Comments submitted to FCC Hearing at Harvard Law School

Glance submitted the following comments to the FCC for the hearing yesterday (25 Feb 2008) in Cambridge at Harvard Law School debating Net Neutrality.  A representative from Glance, who attended the hearing, reported that there ensued quite an interesting discussion of basic rights, policy, competitiveness, innovation and some deep technical issues.  More on that below...

Comments on FCC Hearing in Cambridge, Massachusetts on Broadband Network Management Practices
February 25, 2008

Docket Numbers:  07-52 and 08-7

Glance Networks is a small Internet business with headquarters in Arlington, MA and customers all over the country and the world.

The issue of "traffic shaping" or "traffic throttling" is not just about bitTorrent, and it's not just about limiting file sharing.

Glance Networks provides a legitimate web conferencing service to thousands of mostly small and medium sized businesses.  They use our service to demo their products, do sales presentations and train over the Internet. 

Traffic throttling systems do not typically distinguish between file sharing and businesses streaming media content such as ours.

This is not just a theoretical or a potential issue.  Our business is being effected right now in Canada.  Our customers in Canada on Shaw Cable and Rogers Cable have been seeing this kind of traffic throttling for several years now.  It's gotten to the point that when someone calls up saying their session is incredibly slow, the first question we ask is: "Are you in Canada"?  "Are you on Shaw or Rogers Cable"?

Our business and our customers' business depends on high quality broadband Internet.  The Internet is an open infrastructure that has allowed the creation of hundreds of thousands of small businesses and new innovative services that could never have existed before.  And none of these businesses or ideas can grow into large ones either.  Without this infrastructure, Amazon.com would not exist today, eBay would not exist, Google would not exist.

It's as if all the good, wide paved roads went only to Wal-Mart and to McDonald's.  As if new and small businesses were only served by narrow dirt roads.  It's allowing a competitive disadvantage in a near-monopoly infrastructure that should support the entire economy of today and the future.

Please do not allow new small businesses to be throttled to benefit established large businesses, do not allow new and innovative services to be throttled to benefit established types of services.

Various solutions were debated at the hearing, from regulation to increasing competition.  But we'd come to pretty much the the same conclusion that Dave Clark of MIT shared at the hearing.

What's the solution?  I'm not fond of it, but I think I know what it will have to look like.

First -- what's the problem? And there is a problem, largely of the cable companies own making.

For years they've sold the promise of broadband.  "Blazing fast Internet"!  "A thousand times faster than dial-up"!.  What they don't make obvious is that they're pitching fast download speed, not upload, which often is only a tenth as fast.  This doesn't matter much if you're a passive consumer of media, but not if you create or send media. 

But the real dirty secret, in the fine print or buried in the terms and conditons, is that none of that speed is guaranteed.  That's in perfect conditions, five A.M. on an wide empty highway with a fresh cup of coffee and the radio cranked loud.  Not when there's a lot of traffic on the road.

And the reason is, they can't actually deliver that speed to everyone.  Their network isn't built to support it. 

This isn't how we, as a company, buy bandwidth.  Glance Networks, like other web service companies and large websites, puts our servers in a big co-location facility.  One is down the road in Somerville, and there's a clone of it (a hot backup) out in LA.  We're connected to the the Internet by huge pipes, with unimaginable speed.  But we only pay for what we use.  We buy a particular tier of bandwidth for a fixed rate, and there's an overage charge if we go over that.  As our traffic grows, we eventually bump up to the next tier.

Does this sound familiar?  It's a lot like cell phone pricing.  Remember years ago when you got your very first cell phone?  Maybe you got the 60 minutes per month plan, then you got the bill and saw all those extra overage minutes at 25 cents each.

Well these days everyone has a 300 minute plan, or a 1000 minute plan, at fairly reasonable flat-rate prices.  And we even have unlimited nights and weekends!

It's easier now to predict your cost, and to compare rates among different providers.

I'll miss the old unlimited Internet as much as anyone, and I suspect we'll lose something along the way.  But as technology and needs and competition evolve, pricing will come down, the tiers will get bigger, and it will all work out.

The solution is not to prefer one set of customers over another, or one type of traffic over another.  The solution is to just pay for what you use.