First I can personally testify to the fact that FCC staff is more than
willing to meet with individuals that can help them understand problems.
Been there done that. Of course you have to be in DC if you want to meet
face to face and you must be willing to disclose the meeting in a simple
letter that is filed with the Commissions ECFS system ( on their web site)
that describes the meeting its general subject matter and reference the
appropriate issue (Docket) that the subject matter covers.
If you want to make a simple contribution as a subject matter expert the
procedure is the same. State your case and address it to the famous Ms.
Marlene H. Dortch PDF is accepted. Yes staff do read these things. BTW the
procedure is roughly the same in Canada with the CRTC and other National
Regulatory Authorities.
Phillip if you don¹t help the government staff understand things then the
there is a real risk of bad things happening. We are seeing an increasing
number of issues that do require substantial technical input from our
community. The days of purely technical discussions operating in isolation
is long gone. Ask the biologists.
For instance RAI is spending a great deal of time looking at the Caller ID
spoofing problem to see if there appropriate technologies that can help
protect consumers as well as the network. Securing the IP address space
its almost endless now.
Believe me a lot of people are still worried about interference with the
existing IP transit peering agreements , but the current trend in SIP based
voice communications is to go to the bill and keep model ( at least in North
America) in fact the FCC ordered it to be implemented by 2020.
From: Phillip Hallam-Baker <phill(_at_)hallambaker(_dot_)com>
Date: Saturday, March 14, 2015 at 1:40 PM
To: Henning Schulzrinne <hgs(_at_)cs(_dot_)columbia(_dot_)edu>
Cc: Michel Py <michel(_at_)arneill-py(_dot_)sacramento(_dot_)ca(_dot_)us>,
IETF discussion list
<ietf(_at_)ietf(_dot_)org>, Richard Shockey <richard(_at_)shockey(_dot_)us>
Subject: Re: As if you don't have enough to read..
On Sat, Mar 14, 2015 at 11:38 AM, Henning G Schulzrinne
<hgs(_at_)cs(_dot_)columbia(_dot_)edu> wrote:
The US regulatory process provides both individuals and organizations
opportunities for input, both through written and oral contributions.
Submitting a comment is easier than writing an I-D, as no XML is required, but
there are deadlines ("comment periods") just as for I-Ds.
From my experience, FCC staff are generally more than willing to meet
individuals willing to provide technical information, particularly if they
have done their homework and are not just shilling as for-hire experts. If you
look at the citations in any major FCC item, you'll see plenty of references
to individual faculty presentations. For various reasons, the faculty visiting
the FCC tend to be law professors, rather than engineering, but that's mostly
self-selection.
The risk of making a submission is being asked to help fix the problem...
And the fundamental issue here is that the Internet architecture does not
have any concept of payment for transmission. It is assumed that everything
is 'free'. While this solves a very large number of problems it also creates
problems.
The telephone system has a very clear payment model in which the initiator
of a call is responsible for payment over the wired network and the receiver
bears the cost on wireless. That model simply does not apply to the Internet
and attempts to apply it produce nonsense.
Settlements and interchange agreements are tricky. Especially so when the
data streams are very one sided. But at the end of the day the consumer is
paying their broadband ISP for the ability to connect to NetFlix and
YouTube.
However, engineers should also realize that the high-order-bits of decisions
are not merely technical. They tend to involve legal and economic efficiency
arguments that are rarely clear-cut - they often involve predictions on how a
decision will affect investment, competition, public safety and human
behavior, among others.
Engineers are capable of understanding political and economic arguments!
they just understand them according to a totally different ideological frame
to the one the rest of the world lives in.
It's important to get the technical details right, but it's at least as
important to recognize that this is not just (or even mainly) about the proper
definition of IP addresses or "best effort(s)".
The proper definition of IP addresses is probably irrelevant. More critical
is the understanding of the way that interchange agreements work.
I think there is also something of a problem with the advice some folk give.
I was in a meeting where a very eminent IETF-er ranted about a 'nonsense'
requirement that a part of the Federal Govt would like. A week later I had a
solution worked out that did not cause any of the catastrophes claimed.
It is important to recognize that the 1980s Internet architecture was a
pragmatic approach in which the answer to a lot of hard problems was 'we are
not going to consider those right now'. Well now we have got to the point
where they matter.