[Chapter-delegates] Update to the Internet Impact Assessment Toolkit

[Richard Hill]

Thank you for this. I apologize for the tardy comments, but I was tied up with other things. 

I refer to the full paper, at:

 

  https://www.internetsociety.org/wp-content/uploads/2021/11/Enablers-of-OGST-EN.pdf 

 

Full disclosure: I was asked to comment on an earlier draft of this paper, and I see that many, but not all, of my comments were accommodated. So I reproduce here some of those comments.

 

In my view the descriptions and examples don't facilitate understanding how to deal with some known key issues:

 

A) Regarding technical security, there should be mandatory standards, as for electrical appliances, cars, airplanes, pharmaceuticals, etc. I like the approach adopted for electricity: industry comes up with standards, which are then made mandatory by regulations.

 

B) Regarding trustworthiness (which includes so-called "information security"), censorship (whether by the state or by social media platforms) is not the solution. The solution is better user education, and making platforms liable, just like any other editor. The objection that this infringes freedom of speech is, in my view, not tenable: freedom of speech does not imply a right to publish. Any publisher has the right to decide what and what not to publish, and should be held responsible for its choices.

 

C) Regarding surveillance capitalism (which is the antithesis of privacy), the solution involves better anti-trust enforcement (taking into account that having large amounts of data equates to having a dominant position, and prohibiting e-commerce platforms from selling their own products), mandating data interoperability (so that people can easily change social network platforms), equitably taxing electronic transactions and their profits, and (as recently suggested) heavily taxing targeted advertising.

 

D) Regarding affordable access, there should be an international version of national universal service funds. I know that this idea has been consistently rejected, but I still think that it is the right idea, albeit tricky to implement.

 

Here are my detailed comments.

 

1) Page 4 states that the aspirational set of goals for the Internet is “a network that is open, globally connected, secure and trustworthy”. 

 

I agree, and it is unfortunate that the current Internet is not secure, and it is not trustworthy, neither in the technical sense of confidentiality, integrity, and authentication, nor in the broader sense of providing reliable information.

 

The reasons for the lack of technical security are market failures, see the 2016 ISOC State of Internet report. The reasons for the lack of reliable information are that the current business model favors the publication of unreliable information.

 

It is also not open and globally connected, unless you exclude China.

 

Further, there national regulations on things such as permissible speech and data privacy differ widely around the world, so there are serious limits on regarding "open, global connectivity".

 

2) Page 6 correctly notes that affordable access is a key enabler. It is worth recalling that, at present, access is not affordable in many developing countries, and that there are various initiatives (including in ISOC and in ITU) to favor affordable access.

 

3) Page 7: Example 3 could have been expanded to include a reference to Net Neutrality, which is probably the best-known example of a policy that is intended to facilitate affordable access. 

 

4) Page 7, example 3. Government regulations are not the only reason there is limited competition. The US is a great example of how market failures (natural monopoly effects in low-density areas) have led to a large portion of the population being subject to de facto monopolies for Internet access. That was well documented in the Wheeler Open Access order. 

 

5) Page 9, Example 1: it might have been worth noting that the Internet’s main naming space (the domain name system) is managed centrally, for very good reasons.

 

6) Page 10, Example 1: it might have been worth noting that NATs were developed and deployed because IPv6 is not backwards compatible with IPv4. Since IPv6 is actually a separate (albeit interoperable) network, one could argue that it’s deployment violated the “unrestricted reachability” enabler: it would have been better if IPv6 had been backwards compatible.

 

7) Page 10. The description of "unrestricted reachability" could be misunderstood to imply that no national restrictions on illegal content are acceptable. If read literally, the description implies that CSAM and illegal-drug online markets would be permissible.

 

It would have been better to formulate as follows "Internet users have access to all legally permitted resources and technologies available on the Internet and are able to make legally permitted resources available themselves".

 

8) Page 10, example 2. What you say is correct, but ignores a fundamental issue. VoIP can be a way of bypassing a form of taxation known as "termination rates". Of course any tax raises prices and distorts the market. But all states need to raise taxes, and, in some cases, a tax on incoming voice calls may be the best way to do it.

 

9) Page 11, example 3. The example is not sufficiently sensitive to economic realities: it may be  cheaper to deploy CGNAT than to transition to IPv6. Since cost does affect availability, and affordability, CGNAT may actually have a positive effect.

 

Indeed, if you believe that the market is competitive (which it probably is in this respect), then there is no call to criticize CGNAT.

 

Best,

Richard

 

 

From: Chapter-delegates [mailto:chapter-delegates-bounces at elists.isoc.org] On Behalf Of Carl Gahnberg via Chapter-delegates
Sent: Monday, 8 November 2021 20:51
To: chapter-delegates at elists.isoc.org
Subject: [Chapter-delegates] Update to the Internet Impact Assessment Toolkit

 

Dear colleagues, 

 

As you know, we have been hard at work expanding the Internet Impact Assessment Toolkit (IIAT) <https://www.internetsociety.org/issues/internet-way-of-networking/internet-impact-assessment-toolkit/>  this year. Last year, the IIAT introduced the Internet Way of Networking (IWN): the critical properties at the foundation of this model and the key to the Internet's successful evolution. The IWN has become a useful lens to evaluate whether policy and technology proposals impact what makes the Internet work for everyone. 

 

This year, we decided to expand the Toolkit with a new mechanism that allows us to better understand not only what the Internet needs to exist, but what it needs to thrive. The IWN's critical properties are essential to protecting the Internet's networking model, but we need more information to fully guard it against threats. We've been working to develop a new white paper: "Enablers" of an Open, Globally Connected, Secure and Trustworthy Internet. These factors enable the Internet to reach its full potential. We deeply appreciate your contributions in the PDP process of this white paper, and to help us understand what we need to support the Internet we all want. 

 

We are proud to let you know the white paper is available on the IIAT webpage today, along with a new tool for advocacy: the Internet Impact Brief. 

 

The Internet impact brief is a resource to help both policymakers and Internet advocates rapidly analyze emerging issues to determine how to mitigate harm, and whether a full Internet impact assessment is needed. The Toolkit now includes How to Conduct an Internet Impact Brief, and five briefs that show how real-life issues can impact the Internet.

 

We are continually honored to work with you as part of a global community to promote and defend the Internet. This addition will provide an important foundation for the Internet Society's future work and advocacy to protect the Internet we all want.

 

Want to help us use and promote our new tools? You can:

·      Share the Toolkit with your professional and social networks. Here's a suggestion: “Worried about threats to the open, globally connected, secure and trustworthy Internet? Take your advocacy next level with @internetsociety’s new tool: How to Conduct an Internet Impact Brief.”

·      Use the Toolkit in your advocacy: If you spot a threat to the Internet, let us know! We'd be happy to collaborate on future Internet impact briefs. 

 

Best regards,

The IWN Team 

 

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