[Starlink] Itʼs the Latency, FCC

[Colin_Higbie]

David,

Yes, sure, if there's a choice between Internet access at 10Mbps and no Internet at all forever, 10Mbps is clearly better than nothing. But that's unlikely to be a realistic choice. A more realistic version of that is: budgeting lets us roll out at a rate of 1,000 homes per week at 25Mbps capacity or 1,500 homes per week if we can drop to 10Mbps. In that scenario, I would say that the slower rollout at the higher bandwidth is better, even though that delays some people getting access to Internet, because of the longer-term effect of having an immediately obsolete max connection speed.

I have no objection to oversubscribing, providing it is done based an actual statistical analysis of usage and provided on a good-faith basis (i.e., a belief based on the data that the total capacity will support all users at some significant % of the expected bandwidth at something like 99% or 99.9% of the time). In my opinion, it is not reasonable to require an ISP to provide 100% of its users the full bandwidth they pay for 100% of the time if all users were to max out at the same time (something that never happens in the real world). That drives up costs with negligible benefit.

I apologize if I've not been sufficiently clear on the 25Mbps minimum. I believe I have, but perhaps I'm mistaken. I'm arguing that any ISP building new capabilities to provision new users or enhancing its existing services for existing users should establish a 25Mbps minimum top speed. It's fine if they also offer cheaper slower speeds (not every user will care about getting 25Mbps or want to pay for it). So, every user in this market should be able to get at least 25Mbps, but it's fine that not all will. The important facet to this is that the cabling and infrastructure be able to support at least 25Mbps connections for those users willing to pay for it. 

I don't have the same requirement on latency (because optimal latencies are usually good enough and implementing cake for latency under load is generally a low-cost or no-cost solution), but I would support if experts from this group did have a similar max latency target and would support that this max be measured under load.

Apologies for adding yet another metaphor, but I view these requirements as similar to codes on minimum of 15amp or 20amp in-wall wiring in all new and upgrade work performed by electricians. This doesn't affect existing wiring, which is grandfathered, but it ensures no new construction is already obsolete as it's being done.

Cheers,
Colin




-----Original Message-----
From: David Lang <david at lang.hm> 
Sent: Tuesday, April 30, 2024 11:51 PM
To: Colin_Higbie <CHigbie1 at Higbie.name>
Cc: David Lang <david at lang.hm>; starlink at lists.bufferbloat.net
Subject: RE: [Starlink] Itʼs the Latency, FCC

On Wed, 1 May 2024, Colin_Higbie wrote:

> David,
>
> You wrote, "I in no way advocate for the elimination of 25Mb connectivity. What I am arguing against is defining that as the minimum acceptable connectivity. i.e. pretending that anything less than that may as well not exist (ot at the very least should not be defined as 'broadband')"
>
> If you're simply talking about approaching an existing ISP with existing services and telling them, "Please implement cake and codel to reduce latency problems at load," then I'm with you. That's a clear win because you're fixing a latency problem without creating any new problems. Good.
>
> The importance of the 25Mbps minimum arises with NEW services, new construction. Specifically, where an ISP is looking to expand their geographic footprint or seeking funding to provide improvements or a new ISP is looking to enter a market, it is DESTRUCTIVE for them to roll out a new service that can't support at least 25Mbps service. This is because a new service rollout will generally not be upgraded in terms of bandwidth capacity for a period of years following the initial deployment. As stated before, it's fine if they also OFFER plans with lower top speeds because not everyone needs 25Mbps, but they must at least OFFER a minimum of a 25Mbps plan. You do more harm to Internet infrastructure and further the Internet divide if you encourage good latency for new constructions at sub-25Mbps bandwidth.
>
> If members of this group are touting themselves as experts and advising ISPs, then you must include the 25Mbps bandwidth as the floor for at least the top tier of service.

I would rather there be an ISP serving an area with 10Mb than no ISP serving the area (no matter what the latency)

for wireless Internet, it may not be possible to provide 25Mb of service to some locations, so your argument then means those people get nothing.

I'm also seeing the policy folks in DC pushing for 25Mb to be the minimum for the slowest offering.

So when I see people posting what I paraphrase as "if the service is slower than 25Mb, that service should not exist", I argue. I apologize if that's not what you are arguing, but up until this post (where you say "25Mb for the top tier of
service") that seemed to be what you were saying.

and then there's also the 'what does it mean to say 25Mb of service'. does that mean that the ISP upstream must have 25Mb for every subscriber? or can they oversubscribe to the point that if everyone were trying to use the service, they each get 1Mb? how do you define how much oversubscription is allowed? how do you justify where you draw the line (especially if you are arguing that anything under 25Mb is unusable)

David Lang