Even if the FCC's Comcast order had been based on sound legal and technical footing, its implementation would require extra-human powers of perception since the Commission couldn't be bothered to lay out precisely which features of the Comcast system it finds objectionable. The order criticizes the use of TCP Reset packets to prune the thousands of connections a P2P application can create in a day’s time, but doesn’t ban the technique. That's fortunate, because home gateways also use Resets to clean up NAT tables.
The order objects to the application of bandwidth quotas to classes of applications, but its signatories have issued press statements endorsing priority boosting to benefit other classes of application, such as VoIP.
The only management techniques the order says an ISP can apply that clearly won't run afoul of future whole-cloth enforcement actions are the most heavy-handed. An ISP may apply volume-based billing, the worst possible method for P2P companies, or it can "throttle back the connection speeds of high-capacity users," the worst possible scenario for home network users.
The flat-rate pricing model we’re all used to only works when users consume roughly equal amounts of bandwidth, but the adoption of P2P for non-stop use by a small number of people blows it out the window.
Comcast has adopted a bandwidth cap of 250GB to prevent just one per cent of its customers from consuming half its download capacity. Japan's NTT has adopted 900 GB monthly upload caps on its fiber, Time-Warner is experimenting with metered pricing, and Frontier Communications has adopted a full-scale metering regime that prices downloads at $4 per gigabyte.
When ISPs are forbidden from de-prioritizing P2P streams, management-by-pricing is inevitable.
The only sensible method of traffic management that's ever been proposed for home networks is a two-stage system that does the following:
Firstly, it divides it bandwidth equitably among users at a given service tier; and then, secondly, it allocates delays among the streams to and from each user account according to application needs.
This approach is necessary because internet users do more than one thing at a time. When someone in the house is using VoIP, someone else is surfing the web and both may be downloading files using P2P. Under the FCC's new system, this sort of mixed-use scenario qualifies the entire account for connection speed downgrading, which can only be overcome by purchasing a higher service tier.
Save the Internet is already complaining about the price increases their petitions have wrought.
"It is a false choice to suggest that since Internet service providers cannot arbitrarily block online content, they will be forced to meter. There are a whole host of other non-discriminatory options available to providers that are more effective at managing congestion," the group says in a statement.
Unfortunately, there are no management approaches for mixed-use scenarios that don’t involve just enough discrimination to identify application needs, and the FCC has just banned that practice.
Thanks a lot, folks.®
Richard Bennett is a network architect and occasional activist in Silicon Valley. He wrote the first standard for Ethernet over twisted-pair wiring and contributed to the standards for WiFi and the Ultra-Wideband wireless networks. His eleven-year old blog is at bennett.com.