[opendtv] Re: F.C.C. Is Deluged With Comments on Net Neutrality Rules

  • From: Craig Birkmaier <craig@xxxxxxxxxxxxx>
  • To: "opendtv@xxxxxxxxxxxxx" <opendtv@xxxxxxxxxxxxx>
  • Date: Sat, 19 Jul 2014 07:44:26 -0400

> On Jul 18, 2014, at 9:57 PM, "Manfredi, Albert E" 
> <albert.e.manfredi@xxxxxxxxxx> wrote:
> 
> I can understand the technical problem Comcast has to deal with, then and 
> now. Just ignoring the obvious cost issues the ISPs have does not make for a 
> convincing argument. Someone has to pay the ISP one way or another.
> 
> ...
> 
> Therefore, given that now most ISPs are also MVPDs, and are therefore local 
> monopolies in most cases, how else to solve the conflict of interest problem? 
> It's not like people can look at another provider, most of the time (unless 
> and until credible wireless options emerge). Let Netflix take on the 
> responsibility to distribute servers at their expense, let the ISP deal with 
> subscribers for different levels of service, and let the streaming protocols 
> self-regulate the quality they can deliver, in the presence of other traffic.

You are missing the forrest for the trees here Bert.

You correctly identify the real problem as the need for ISPs to make major 
investments in the last mile. Then you suggest that server co-location is a 
solution. 

The reality is that it does not matter if the bits reside within the ISP "head 
end" if the bottleneck is the last mile. Choking a service at an 
interconnection handoff is just a way to prevent the problem in the real 
bottleneck - the last mile. It is also a convenient way to run the blackmail 
schemes we have seen in recent years.

The existence of heavy bandwidth services like Netflix is simply the stimulus 
for the next level of upgrades to the last mile - I.e. It creates consumer 
demand for better QOS, AS WELL as demand for higher bit rates. The same can be 
said for VOD services run by the ISP, as is happening with Comcast.

For the most part the marketplace has been working. We now enjoy much higher 
bit rates and QOS than existed a decade ago. I have very few problems with 
"buffering" with my Cox ISP service. 

Regulating ISP service under Title II may just entrench the ISP oligopoly and 
let them maintain high profits while slowing the investment in the last mile.

Fortunately, this bottleneck will disappear in due time. Some industry players 
want to keep the pressure on by making the problem bigger - e.g. moving to 4K 
UHDTV.  This is not a realistic future. When the last mile can reliably deliver 
7-10 Mbps streams to every home the consumer will be satisfied. We could 
deliver 24 channel audio sampled at 1MHz via the Internet today. The reality is 
that we passed "good enough" for audio a log time ago. We are approaching "good 
enough" for video - the problem is now isolated to the last mile.

Regards
Craig




> 
>> I also think that the stance Wheeler has taken and proposed FCC
>> regulations supports Comcast's tactic, that they can adjust speed
>> for different traffic from where they originate from and
>> negotiate payments for higher speeds.  Perhaps I do not understand
>> the intricacies of FCC's possible regulation.
>> 
>> But at present, it sounds to me like you are against the possible
>> FCC regs and these deals the ISPs are making in the middle.
> 
> The FCC does not need to help foster runaway greed. Having content sources 
> pay extra to the ISP is rife with risk. Where will it end? It's perhaps the 
> usual case of greed having no limits.
> 
> Bert
> 
> 
> 
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