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

[Christopher Wilkinson]

Dear Christian, Dear Frédéric:

I very much agree with Christian's analysis and recommendation. I  
attach my initial letter on this topic, from January 2009.

Regards

CW


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On 01 Nov 2011, at 16:40, Christian de Larrinaga wrote:

> 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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>
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