom= mend.
>
> My prior suggestion of "registration" and accepting only the= last comment was based on the observations above.=C2=A0 Back pressure does= n't have to be monetary, and registered users don't have to be pers= onally identified.=C2=A0 =C2=A0Simply making it sufficiently "hard&quo= t; to register (using CAPTCHAs, 2FA, whatever) would be a "cost" = discouraging "loud voices".=C2=A0 =C2=A0Even the law firms submit= ting millions of comments on behalf of their clients might balk at the cost= (in labor not money) to register their million clients, even anonymously, = so each could get his/her comment submitted.=C2=A0 =C2=A0Of course, they co= uld always pass the costs on to their (million? really?) clients.=C2=A0 But= it would still be Back Pressure.
>
> One possibility -- make the "cost" of submitting a million e= lectronic comments equal to the cost of submitting a million postcards...?<= br> >
> Jack Haverty
>
>
> On 10/9/23 16:55, David Bray, PhD wrote:
>
> Great points Vint as you're absolutely right - there are multiple = modalities here (and in the past it was spam from thousands of postcards, t= hen mimeographs, then faxes, etc.)
>
> The standard historically has been set by the Administrative Conferenc= e of the United States: https://www.acus.gov/about-acus
>
> In 2020 there seemed to be an effort to gave the General Services Admi= nistration weigh-in, however they closed that rulemaking attempt without pu= blishing any of the comments they got and no announcement why it was closed= .
>
> As for what part of Congress - I believe ACUS was championed by both t= he Senate and House Judiciary Committees as it has oversight and responsibi= lity for the interpretations of the Administrative Procedure Act of 1946 (w= hich sets out the whole rulemaking procedure).
>
> Sadly there isn't a standard across agencies - which also means th= ere isn't a standard across Administrations. Back in 2018 and 2020, bot= h with this group of 52 people here https://tinyurl.com/l= etter-signed-52-people - as well as individually - I did my darnest to = encourage them to do a standard.
>
> There's also the National Academy of Public Administration which i= s probably the latest remaining non-partisan forum for discussions like thi= s too.
>
>
> On Mon, Oct 9, 2023 at 7:46=E2=80=AFPM Vint Cerf <vint@google.com> wrote:
>>
>> David, this is a good list.
>> FACA has rules for public participation, for example.
>>
>> I think it should be taken into account for any public commenting = process that online (and offline such as USPS or fax and phone calls) that = spam and artificial inflation of comments are possible. Is there any specif= ic standard for US agency public comment handling? If now, what committees = of the US Congress might have jurisdiction?
>>
>> v
>>
>>
>> On Tue, Oct 10, 2023 at 8:22=E2=80=AFAM David Bray, PhD via Nnagai= n <nn= again@lists.bufferbloat.net> wrote:
>>>
>>> I'm all for doing new things to make things better.
>>>
>>> At the same time, I used to do bioterrorism preparedness and r= esponse from 2000-2005 (and aside from asking myself what kind of crazy wor= ld needed counter-bioterrorism efforts... I also realized you don't wan= t to interject something completely new in the middle of an unfolding crisi= s event). If something were to be injected now, it would have to have conse= nsus from both sides, otherwise at least one side (potentially detractors f= rom both) will claim that whatever form the new approaches take are somehow= advantaging "the other side" and disadvantaging them.
>>>
>>> Probably would take a ruling by the Administrative Conference = of the United States, at a minimum to answer these five questions - and eve= n then, introducing something completely different in the midst of a politi= cal melee might just invite mudslinging unless moderate voices on both side= s can reach some consensus.
>>>
>>> 1. Does identity matter regarding who files a comment or not = =E2=80=94 and must one be a U.S. person in order to file?
>>>
>>> 2. Should agencies publish real-time counts of the number of c= omments received =E2=80=94 or is it better to wait until the end of a comme= nting round to make all comments available, including counts?
>>>
>>> 3. Should third-party groups be able to file on behalf of some= one else or not =E2=80=94 and do agencies have the right to remove spam-lik= e comments?
>>>
>>> 4. Should the public commenting process permit multiple commen= ts per individual for a proceeding =E2=80=94 and if so, how many comments f= rom a single individual are too many? 100? 1000? More?
>>>
>>> 5. Finally, should the U.S. government itself consider, given = public perceptions about potential conflicts of interest for any agency per= forming a public commenting process, whether it would be better to have thi= rd-party groups take responsibility for assembling comments and then filing= those comments via a validated process with the government?
>>>
>>>
>>>
>>> On Sat, Oct 7, 2023 at 4:10=E2=80=AFPM Jack Haverty <jack@3kitty.org> wrot= e:
>>>>
>>>> Hi again David et al,
>>>>
>>>> Interesting frenzy...lots of questions that need answers a= nd associated policies.=C2=A0 =C2=A0I served 6 years as an elected official= (in a small special district in California), so I have some small understa= nding of the government side of things and the constraints involved.=C2=A0 = =C2=A0Being in charge doesn't mean you can do what you want.
>>>>
>>>> I'm thinking here more near-term and incremental steps= .=C2=A0 You said "These same questions need pragmatic pilots that invo= lve the public ..."
>>>>
>>>> So, how about using the current NN situation for a pilot?= =C2=A0 Keep all the current ways and emerging AI techniques to continue to = flood the system with comments.=C2=A0 =C2=A0But also offer an *optional* wa= y for humans to "register" as a commenter and then submit their (= latest only) comment into the melee.=C2=A0 Will people use it?=C2=A0 Will &= quot;consumers" (the lawyers, commissioners, etc.) find it useful?
>>>>
>>>> I've found it curious, for decades now, that there are= (too many) mechanisms for "secure email", that may help with the= flood of disinformation from anonymous senders, but very very few people u= se them.=C2=A0 =C2=A0Maybe they don't know how; maybe the available sch= emes are too flawed; maybe ...?
>>>>
>>>> About 30 years ago, I was a speaker in a public meeting or= chestrated by USPS, and recommended that they take a lead role, e.g., by ac= ting as a national CA - certificate authority.=C2=A0 Never happened though.= =C2=A0 =C2=A0FCC issues lots of licenses...perhaps they could issue online = credentials too?
>>>>
>>>> Perhaps a "pilot" where you will also accept com= ments by email, some possibly sent by "verified" humans if they u= nderstand how to do so, would be worth trying?=C2=A0 =C2=A0Perhaps comments= on "technical aspects" coming from people who demonstrably know = how to use technology would be valuable to the policy makers?
>>>>
>>>> The Internet, and technology such as TCP, began as an expe= rimental pilot about 50 years ago.=C2=A0 Sometimes pilots become infrastruc= tures.
>>>>
>>>> FYI, I'm signing this message.=C2=A0 Using OpenPGP.=C2= =A0 I could encrypt it also, but my email program can't find your publi= c key.
>>>>
>>>> Jack Haverty
>>>>
>>>>
>>>> On 10/5/23 14:21, David Bray, PhD wrote:
>>>>
>>>> Indeed Jack - a few things to balance - the Administrative= Procedure Act of 1946 (on which the idea of rulemaking is based) us about = raising legal concerns that must be answered by the agency at the time the = rulemaking is done. It's not a vote nor is it the case that if the agen= cy gets tons of comments in one direction that they have to go in that dire= ction. Instead it's only about making sure legal concerns are considere= d and responded to before the agency before the agency acts. (Which is part= ly why sending "I'm for XYZ" or "I'm against ABC&quo= t; really doesn't mean anything to an agency - not only is that not a l= egal argument or concern, it's also not something where they're obl= igated to follow these comments - it's not a vote or poll).
>>>>
>>>> That said, political folks have spun things to the public = as if it is a poll/vote/chance to act. The raise a valid legal concern part= of the APA of 1946 is omitted. Moreover the fact that third party law firm= s and others like to submit comments on behalf of clients - there will alwa= ys be a third party submitting multiple comments for their clients (or &quo= t;clients") because that's their business.
>>>>
>>>> In the lead up to 2017, the Consumer and Government Affair= s Bureau of the FCC got an inquiry from a firm asking how they could submit= 1 million comments a day on an "upcoming privacy proceeding" (th= eir words, astute observers will note there was no privacy proceeding befor= e the FCC in 2017). When the Bureau asked me, I told them either mail us a = CD to upload it or submit one comment with 1 million signatures. To attempt= to flood us with 1 million comments a day (aside from the fact who can &qu= ot;predict" having that many daily) would deny resources to others. In= the mess that followed, what was released to the public was so redacted yo= u couldn't see the legitimate concerns and better paths that were offer= ed to this entity.
>>>>
>>>> And the FCC isn't alone. EPA, FTC, and other regulator= y agencies have had these hijinks for years - and before the Internet it wa= s faxes, mass mimeographs (remember blue ink?), and postcards.The Administr= ative Conference of the United States (ACUS) - is the body that is supposed= to provide consistent guidance for things like this across the U.S. govern= ment. I've briefed them and tried to raise awareness of these issues - = as I think fundamentally this is a **process** question that once answered,= tech can support. However they're not technologies and updating the in= terpretation of the process isn't something lawyers are apt to do until= the evidence that things are in trouble is overwhelming.
>>>>
>>>> 52 folks wrote a letter to them - and to GSA - back in 202= 0. GSA had a rulemaking of its own on how to improve things, yet oddly neve= r published any of the comments it received (including ours) and closed the= rulemaking quietly. Here's the letter: https://tinyu= rl.com/letter-signed-52-people
>>>>
>>>> And here's an article published in OODAloop about this= - and why Generative AI is probably going to make things even more challen= ging: https://www.oodaloop.com/archive/2023/04/18/why-a-pau= se-on-ai-development-is-not-the-answer-an-insiders-perspective/
>>>>
>>>> [snippet of the article] Now in 2023 and Beyond: Proactive= Approaches to AI and Society
>>>>
>>>> Looking to the future, to effectively address the challeng= es arising from AI, we must foster a proactive, results-oriented, and coope= rative approach with the public. Think tanks and universities can engage th= e public in conversations about how to work, live, govern, and co-exist wit= h modern technologies that impact society. By involving diverse voices in t= he decision-making process, we can better address and resolve the complex c= hallenges AI presents on local and national levels.
>>>>
>>>> In addition, we must encourage industry and political lead= ers to participate in finding non-partisan, multi-sector solutions if civil= societies are to remain stable. By working together, we can bridge the gap= between technological advancements and their societal implications.
>>>>
>>>> Finally, launching AI pilots across various sectors, such = as work, education, health, law, and civil society, is essential. We must l= earn by doing on how we can create responsible civil environments where AIs= can be developed and deployed responsibly. These initiatives can help us b= etter understand and integrate AI into our lives, ensuring its potential is= harnessed for the greater good while mitigating risks.
>>>>
>>>> In 2019 and 2020, a group of fifty-two people asked the Ad= ministrative Conference of the United States (which helps guide rulemaking = procedures for federal agencies), General Accounting Office, and the Genera= l Services Administration to call attention to the need to address the chal= lenges of chatbots flooding public commenting procedures and potentially cr= owding out or denying services to actual humans wanting to leave a comment.= We asked:
>>>>
>>>> 1. Does identity matter regarding who files a comment or n= ot =E2=80=94 and must one be a U.S. person in order to file?
>>>>
>>>> 2. Should agencies publish real-time counts of the number = of comments received =E2=80=94 or is it better to wait until the end of a c= ommenting round to make all comments available, including counts?
>>>>
>>>> 3. Should third-party groups be able to file on behalf of = someone else or not =E2=80=94 and do agencies have the right to remove spam= -like comments?
>>>>
>>>> 4. Should the public commenting process permit multiple co= mments per individual for a proceeding =E2=80=94 and if so, how many commen= ts from a single individual are too many? 100? 1000? More?
>>>>
>>>> 5. Finally, should the U.S. government itself consider, gi= ven public perceptions about potential conflicts of interest for any agency= performing a public commenting process, whether it would be better to have= third-party groups take responsibility for assembling comments and then fi= ling those comments via a validated process with the government?
>>>>
>>>> These same questions need pragmatic pilots that involve th= e public to co-explore and co-develop how we operate effectively amid these= technological shifts. As the capabilities of LLMs continue to grow, we nee= d positive change agents willing to tackle the messy issues at the intersec= tion of technology and society. The challenges are immense, but so too are = the opportunities for positive change. Let=E2=80=99s seize this moment to c= reate a better tomorrow for all. Working together, we can co-create a futur= e that embraces AI=E2=80=99s potential while mitigating its risks, informed= by the hard lessons we have already learned.
>>>>
>>>> Full article: https://www.oodaloop.com/arc= hive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders= -perspective/
>>>>
>>>> Hope this helps.
>>>>
>>>>
>>>> On Thu, Oct 5, 2023 at 4:44=E2=80=AFPM Jack Haverty via Nn= again <nnagain@lists.bufferbloat.net> wrote:
>>>>>
>>>>> Thanks for all your efforts to keep the "feedback= loop" to the rulemakers functioning!
>>>>>
>>>>> I'd like to offer a suggestion for a hopefully pol= itically acceptable way to handle the deluge, derived from my own battles w= ith "email" over the years (decades).
>>>>>
>>>>> Back in the 1970s, I implemented one of the first emai= l systems on the Arpanet, under the mentorship of JCR Licklider, who had be= en pursuing his vision of a "Galactic Network" at ARPA and MIT.= =C2=A0 =C2=A0One of the things we discovered was the significance of anonym= ity.=C2=A0 =C2=A0At the time, anonymity was forbidden on the Arpanet; you n= eeded an account on some computer, protected by passwords, in order to legi= timately use the network.=C2=A0 =C2=A0The 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.=C2=A0 =C2=A0But many uses= of the network, and needs of its users, demand accountability, so all sort= s of mechanisms have been pasted on top of the network to provide ways to j= udge user identity.=C2=A0 Banks, medical services, governments, and busines= ses all demand some way of proving your identity, with passwords, various s= chemes of 2FA, VPNs, or other such technology, with varying degrees of prot= ection.=C2=A0 =C2=A0It is still possible to be anonymous on the net, but ma= ny things you do require you to prove, to some extent, who you are.
>>>>>
>>>>> So, my suggestion for handling the deluge of "com= ments" is:
>>>>>
>>>>> 1/ create some mechanism for "registering" y= our intent to submit a comment.=C2=A0 =C2=A0Make it hard for bots to regist= er.=C2=A0 Perhaps you can leverage the work of various partners, e.g., ISPs= , retailers, government agencies, financial institutions, of others who alr= eady 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 wa= y to "edit" your previous comment - i.e., advise that your commen= t is always the last one you submitted.=C2=A0 =C2=A0I.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 re= ad the comments.=C2=A0 =C2=A0Even better, provide those "information c= onsumers" with ways to sort, filter, and search through the body of co= mments.
>>>>>
>>>>> 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 ki= nd intro...
>>>>>
>>>>> First, I'll open with I'm a gosh-darn non-part= isan, which means I swore an oath to uphold the Constitution first and serv= e 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-par= tisans 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 remain= s that a few actors attempted to flood the system with less-than-authentic = comments.
>>>>>
>>>>> In some respects this is not new. The whole "noti= ce and comment" process is a legacy process that goes back decades. An= d the FCC (and others) have had postcard floods of comments, mimeographed l= etters of comments, faxed floods of comments, and now this - which, when co= mbined 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 bot= h filing and pulling info from the Electronic Comment Filing System.
>>>>>
>>>>> Both times I was told *no* out of concerns that they m= ight prevent someone from filing. I asked if I could block obvious spam, de= fined 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, 5a= m, and 6am ET at night which normally shouldn=E2=80=99t see such volumes. W= hen I said there was a combination of actual humans wanting to leave commen= ts and others who were effectively denying service to others (especially be= cause if anyone wanted to do a batch upload of 100,000 comments or more the= y could submit a CSV file or a comment with 100,000 signatories) - both par= ties said no, that couldn=E2=80=99t be happening.
>>>>>
>>>>> Until 2021 when the NY Attorney General proved that wa= s exactly what was happening with 18m of the 23m apparently from non-authen= tic 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 teena= gers).
>>>>>
>>>>> So with Net Neutrality back on the agenda - here=E2=80= =99s a simple prediction, even if the volume of comments is somehow control= led, 10,000+ pages of comments produced by ChatGPT or a different LLM is bo= th possible and probably will be done. The question is if someone includes = a legitimate legal argument on page 6,517 - will FCC=E2=80=99s lawyers spot= it and respond to it as part of the NPRM?
>>>>>
>>>>> Hope this helps and with highest regards,
>>>>>
>>>>> -d.
>>>>> --
>>>>>
>>>>> Principal, LeadDoAdapt Ventures, Inc. & Distinguis= hed Fellow
>>>>>
>>>>> Henry S. Stimson Center, Business Executives for Natio= nal Security
>>>>>
>>>>>
>>>>>
>>>>> On Mon, Oct 2, 2023 at 2:15=E2=80=AFPM Dave Taht via N= nagain <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 t= echnical issues
>>>>>> surrounding the internet, to participate on this l= ist. I encourage you
>>>>>> all to reach out on your own, especially to those = that you can
>>>>>> constructively and civilly disagree with, and hope= fully work with, to
>>>>>> establish technical steps forward. Quite a few hav= e 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!) storie= s of that era, and I
>>>>>> do kind of hope now, that some of that history sur= faces, 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 tackl= e here, going
>>>>>> forward.
>>>>>>
>>>>>> [1] https://www.stimson.org/ppl/davi= d-bray/
>>>>>> [2] "Pain shared is reduced. Joy shared, incr= eased." - Spider Robinson
>>>>>>
>>>>>>
>>>>>> --
>>>>>> Oct 30: https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html >>>>>> Dave T=C3=A4ht CSO, LibreQos
>>>>>> _______________________________________________ >>>>>> Nnagain mailing list
>>>>>> Nnagain@lists.bufferbloat.net
>>>>>> https://lists.bufferbloat.net= /listinfo/nnagain
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> Nnagain mailing list
>>>>> Nnagain@lists.bufferbloat.net
>>>>> https://lists.bufferbloat.net/lis= tinfo/nnagain
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> Nnagain mailing list
>>>>> Nnagain@lists.bufferbloat.net
>>>>> https://lists.bufferbloat.net/lis= tinfo/nnagain
>>>>
>>>>
>>> _______________________________________________
>>> Nnagain mailing list
>>> Nnagain@lists.bufferbloat.net
>>> https://lists.bufferbloat.net/listinfo/nn= again
>>
>>
>>
>> --
>> Please send any postal/overnight deliveries to:
>> Vint Cerf
>> Google, LLC
>> 1900 Reston Metro Plaza, 16th Floor
>> Reston, VA 20190
>> +1 (571) 213 1346
>>
>>
>> until further notice
>>
>>
>>
>
> _______________________________________________
> Nnagain mailing list
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> https://lists.bufferbloat.net/listinfo/nnagain



--
Oct 30: https://netdevconf.info/= 0x17/news/the-maestro-and-the-music-bof.html
Dave T=C3=A4ht CSO, LibreQos
_______________________________________________
Nnagain mailing list
Nnagain@= lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain
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