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[ NNSquad ] Comcast's New "Two Strikes and You're Dead" Internet Usage Policy -- and More

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To: pfir-list@pfir.org
Date: Thu, 28 Aug 2008 18:31:34 -0700
From: pfir@pfir.org
Subject: [ PFIR ] Comcast's New "Two Strikes and You're Dead" Internet Usage
	Policy -- and More

 Comcast's New "Two Strikes and You're Dead" Internet Usage Policy -- and More


Greetings.  Comcast has announced a 250 GB/month "death penalty"
Internet usage cap, effective October 1.  This appears to be based
on the total of all downloading and uploading 
( http://tinyurl.com/comcast-bandwidth-cap ).

Comcast and some observers will no doubt suggest that 250 GB is a
generous cap, particularly in light of some ISPs apparently planning
caps an order of magnitude or more lower.  I'll have more to say
about "other ISPs" below.

Some specific details of Comcast's new policy are definite eyebrow

The cap is not a "no more usage after this point" cap.  It's a
"you're no longer our customer" cap.  Exceed the limit twice in six
months and you're tossed from Comcast for a full year.  Due to
limited practical competition in many areas, that would mean that
some former customers would not have access to any other broadband
Internet services at affordable (or in some cases any!) prices.

Comcast appears not to be providing customers with a means to check
their current Internet usage volumes.  They simply suggest that
their subscribers go out and find software for this purpose for all
of their computers and handle it completely by themselves.  

The same cap applies to all levels of residential service,
regardless of the speed tier to which the customer has subscribed.

The usual table of comparative usage is presented of course, to
supposedly inform users about what 250 GB really means.  Well,
actually, the document provides the table twice, and the numbers are
different in each!

Table 1:

    Sending 20,000 high-resolution photos,
    Sending 40 million emails;
    Downloading 50,000 songs; or
    Viewing 8,000 movie trailers

Table 2:

   Send 50 million emails (at 0.05 KB/email)
   Download 62,500 4 MB songs (at 4 MB/song)
   Download 125 standard-definition movies (at 2 GB/movie)
   Upload 25,000 hi-resolution digital photos (at 10 MB/photo)

Hmm, 10 million e-mails appeared magically between Table 1 and 
Table 2!  And man, those are sure short Table 2 e-mails -- only 50 bytes
each!  Oops, let's try figure out what they really meant.  Maybe 5K
each?  Oh well, the details don't matter, right?

But of course, most people use their Internet connections for a mix
of applications -- many of which run autonomously, so no one element
of those conflicting tables will apply in isolation for most

Hey, wait a minute.  Is something important missing from those
tables?  125 standard-definition movies says Table 2.  Huh.  The
cable companies, including Comcast, have been telling us that
standard definition is obsolete, that we all need to upgrade to HD
service!  I wonder why they didn't include HD movies in their
tables, given that those will increasingly dominate what viewers

Perhaps this issue relates to the fact that a typical HD movie can
run maybe five times the size of the same SD movie?  Yeah, I guess
"25 HD movies" (as your total usage for the month) wouldn't look so
great, especially when Comcast's own on-demand/PPV movie offerings
don't count against your Internet usage cap at all!  Well, so much
for outside movie services providing HD.  "We don't need no stinkin'
competition!" -- right?

With Comcast leading the way, we can assume that other ISPs -- cable
and DSL -- will be hot to trot for this bandwagon.  

I saw this image ( http://lauren.vortex.com/rr-no-limits.jpg ) in a
Time Warner Internet ad a few days ago.  One imagines that such 
"No Limits" promotions will be seen as a historical artifact very
shortly.  I visualize Wile E. Coyote crouching in a cave, smiling at
a rack of equipment labeled "ACME Bandwidth Limiter" -- as the Road
Runner zooms along a nearby desert road.  Suddenly a light on the
ACME unit turns red, a metal wall pops up in front of the Road
Runner, and the speedy bird finally meets his match is a flurry of
flying feathers.  Wile attaches his bib, grabs his fork and knife,
and heads out for his long-awaited reward.

Reasonable network management by ISPs should not only be accepted,
but also expected.  We all want the Internet to run smoothly.  But
sloppy, arbitrary, technically questionable, or anti-competitive
policies are not acceptable.  It's time to start a serious dialogue
regarding the differences between these two situations, and how as
consumers of Internet services we can obtain enough information
about ISP operations to make informed judgments about such matters.

In the meantime, Comcast might want to clean up their bandwidth cap
FAQ on an ASAP basis -- before David Letterman gets hold of it.

Lauren Weinstein
lauren@vortex.com or lauren@pfir.org 
Tel: +1 (818) 225-2800
Co-Founder, PFIR
   - People For Internet Responsibility - http://www.pfir.org 
Co-Founder, NNSquad 
   - Network Neutrality Squad - http://www.nnsquad.org
Founder, PRIVACY Forum - http://www.vortex.com 
Member, ACM Committee on Computers and Public Policy
Lauren's Blog: http://lauren.vortex.com 

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