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Cable giant defends Data Discrimination policy with 80 pages of chaff

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?



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RE: Comcast is a Monopoly
By lexluthermiester on 2/19/2008 3:31:39 PM , Rating: 2
I live in Salt Lake, UT and here we have Comcast, Utopia, Three different DSL providers[That all run through Qwset lines], Bi-directional Satellite and of course dial-up. I can sign up for 6mbps DSL for $45 after taxes. You live in a more developed area than I, so perhaps you should do some home work... I did a check and in Vermont there is Verizon Fiber & DSL @ 6 to 10 mbps, Speakeasy DSL @ upto 15 mbps and a few different satellite providers... eyebeeemmpawn; you have plenty of choices, pick one if you don't like Comcast. Granted, I have no love for them, but we both have choices.

As for the Comcast filtering[false disconnect pockets] of BitTorrent, I use the Azureus client and have the encrypted connections setting on. I also use a non standard port, which gets rotated once a week. I've had no issues with any level of bandwidth. And honestly if they ever did manage to "filter" my BT traffic, I'd simply go to a different carrier. Boohoo, I'll get over it. Qwest doesn't allow traffic shaping and neither does Utopia...


RE: Comcast is a Monopoly
By TomCorelis on 2/19/2008 3:43:14 PM , Rating: 2
Most Americans don't have your luxury.


RE: Comcast is a Monopoly
By eyebeeemmpawn on 2/20/2008 9:14:04 AM , Rating: 2
yeah, there are DSL options, but why don't you go ahead and try to get service somewhere here in Vermont? Fast DSL would be an option for me, but its not available at my house. Maybe you should do your homework. Not to mention that DSL charge would require a home phone line as well. I haven't had a home phone line is 7 years.

But again, I'll repeat my original statement:

Cable Internet vs. DSL != competition

I'm glad to hear that in other parts of the country you have options. But you're only kidding yourself if you think that having a cable internet option, and a dsl option is competition. The bills have increased ~20% in 2 years, with no increase in service level. Not to mention the customer service is absolutely terrible.

What will happen here is, they will charge "what the market will bear". But the market is set by Comcast, so the price will continue to creep up as they see fit. People will cancel when they just can't justify the expense. But with the increased profit margin on the remaining customers, what is their motivation to stay competitive? They're the only choice.


RE: Comcast is a Monopoly
By lexluthermiester on 2/20/2008 6:14:54 PM , Rating: 1
The point of my post was to point out that you DO have other choices, as with most people. And the $47 6mbps DSL connection included a basic phone line[dial tone] connection. Based on your challenge I did a little more research on the matter. I don't have your exact address[and don't want it], but DSL coverage seems to be an option for about 90% of Vermont's populace. Satellite is 100% of the USA and starts at 10mbps, full duplex. So really if you don't like Comcast, go with something else.


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