The Internet was set alight last October, when news broke out that Comcast actively interfered with P2P traffic. Nasty words flew back and forth. Lawsuits were filed. Even the FCC joined the party, kicking off its own investigation early last January.

Fast forward to last Tuesday, when Comcast answered the FCC’s inquiries with an 80 page reply (PDF) that explained the company’s rationale behind its definition of “reasonable network management:”

“Notwithstanding the enormous capacity and flexibility of the cable infrastructure, there are (and always will be) some throughput limitations. Thus, the question is not whether all customers will be able to use shared bandwidth indiscriminately… but, rather, how to optimize every customer’s online experience and ability to … use all Internet applications and services.”

Fair enough. Other parts of the document point out that Comcast is more concerned with making sure that their average users can surf the web proper, as opposed to placating the desires of a “vocal minority of users who make the most noise.”

Right there, however, Comcast’s logic falls apart. A quarter of the way through the document – Page 14, according to Acrobat – Comcast defers to the testimony of Congresswoman Mary Bono Mack, who says that “P2P applications are designed to consume as much bandwidth as is available, thus more capacity only results in more consumption.”

So that much is true – but just as true are the numerous other protocols and applications that are also bandwidth intensive. Almost every other non-streaming application works because of similar goals: using as much bandwidth as necessary to obtain optimal results. In some cases, bandwidth requirements are minimal, like in online chat applications. In other cases, however, saturating a user’s limited pipe simply isn’t fast enough, as you simply cannot escape the fact that downloading a file or streaming a high quality video requires a comparatively large amount of data. There are many, many bandwidth hogs out there that are just as good, if not better, at “clogging the tubes” than BitTorrent and its ilk.

Look at Windows Update: every time Microsoft drops a big patch on the Windows masses, literally hundreds of millions of computers throughout the world will compete for space to download it – and it is quite often very large: a 2005 estimate from Chris St. Amand of the Microsoft Operations team pegged Windows update traffic at 10-15 gigabits per second from the main download center during peak periods.

Comcast users represent a significant chunk of that number, being that the ISP is currently the #2 provider of Internet services in the United States. Where’s Comcast stepping in to manage its subscribers’ use of Windows Update?

The point I’m trying to make here is that BitTorrent isn’t the only bandwidth demon that haunts ISPs, and for Comcast and Congresswoman Bono Mack to accuse it of consuming “as much bandwidth as possible,” without mentioning many of the other applications that do as well, is obfuscating the real issue: that Internet consumption is expanding faster than ISPs would like it to.

Services like BitTorrent, and other P2P apps, have a legitimate place in today’s and tomorrow’s Internet. A number of progressive companies – Blizzard Entertainment, Joost, and others – use BitTorrent, or BitTorrent-like systems, to offload content away from the old guard of expensive, centralized client-server models and towards newer, P2P models. While this model does introduce an extra burden on the ISPs, I would think that ISPs should be responding to the needs of their customers, and not the other way around.

Food for thought: if Comcast invested all the money spent on excessive “network management” towards expanding the weak points of its infrastructure, how much further would the company be? How much further would the quality of our Internet service be? Instead of cracking down on protocols that Comcast deems unworthy, wouldn’t it be easier to promise – and enforce – a usable minimum of bandwidth to subscribers, and allow the rest of the pipe to be a free-for-all?

You can tell that Comcast is on the defensive. In the places where its response to the FCC isn’t littered with narcissistic praise, it constantly qualifies its “network management” practices with words like “little” or “minor” or “reasonable,” and there’s always an emphasis on the well-being of “all” users. Frequently these qualifiers appear italicized for emphasis. Don’t get me wrong, I’m all for reasonable network management – and indeed Comcast names many examples of reasonable network management in other companies – but none of those definitions include Comcast’s, who thinks that injecting forged disconnect packets into P2P sessions is “reasonable.”

Comcast contends that its practices are necessary so that it can stay viable in an intensely competitive – hah! – industry. I am officially calling shenanigans on this claim. I think Comcast is unwilling to further invest in its infrastructure’s weak points despite its considerable financial growth in 2007, and that it is unwilling to support an Internet that is growing faster than its master plan.

The Greek philosopher Heraclitus once wrote that “nothing endures but change.” Comcast, just like most any big company, is simply fighting change – and all the disruptions that come with it.

But we all know what happens when you fight change, right?