[Chapter-delegates] [European-chapters] ISOC contribution- Net Neutrality - BEREC consultation- Deadline 28 October.

[Christian de Larrinaga]

Frederic,

Too  much on the plate to get around to this until now.  So apologies and these are personal comments.

I read this and I feared that it could be interpreted as general purpose IP networks being not fit for purpose. I value the general purpose Internet as one that is also fit for purpose for everyone model. 

So given the interconnection model as described in the paper

As I see it there are two types of network access loop scenarios to consider. 

a/ Networks with sufficient capacity to handle the traffic demands of its users so that best effort delivery meets the performance of a mix of time and non time sensitive content.

b/ Networks that do not have sufficient capacity. 

The first category do not need traffic management and so should be always neutral in terms of the traffic being carried. In periods of peak loads they remain below a safe threshold on capacity and where they go over they invest in further capacity to meet a growth in demand. 

The second category that has too little capacity should first I would argue be encouraged to increase capacity to meet the demand. This may take time or be impossible due to medium limitations such as licensed wireless bandwidth restraints. In these cases alternative paths and or traffic management will be needed and this may take a variety of measures depending on the local circumstances. Here the paper provides useful clue. 

So the main point I would raise is that in terms of high level policy I would argue that the preference should be to encourage investment in more capacity (capacity building) rather than in traffic management. 



A sideline to this is that the more investment is directed at intelligent devices in the net the more difficult it gets to upgrade services end to end as dependency on middleboxes tends to end up limiting flexibility to the upgrade path of the vendors of those boxes (e.gl., from v4 to v6 or from DNS to DNSSEC or for VPLS or MPLS or OpenFlow or.... 


So promote capacity building on general purpose IP connectivity. And don't get trapped down CGN hooks due to v6 transition and DPI agenda


hope this helps


Christian
 





On 25 Oct 2011, at 17:34, Frederic Donck wrote:

> Dear Colleagues,
> 
> I would like to share with you some very recent development wrt the "Network Neutrality" dossier in Europe.
> As you certainly remember, the European Commission said it would rely on the European Body of Regulators for Electronic Communications (aka "BEREC", a body which is composed of European NRAS) to further develop the European principles at regulatory level.
> 
> You will find below the draft guidelines which the 'BEREC' has released at the beginning of this month for consultation.
> Stakeholders are invited to send their answers by the 2nd of November 2011.
> http://erg.ec.europa.eu/doc/berec/consultation_draft_guidelines.pdf
> http://erg.ec.europa.eu/doc/berec/consult_info.pdf
> 
> This is a very short deadline but we nevertheless thought it would be very important to provide BEREC with an ISOC contribution. 
> Please find below an ISOC preliminary draft response in which:
> - we applaud BEREC on the quality of these draft guidelines, which are well aligned with principles that the Internet Society has long espoused. 
> - we are especially supportive of the focus on the end-user perspective, and the observation that unrestricted offers of Internet service are paramount is very welcome.
> - we provide BEREC with common terminology in relation to Internet service, along with metrics to help understand the extent to which Internet service is actually available versus a plethora of more restricted offerings.
> 
> In view of the very short deadline, would you please share you thoughts and/or support by return, and no later than Friday 28 October COB.
> 
> thank you very much in advance
> 
> Best Regards
> Frederic
> 
> Frederic Donck
> Director European Regional Bureau
> Internet Society
> 
> www.isoc.org
> 
> 
> 
> <ISOC_Response_BEREC_NN_guidelines-mdf.docx>
> 
> 
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