Problems with New America Foundation’s transparency standard
Two weeks ago I raised the need for a broadband transparency standard and proposed some ideas just to get the conversation started. Yesterday, the New America Foundation’s Open Technology Initiative (OTI) issued their recommendations for a broadband transparency standard, but there are some flaws in their proposal that make it practically impossible to achieve unless we’re willing to pay 10 times more money for broadband services.
The first problem I noticed is that the OTI appears to be calling for no more than a 2 to 1 contention ratio i.e., every bit of capacity can only be shared by two subscribers. So for a 15 Mbps broadband connection, the OTI is advocating a minimum speed of 8 Mbps to the border router and Robb Topolski of the OTI stated in an email announcement that “the ISP can support whatever minimum rate he’s willing to back up financially (via a refund or credit)”. But the way broadband works today (especially Cable broadband) is that every bit of capacity is shared by 20 or more subscribers but the benefit is that consumers pay 20 times less for each megabit per second than a commercial grade dedicated circuit. By purchasing 1/20th fractional ownership of a 6 Mbps circuit, consumers only pay $6 per Mbps instead of the $100+ per Mbps price of a dedicated unshared business class circuit. 2 to 1 contention ratios are far too impractical for broadband services just like owning 182 days per year of a hotel room in Hawaii would be too expensive for most people.
Having a guaranteed minimum border router connection speed that is no less than 50% of the advertised speed might be attainable if we are measuring an hourly average and we exclude the worst case peak usage hours, but it will be highly impractical to guarantee those minimum speeds at one second or one minute averages.
The other big problem with the OTI transparency proposal is that it is advocating a maximum permissible round trip latency to the border router (the ISP’s router that connects to the rest of the Internet) should be no more than 50 ms. If we assume that this minimum guaranteed number is specified by the ISP, the scheme simply wouldn’t work. In fact, it would break down as soon as the user uses an application such as BitTorrent or other P2P application that has a tendency to send and receive several packets back-to-back. Just 4 back-to-back packets on a 6 Mbps broadband connection would cause the latency to go beyond the 50ms maximum which means this scheme clearly would not work. This is the reason I put in an exception for self-induced jitter and latency. The only way to solve this jitter problem is if the ISP intelligently prioritized the network which Robb Topolski ironically opposes. A more fundamental problem stems from the fact that there are actually many “border routers” employed by ISPs and some of them may be on the other side of the country which have latencies of 70+ ms latency simply because the speed of light in glass doesn’t allow for packets to travel across the country and back any faster.
Moreover, I certainly hope that the OTI isn’t suggesting that all broadband providers be able to provide sub 50 ms round-trip latencies because even WiMAX will have a difficult time ensuring such low latencies. It would be out of the question for HSPA or EV-DO based 3G technologies and only LTE would be able to consistently achieve such a low latency. But even then, nothing can prevent the subscriber from stuffing their own broadband connection with so many packets that it causes over 1000 ms jitter unless implement a QoS enabled network.
Coming up with a transparency standard isn’t easy and it is the reason I only put forth some ideas for everyone to publicly debate. We should not unilaterally propose a standard and just expect network operators to follow it.
Hey George, thanks for reviewing the proposal.
The ISPs currently are able to come up with a number and emblazen it on all of their ads. Some of us actually get that number, but many do not.
If we were to take the true contention ratio, we’d be diving the size of the bandwidth pool by the number of homes passed who subscribe to Internet and we’d have both the accurate speed and an amazingly small speed. That’s fair, but it truly isn’t what the ISPs are selling because we know that all those subscribers won’t be on at once and that things like bandwidth consumptions limits and other traffic management techniques can further improve the minimum speed that an ISP can virtually guarantee.
The guarantees of speed, latency, and uptime are to the ISP’s border routers or access routers (where their ‘net meets the rest of the ‘net). We think it’s important that the ISP be able to set its own service goals and raise the bar on itself and its competition. While it is useful to empower users with stated minimum expectations, we’re flexible as to the fine details (how long is ‘extended’?, how is this reliably measured?, and etc.) because ISPs need to manage some customers who have unrealistic expectations from the starting gate. The idea is that few customers will complain if ISPs generally treat them right in an area that is grossly oversubscribed, but there’s room here to bicker in the face of the few remaining hard-corps serial complainers.
There’s still room for improvement on the idea. Now that you know the goals, I invite you to help.
Robb Topolski
Chief Technologist
Open Technology Initiative, New America Foundation
Robb,
First of all, thank you for joining me in my call for more ISP transparency.
Second, thank you for dropping the idea that “up to” somehow equals “at least”. There’s been too much of an expectation that the “up to” bandwidth somehow means a minimum guarantee. I’m glad that you’re finally able to come around and accept the fact that Broadband will always have contention ratios.
As far as I’m concerned, I’d be very happy to have 1000:1 contention ratios if it means that I am sharing a 1000 Mbps pipe. Statistical multiplexing and some sort of fair share algorithm would mean that I get to burst to 1000 Mbps and get my short requests more instantaneously. Larger pools also mean better statistical stability. Statistical multiplexing and fractional ownership via usage caps allow the flexibility to boost peak performance and that ultimately benefits the ISP customer.
As I explained in this blog posting, there are two things you should really consider fixing in your proposal.
1. You need to be careful that you’re not advocating that contention ratios must be no more than 2 to 1. The way you’ve set up your example seems like you’re advocating no more than 2 to 1 contention. My suggestion to you is that you clarify it such that it means 50% (or whatever the ISP wants to set and advertise) minimum performance as an hourly average. That allows for temporary drops to 10% performance but they can make up the averages over the course of an hour.
2. You should specify maximum permissible latency that is not self induced. The way you’ve worded your proposal means that anyone who runs a P2P application will instantly jack up their own latency and jitter and cause the ISP to fail in their service delivery. That’s not a reasonable requirement for the ISP.
Furthermore, this is all the more reason that ISPs should be priorizing low bandwidth applications (low could also mean low average bandwidth e.g., web browsing) over high bandwidth applications. That allows P2P to be less toxic which means fewer people shutting off their own P2P client which translates into more seeders. Since I know you’re an avid P2P user, I invite you to join me in calling for more prioritization http://www.digitalsociety.org/2009/09/fcc-5th-principle-must-allow-for-reasonable-discrimination/.
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