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[ NNSquad ] The FCC Internet Measurement Controversy Heats Up

The FCC Internet Measurement Controversy Heats Up
http://j.mp/MREYKl  (This message on Google+)

 - - -

For the last few days, an interesting controversy has been erupting,
largely out of sight of the nontechnical community.

It is potentially quite important.  It relates to how the FCC measures
ISPs' performance, as part of an effort to help assure that consumers
actually obtain the speeds and bandwidth that they've been promised.

For some time now, the FCC has been distributing a small device ("the
Whitebox") to participants in an Internet measurement regime via a
number of associated servers.

The genesis of this project was Measurement Lab (M-Lab), and until now
public Measurement Lab servers have been the primary servers used for
these ongoing measurements.  (I helped organize the original meeting at
Google that led to M-Lab, and also attended that meeting, so I've been
following this effort closely all along.)

Very recently, concerns have been raised that the FCC might be
preparing to move away from their reliance on these public servers and
move toward a system primarily relying on ISP owned and operated
internal servers that in some cases would not be publicly accessible.

When Vint Cerf and others initially raised public concerns regarding
this possibility, some observers branded them as being both incorrect
and alarmist (in one case, via a public message that I would
characterize as quite impolite in tone).

The FCC's CTO also responded, and said:

   "The FCC has no plans to move away from the M-Lab platform and
    replace it with closed-infrastructure ISP-managed servers."

However, as you'll note from the messages included below, a document
exists which at least gives the appearance of contradicting the FCC
on this issue in some important respects.

The key line from the document ["ISP-provided measurement servers"], is:

   "The above approach will allow us to use 'on-net' results in the
    future as our primary data source for reports."

That is, the document suggests a move toward using servers provided by
individual ISPs to measure those same ISPs' own performance, so most
measurements for any given ISP would be made on servers controlled by
that ISP.  This is in contrast to the current approach where servers
*not* under control of the same ISP are more commonly employed for
any given measurements involving that ISP.

I prefer not to send out attachments in these mailings, so I have
made the entire document available via: 

http://j.mp/MRAinJ  (Lauren's Blog)

At the very least, this appears to be a situation that is in need
of immediate clarification by the FCC.


----- Forwarded message from Dave Farber <dave@farber.net> -----

Date: Fri, 20 Jul 2012 08:01:20 -0400
From: Dave Farber <dave@farber.net>
Subject: [IP] FCC broadband measurement program. Please note attachment.
Reply-To: dave@farber.net
To: ip <ip@listbox.com>

---------- Forwarded message ----------
From: *Sascha Meinrath*
Date: Friday, July 20, 2012
Subject: Re: FCC broadband measurement program
To: David Farber <dave@farber.net>

Hi Dave,

I had a very productive meeting with Henning Schulzrinne yesterday and do
want to undermine the forward progress we are now making with the FCC.
 There is
a lot to be done to improve things, but I believe we are now working toward
same goals.  However, I do find it imperative to respond to Henning's public
statements. Earlier this week, Henning wrote:

"We share the objectives of the letter writers that 'Open data and an
independent, transparent measurement framework must be the cornerstones of
scientifically credible broadband Internet access measurement program.'Oo
Unfortunately, the letter claims: 'Specifically, that the Federal
Commission (FCC) is considering a proposal to replace the Measurement Lab
infrastructure with closed infrastructure, run by the participating Internet
service providers (ISPs) whose own speeds are being measured.' This is

I have attached a copy of the proposal, "ISP-provided measurement servers"
our letter references, and would ask your readers to read it for themselves
draw their own conclusions.  In particular, people should look at proposed
changes to the "Testing Schedule" section on the top of page 3.

The FCC now states that these concerns are "baseless", however, I believe
any reasonable reading of this document proves otherwise.  When Henning
"The FCC has no plans to move away from the M-Lab platform and replace it
closed-infrastructure ISP-managed servers," this proposal demonstrates
otherwise.  We were reluctant to share this document publicly, since it was
unclear if it was confidential; however, given the FCC's denial of its
existence, feel that it is now warranted.

--Sascha Meinrath
Director, Open Technology Institute
Co-Founder, MeasurementLab.net
New America Foundation

> ---------- Forwarded message ----------
> From: *Marc Donner* <donner@google.com <javascript:;> <mailto:
donner@google.com <javascript:;>>>
> Date: Thu, Jul 19, 2012 at 8:23 PM
> Subject: Dave Farber posted this from Henning Schulzrinne of FCC
> To: Meredith Whittaker <meredithrachel@google.com <javascript:;>
> <mailto:meredithrachel@google.com <javascript:;>>>
> From: Henning Schulzrinne <Henning.Schulzrinne@fcc.gov <javascript:;>>
<mailto:Henning.Schulzrinne@fcc.gov <javascript:;>>
> Subject: FCC broadband measurement program
> Date: July 18, 2012 4:06:30 PM EDT
> To: "dave@farber.net <javascript:;>" <mailto:dave@farber.net<javascript:;>>
<dave@farber.net <javascript:;>> <mailto:dave@farber.net <javascript:;>>
> Dave,
> please post to the IP list.
> ---
> Iím writing to respond to concerns that have been circulating on this
list regarding the FCC and our broadband measurement program.  I want to be
clear.  These concerns are baseless.  The FCC has no plans to move away
from the M-Lab platform and replace it with closed-infrastructure
ISP-managed servers.  The FCC is committed to the scientific process and
making measurement data openly available.  For our upcoming broadband
measurement report, we will be releasing all raw data and scripts necessary
to scrutinize and test our results.  We did that for the last report and we
will do that for the next report.  We will act, and have acted,
consistently with the scientific process and academic standards.  There has
been discussion of supplementing existing M-Lab servers with ISP servers so
as to have more redundancy and cross-checks in our testing.  The FCC is
reviewing this proposal and has not acted upon it.  The FCC will only
consider this proposal if it can be implemented c
 with our commitment to openness and transparency, and consistent with the
highest standards of scientific research.  I encourage anyone who is
concerned about circulating reports to not rely on those reports and to
contact me directly.  We embrace an open and public discussion about our
process.  We think this discussion will be most fruitful if it is based on
an accurate understanding of what the FCC has done and what proposals are
currently part of the open, public debate.
> Henning Schulzrinne
> =====
> Marc Donner
> +1-212-565-1977 <tel:%2B1-212-565-1977>

----- End forwarded message -----

Lauren Weinstein (lauren@vortex.com): http://www.vortex.com/lauren 
Co-Founder: People For Internet Responsibility: http://www.pfir.org 
 - Data Wisdom Explorers League: http://www.dwel.org
 - Network Neutrality Squad: http://www.nnsquad.org 
 - Global Coalition for Transparent Internet Performance: http://www.gctip.org
 - PRIVACY Forum: http://www.vortex.com 
Member: ACM Committee on Computers and Public Policy
Lauren's Blog: http://lauren.vortex.com
Google+: http://vortex.com/g+lauren / Twitter: http://vortex.com/t-lauren 
Tel: +1 (818) 225-2800 / Skype: vortex.com
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