Top ten ($7.2B) broadband stimulus: ideal conditions
April 13th, 2009 by kcLast month (23 March) I was on an NTIA panel at the Department of Commerce, to recommend conditions on this broadband stimulus money, aka arm wrestling between companies. Gigi covers it in her blog; today was the deadline to finish my recommendations to DOC and NTIA:
- Prepare for the inevitable realization of the underlying empirical fact: you can’t make Wall-Street-approved margins moving bits around over long distances. You certainly can’t have bit-moving margins and get science and innovation and critical infrastructure protection done. Other countries now ahead of us in broadband penetration have already figured out effective policies for stimulating broadband growth. As a general rule the DOC and NTIA should use this money to put the U.S. Congress in a better position to improve our current failing policies.
- Architect some economic transparency into the rest of the industry. The erosion of voice revenue which has funded much of the Internet’s evolution — with the help of regulation allowing that subsidy — means the business model for Internet transport is fundamentally unsustainable, which the carriers know better than anyone. But the entire Internet provisioning ecosystem is characterized by pervasive non-disclosure agreements, undocumented cross-industry subsidies and a common practice of treating even mundane operational practices and costs as trade secrets, which leaves regulators operating in a fog around the Internet infrastructure, not ideal conditions to write regulation. Recall, the last reported accounting error in our industry was bigger than this entire broadband stimulus package. Which is all admittedly noise compared to AIG, but it was the Biggest Bankruptcy Ever at the time. It’s obvious why we’re repeating history: we don’t have any data.
- Use this transparency to pursue a quantitiative macroscopic picture, starting with the economics. Use a chunk of the $350M to create a visual map of how the funding flows through the ecosystem, as well as acquire and publish quantitative data on pricing, penetration, performance, and peering of Internet transport providers. Spending some of these mapping funds on data-sharing and objective research and analysis will help establish a rigorous field of Internet economics, the lack of which engineers now admit limits our ability to fix technical problems of the Internet. Yet the two biggest conversations about pricing (network neutrality and metered billing) are happening with no cost and pricing data, much less data on traffic levels or patterns.
- On a simillar wavelength, use some of the $350M allocated for mapping to fund a spectrum inventory with R&D support.
- Establish a technical advisory team to peer review and steer progress on mapping and other data analysis projects, including privacy-respecting, legal, and ethical data handling practices. Document where limitations prevent sharing of data otherwise considered relevant to broadband stimulus goals.
- Require wholesale non-exclusive access to any infrastructure owned by the company that takes stimulus funds. Support experiments with structural separation, like the UK’s Openreach which has led to falling prices, or Australia’s recently announced experiment with public infrastructure. (Yes, this pretends we didn’t make the mistake of tossing common carriage concepts for the Internet. )
- Leverage other funding communities, e.g., allow NSF or DHS to cost-share with broadband stimulus projects for R&D that provides particular leverage in building infrastructure, or for public-private partnerships that advance broadband and mapping capabilities. Example projects include a backbone infrastructure to connect community and municipal networks in exchange for research support or public safety. Require that funding recipients send at least one representative to academic research and scenario planning workshops. Provide funding and policy support for data collection to validate tools funded by NSF to measure traffic, bandwidth estimation, mapping, hygiene (filtering, config), penetration, usage patterns. (Cost-share with the $250M for innovative programs to encourage sustainable broadband adoption).
- Leverage other infrastructure, like electricity grids and roads. Encourage partnerships. Don’t allow recipients to lobby against competition. Use existing successful infrastructure projects as role models.
- Disclose all traffic mangement behavior. Avoid deep packet inspection (DPI) techniques except for security reasons, until the privacy conversation matures.
- Require that providers maintain responsive abuse contact, and accurate registry information for all DNS names and IP addresses hosted by the provider.