From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from mail-ed1-x529.google.com (mail-ed1-x529.google.com [IPv6:2a00:1450:4864:20::529]) (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 738523B2A4 for ; Tue, 19 Mar 2024 14:27:15 -0400 (EDT) Received: by mail-ed1-x529.google.com with SMTP id 4fb4d7f45d1cf-56845954ffeso7891650a12.2 for ; Tue, 19 Mar 2024 11:27:15 -0700 (PDT) DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=gmail.com; s=20230601; t=1710872834; x=1711477634; darn=lists.bufferbloat.net; h=to:subject:message-id:date:from:in-reply-to:references:mime-version :from:to:cc:subject:date:message-id:reply-to; bh=L6zz2zpnwbip8tDCYdAtrpvJuDU5aO7hse30YkXhAw8=; b=DgBE/QmccQZKQZ7hQoEJvqRf+gvUza3s8uT0G+PNTj2lJfD01TNiX8GHxdtPOTB2l2 ZhFYAKbuR/uH1zChzQYw6yyNso10LAjHU+mYOrdi4AYM2x9Uu1S/Mg8LuAAv8upKALk+ oaHWJkZYAI1S2No38S1b3GOCRLzsCSBNpILG1XaFp9EMuQVO6CtrYgwezzEXHhCPRfBR rN7Wrt7QERzrIvpsVp9+mBVqF25XpufiNnH345Js4qvctI2NhIgHQpV2rU3mS/vmuPOI d8rwLMSjT/kiUlcUC/2TQWCt6Y6uOqpp2Twl+nmGf2k/yTeb/wzjsKzasdJDYEN9/Pjs GCCA== X-Google-DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=1e100.net; s=20230601; t=1710872834; x=1711477634; h=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=L6zz2zpnwbip8tDCYdAtrpvJuDU5aO7hse30YkXhAw8=; b=W2eBT4a2pwprMr8G6FWNGDelKelsw1aWQTZm80dd7ccv/uffLpDfi1+c0Xd9Zq5O/j DFIP7OVrAiY78Mw+UH6NbfyX1XDie0JdUSD3X+Siy7LSmIwbRPfBazMBeh0gMkUcM8+v fo928p0ewFCx/jFzy7tCT14VCB1ED011viv/RndaWscq0U+W5FV81x01qjEXwtH49lB3 kwymuS5n9kTlur5Y5RVWu1XdV/7KBTbPCkbGx1OqYwy2lRBxLFbXfrYKbXWTKkm0kp/6 TxaFHMuWzjXaa02n+IgBFxaMLmBhGmrLYRtukyhcEEv667AYs8WAzVWXMbf0phRIAKzk Rq9w== X-Gm-Message-State: AOJu0YzrDEBiCefHZnyrgv1hkeX66W0QFGRniN+Xy5v5fEoQUdPusF1w mh7G7B2AS182tjor3uHPoBQwgWQRSgHv5HEMvElIJ5jBOGZUarpAH4CrakMTZyiLiR5ldCE1dWo 9t1nXmBOXtnppLUtKlwQFlEmpGlzsLtBhLWs= X-Google-Smtp-Source: AGHT+IFI+kMx4kMsdU6d9E9pw86JuJjeCPjsmhGFQ5LSp9VIpq7zM/8VrPgTQI32VXF/QNp1iBkYXxGznj7A52wpC9Y= X-Received: by 2002:a05:6402:4143:b0:568:c6a2:f427 with SMTP id x3-20020a056402414300b00568c6a2f427mr2718168eda.27.1710872833698; Tue, 19 Mar 2024 11:27:13 -0700 (PDT) MIME-Version: 1.0 References: In-Reply-To: From: Nathan Simington Date: Tue, 19 Mar 2024 14:27:00 -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="0000000000008233960614079fd1" Subject: Re: [NNagain] some chatter about the fcc news 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, 19 Mar 2024 18:27:15 -0000 --0000000000008233960614079fd1 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Hi everyone, It goes without saying that I would prefer not to have the following candid remarks widely disseminated :) I'm sorry =E2=80=94 I couldn't get to the right answer inside the FCC build= ing on this one. I tried to persuade our staff and my colleagues, but for almost 10 years, DC has been mentally parasitized by artificial and bogus line speed-only measurements and the assumption that line speed is the only relevant measurement of QoS. The original version of the IAJA actually required symmetrical 100/100 for program fundability. They got talked down to 100/20 largely because of Congressional testimony, particularly by former Democratic FCC commissioner, later Rural Utilities Service Administrator Jonathan Adelstein, who was running WISPA at the time. There is a strong FTTH-only constituency in DC, which has as its holy text this 8-page paper: https://docs.fcc.gov/public/attachments/DOC-343135A1.pdf. The (specious) analogy btw universal FTTH and rural electrification is very appealing to a common type: nostalgic, non-technical New Dealers wanting to "make every American a first-class digital citizen" and similar rhetoric. The adjustment of the FCC definition of "broadband" was driven partly by this holy-war belief and partly by the desire to harmonize with NTIA's definitions under BEAD. Dave is of course 100% right about the negative effects on connectivity of bogus capacity requirements. I personally expect that many people who are expensive to serve will be the last in line for BEAD and RDOF builds, meaning that these programs may have no positive effects at all on their connectivity (indeed, may hold it back.) The only potential good news that I have to offer is that my staff knows the score, and if they work in future administrations, they will be pushing back on the mistaken priorities of the present admin. Re technical depth at the agency, it's worse than you think. The OET has great staff, but they are not politically independent and no longer enjoy the hortatory power they had under Knapp or Dale Hatfield. Also, they are a relatively small part of the agency. As in many politicized organizations, they are expected to deliver to spec and otherwise shut up about policy. The one piece of good news there is that the FCC's relevance as a media regulator, which is part of why it became so politicized, is on the wane. I've joked that we're turning into the "Federal Physical Connectivity Commission," with more in common e.g. with Canada's ISED than its CRTC, but maybe that isn't a bad thing. We will need to get a deeper RF engineering bench to deal with HI issues in the enormous amounts of unlicensed centimeter-wave that have been permitted; users there are going to keep pushing upward on power levels, and it's going to fall to us to address this. We need a network engineering bench, period =E2=80=94 I was horrified to learn that no one at the Commiss= ion had any knowledge of peering and transit anymore, to say nothing of actual implementation. I'm a peering-and-transit amateur, but no one else even knew what I was talking about when I said things like "how do we incentivize building in an era of unlimited settlement-free peering?", which is a big deal considering that this was one of the fundamental questions raised by Title II classification! Traditionally, this was hard to staff because office and bureau budgets were allocated based on regulatory fee collection; that's been decoupled recently, starting with the 2018 RAY BAUM's Act, and my team has pushed this decoupling farther every year. It just makes no sense to put 1/4+ of the agency's budget into broadcast regulation while starving the satellite and RF engineering sides. I also suspect that our field enforcement is getting increasingly marginalized (in fact, Dale Hatfield warned me almost 3 years ago that that was already his impression.) I know things are tough right now, but please feel free to email me or talk on-list about FCC structural reforms. I and my team are listening and it will help us to make recommendations to any future admin. To switch gears for a second (and sorry for going off-topic,) the FCC actually did do something really good lately: https://docs.fcc.gov/public/attachments/FCC-24-26A1.pdf. There's a lot to chew on in this thing, but I think the key wins are: 1) No federal pre-emption. If someone harms you by not living up to their security label commitments, you can take them to state court under a contract or negligence theory. For the first time, you can really discipline your equipment vendors! (The FCC can also go after them on its own initiative.) 2) Disclosure of OTA patch-support periods. At time of sale, a vendor has to provide a minimum date for OTA patch support, and by getting a label, they assume a duty to patch critical vulnerabilities through that period. 3) No safe harbors. If you suffer harm through a vendor's failure to live up to their label commitments, the label will not protect them. 4) Protection of open source/third-party firmware. Installing new software or firmware on a device does not void the representations in a label. For example, installing your own queue and buffer management system on a router does not free the company from its duty to keep the radio components patched or to secure internal data traffic. I have high hopes that the next version of the label will focus on industrial techs and other non-consumer-facing applications. Also, addressing security at the consumer level should cause better practices to propagate through the entire wireless networking industry. I mention this because we couldn't have done this without Dave, Hacker News, and many discussions with the tech community. I will be posting a one page round-up to HN this week and I hope that everyone jumps on to tell us how to do the next phase better! Tech consultation works, we just need to pull our heads out of our [REDACTED] and actually do it! All best-- Nathan On Tue, Mar 19, 2024 at 11:50=E2=80=AFAM Dave Taht via Nnagain < nnagain@lists.bufferbloat.net> wrote: > from brett glass: > > > https://www.broadband.io/c/get-broadband-grant-alerts-news/it-s-on-fcc-of= ficially-increases-its-broadband-speed-requirement-to-100-20-mbps#comment_w= rapper_32464006 > > This decision is the equivalent of saying, =E2=80=9CIf you don=E2=80=99t = have a > Cadillac, you don=E2=80=99t have a car.=E2=80=9D > > It also confuses =E2=80=9Cspeed=E2=80=9D (an ill-defined term) with capac= ity, latency, > jitter, and other factors which do matter, and ridiculously overstates > the amount of bandwidth needed for common Internet activities. Unless, > of course, the service is very bad, in which case you can compensate > somewhat - not completely - by throwing more bandwidth at the problem. > > In short, it=E2=80=99s a bad decision, made by politicians who have most > likely been deceived by corporate lobbyists, rather than the sort of > rational decision that would be made if the FCC were an apolitical > expert agency. Or if the Commissioners had even consulted a > knowledgeable practicing network engineer. (Are there any engineers > left at the FCC? Or have most of them, like Julie Knapp, retired after > being frustratingly ignored?) > > For my company, a WISP, it means deploying more expensive equipment > than I need to, when folks don=E2=80=99t need the capacity. (Our quality = is so > good that most of our customers peak at 5-10 Mbps of capacity - the > data rate is still typically 200-500 Mbps - and don=E2=80=99t need to pay= for > more, though some do.) This depletes capital, needlessly increases the > cost of broadband service and discourages uptake of service (we still > see a lot of folks who rely entirely on cell phones and tethering). > Yet another example of destructive overregulation and government > bureaucracy. Government should stay out of the broadband business and > quit meddling with it. It=E2=80=99s not competent and is doing a LOT more= harm > than good. > > > -- > https://www.youtube.com/watch?v=3DN0Tmvv5jJKs Epik Mellon Podcast > Dave T=C3=A4ht CSO, LibreQos > _______________________________________________ > Nnagain mailing list > Nnagain@lists.bufferbloat.net > https://lists.bufferbloat.net/listinfo/nnagain > --=20 Nathan Simington cell: 305-793-6899 --0000000000008233960614079fd1 Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable
Hi everyone,

It goes without saying tha= t I would prefer not to have the following candid remarks widely disseminat= ed :)

I'm sorry =E2=80=94 I couldn't get t= o the right answer inside the FCC building on this one. I tried to persuade= our staff and my=C2=A0colleagues, but for almost 10 years, DC has been men= tally parasitized by artificial and bogus line speed-only measurements and = the assumption that line speed is the only relevant measurement of QoS.

The original version of the IAJA actually required sy= mmetrical 100/100 for program fundability. They got talked down to 100/20 l= argely because of Congressional testimony, particularly by former Democrati= c FCC commissioner, later Rural Utilities Service Administrator Jonathan Ad= elstein, who was running WISPA at the time. There is a strong FTTH-only con= stituency in DC, which has as its holy text this 8-page paper:=C2=A0https://docs.= fcc.gov/public/attachments/DOC-343135A1.pdf. The (specious) analogy btw= universal FTTH and rural electrification is very appealing to a common typ= e: nostalgic, non-technical New Dealers wanting to "make every America= n a first-class digital citizen" and similar rhetoric.

<= /div>
The adjustment of the FCC definition of "broadband" was= driven partly by this holy-war belief and partly by the desire to harmoniz= e with NTIA's definitions under BEAD.

Dave is = of course 100% right about the negative effects on connectivity of bogus ca= pacity requirements. I personally expect that many people who are expensive= to serve will be the last in line for BEAD and RDOF builds, meaning that t= hese programs may have no positive effects at all on their connectivity (in= deed, may hold it back.)

The only potential good n= ews that I have to offer is that my staff knows the score, and if they work= in future administrations, they will be pushing back on the mistaken prior= ities of the present admin.

Re technical depth at = the agency, it's worse than you think. The OET has great staff, but the= y are not politically independent and no longer enjoy the hortatory power t= hey had under Knapp or Dale Hatfield. Also, they are a relatively small par= t of the agency. As in many politicized organizations, they are expected to= deliver to spec and otherwise shut up about policy.

The one piece of good news there is that the FCC's relevance as a me= dia regulator, which is part of why it became so politicized, is on the wan= e. I've joked that we're turning into the "Federal Physical Co= nnectivity Commission," with more in common e.g. with Canada's ISE= D=C2=A0than its CRTC, but maybe that isn't a bad thing.

<= /div>
We will need to get a deeper RF engineering bench to deal with HI= issues in the enormous amounts of unlicensed centimeter-wave that have bee= n permitted; users there are going to keep pushing upward on power levels, = and it's going to fall to us to address this. We need a network enginee= ring bench, period =E2=80=94 I was horrified to learn that no one at the Co= mmission had any knowledge of peering and transit anymore, to say nothing o= f actual implementation. I'm a peering-and-transit amateur, but no one = else even knew what I was talking about when I said things like "how d= o we incentivize building in an era of unlimited settlement-free peering?&q= uot;, which is a big deal considering that this was one of the fundamental = questions raised by Title II classification!

Tradi= tionally, this was hard to staff because office and bureau budgets were all= ocated based on regulatory fee collection; that's been decoupled recent= ly, starting with the 2018 RAY BAUM's Act, and my team has pushed this = decoupling farther every year. It just makes no sense to put 1/4+ of the ag= ency's budget into broadcast regulation while starving the satellite an= d RF engineering sides. I also suspect that our field enforcement is gettin= g increasingly marginalized (in fact, Dale Hatfield warned me almost 3 year= s ago that that was already his impression.)

I kno= w things are tough right now, but please feel free to email me or talk on-l= ist about FCC structural reforms. I and my team are listening and it will h= elp us to make recommendations to any future admin.

To switch gears for a second (and sorry for going off-topic,) the FCC act= ually did do something really good lately:=C2=A0https://docs.fcc.gov/public/attach= ments/FCC-24-26A1.pdf. There's a lot to chew on in this thing, but = I think the key wins are:

1) No federal pre-emptio= n. If someone harms you by not living up to their security label commitment= s, you can take them to state court under a contract or negligence theory. = For the first time, you can really discipline your equipment vendors! (The = FCC can also go after them on its own initiative.)

2) Disclosure of OTA patch-support periods. At time of sale, a vendor has = to provide a minimum date for OTA patch support, and by getting a label, th= ey assume a duty to patch critical vulnerabilities through that period.

3) No safe harbors. If you suffer harm through a vend= or's failure to live up to their label commitments, the label will not = protect them.

4) Protection of open source/third-p= arty firmware. Installing new software or firmware on a device does not voi= d the representations in a label. For example, installing your own queue an= d buffer management system on a router does not free the company from its d= uty to keep the radio components patched or to secure internal data traffic= .

I have high hopes that the next version of the l= abel will focus on industrial techs and other non-consumer-facing applicati= ons. Also, addressing security at the consumer level should cause better pr= actices to propagate through the entire wireless networking industry.
=

I mention this because we couldn't have done this w= ithout Dave, Hacker News, and many discussions with the tech community. I w= ill be posting a one page round-up to HN this week and I hope that everyone= jumps on to tell us how to do the next phase better! Tech consultation wor= ks, we just need to pull our heads out of our [REDACTED] and actually do it= !

All best--
Nathan

On Tue, Mar 19,= 2024 at 11:50=E2=80=AFAM Dave Taht via Nnagain <nnagain@lists.bufferbloat.net> wrote:
<= /div>
from brett glass:

https://www.= broadband.io/c/get-broadband-grant-alerts-news/it-s-on-fcc-officially-incre= ases-its-broadband-speed-requirement-to-100-20-mbps#comment_wrapper_3246400= 6

This decision is the equivalent of saying, =E2=80=9CIf you don=E2=80=99t ha= ve a
Cadillac, you don=E2=80=99t have a car.=E2=80=9D

It also confuses =E2=80=9Cspeed=E2=80=9D (an ill-defined term) with capacit= y, latency,
jitter, and other factors which do matter, and ridiculously overstates
the amount of bandwidth needed for common Internet activities. Unless,
of course, the service is very bad, in which case you can compensate
somewhat - not completely - by throwing more bandwidth at the problem.

In short, it=E2=80=99s a bad decision, made by politicians who have most likely been deceived by corporate lobbyists, rather than the sort of
rational decision that would be made if the FCC were an apolitical
expert agency. Or if the Commissioners had even consulted a
knowledgeable practicing network engineer. (Are there any engineers
left at the FCC? Or have most of them, like Julie Knapp, retired after
being frustratingly ignored?)

For my company, a WISP, it means deploying more expensive equipment
than I need to, when folks don=E2=80=99t need the capacity. (Our quality is= so
good that most of our customers peak at 5-10 Mbps of capacity - the
data rate is still typically 200-500 Mbps - and don=E2=80=99t need to pay f= or
more, though some do.) This depletes capital, needlessly increases the
cost of broadband service and discourages uptake of service (we still
see a lot of folks who rely entirely on cell phones and tethering).
Yet another example of destructive overregulation and government
bureaucracy. Government should stay out of the broadband business and
quit meddling with it. It=E2=80=99s not competent and is doing a LOT more h= arm
than good.


--
https://www.youtube.com/watch?v=3DN0Tmvv5jJKs Epik = Mellon Podcast
Dave T=C3=A4ht CSO, LibreQos
_______________________________________________
Nnagain mailing list
Nnagain@= lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain


--
Nathan Simington
cell:=C2=A0305-793-6899
--0000000000008233960614079fd1--