Our response to Ofcom and the European Commission regarding Net Neutrality
This blog post was co-authored with John Oswald. John is a consulting manager out of our consulting division and is based in the UK. He also blogs. Recently, John and I worked together on responding on behalf of Amdocs to Ofcom’s public consultation on Net Neutrality and the European Commission’s consultation on the Open Internet and Net Neutrality. Attached you can find our formal detailed responses (Amdocs Response to Ofcom inquiry regarding Net Neutrality and Amdocs Response to European Commission’s Net Neutrality Consultation). Here’s a slightly more personal perspective:
Why I’d love Net Neutrality
Speaking as a consumer I would instinctively love the idea of net neutrality. I’d love everything I do on the Internet to be treated equally. No different from that experienced by any other person. I would like to be able to access every site with the same speed and the same quality of experience. I’d like to be able to share stuff with peers. I’d like to be able to serve any content from my own servers or web site, and do so at the same speeds and latency that Google does. I’d love to be able to do all that. It would also mean that I could access any file, any file type, any type of data, from any server and any peer – using any service, unencumbered and unfettered by the network provider I just happen to be connected to in order to have access to it all.
Basically, wouldn’t it be great if internet access was a human right, a little bit like access to the oxygen we need in order to breathe? Although the quality is not uniform, just about every living person on the planet has unrestricted access to oxygen.
But why this cannot work
However, this model is unsustainable. You might ask “Why is it unsustainable?” Well, on one hand the network capacity, and the access to it, are finite resources that continuously require investment in order to provide a service. On the other, the usage that we have is disproportionate – one user can and does use 100 times more than another user. As opposed to oxygen, which we all use approximately the same amount of, this is not true for network capacity. In fact, a very small percentage of the users consume a large percentage of the network resources, as various bits of research indicate. In addition to this, as opposed to oxygen, the amount that each of us consumes is not fixed, but rather grows exponentially over time. As we use the network to download more and more video, with higher definition, and more content and applications use the network in new ways, we simply keep on using more of it more of the time. It’s not even linear growth, but rather exponential. Just to maintain the quality of service that we are familiar with – that is adequate for the services we consume, communication service providers need to pour in continued investment. So it’s not just a matter of adding users to the network, for which it is obvious investments are required, but the users that are already there use more and more network resources.
The analogy to draw is closer to electricity or energy in general. In the case of electricity, people that use more, pay more. Electricity is not an infinite resource, it’s a finite resource.
So the hypothesis that the network is a resource that’s evenly available with no distinguishing elements between users or services is simply wrong.
While I would love it as a consumer, it’s simply unsustainable from a business perspective.
Could a government take it upon itself to provide this network connectivity? Well, perhaps. But it too would need to invest more and more taxpayer money into building out and maintaining the network, which would be devoured at exponential rate and very unevenly by its citizens. The government would be subsidizing the use of the very few heavy network users.
So what does work?
Well, a predominantly self-regulating free market works. That market is what has created the amazing broadband we see today – both fixed and mobile. That market has created all the innovation that we are experiencing in our exceedingly connected lives. It hasn’t been without its challenges: the fact this market exists at all has been considerably helped by regulators intervening to ensure that free competition can exist. In most places, consumers have the power to change providers, to comment on their services, to avail themselves of the most appropriate type of connectivity for their needs.
And what is required for this free market to continue to benefit us all is the ability to innovate and for new consumer-facing propositions to be created. In order to fuel this innovation, as has been the case since time immemorial, innovators need to be able to expect a return on their investment. Therefore, they should be able to enjoy some form of exclusivity to experiment and launch new ideas.
Let’s suppose an innovator wanted to develop a new service that requires a particular quality of service – for instance, the service might require that 99% of the packets arrive in sequence and within 50ms to their destination. That service might require conditioning of the network in order to support such a commitment to the innovator. However, in a ‘best efforts’ network, any congestion or burst from another user might thwart the ability to receive this high quality service. So, the innovator would, perhaps, be willing to pay for this high quality service – but if the innovator pays for this service, it would mean that any other user of the network might get bumped in order to support the committed agreement. That means that the packets of the innovator and other users of the network are not treated equally.
However, if the service provider were unable to offer this ability to the innovator, such services might never emerge – since it would be impossible to fund them. Innovators require a return on their investment in innovation.
What is true for the innovator holds true for any organization – emergency services, for instance, might need (and receive today on the telephony network) preferential treatment for handling of their communication needs. Not to mention some of the other services we’re increasingly seeing a lot of, like healthcare, home security etc. We are effectively ‘guaranteed’ a high quality of service when we watch TV; why not allow this for elements of the internet, which after all is becoming much more of an entertainment platform.
Indeed, the mere fact of building a network creates inequality in the availability of service to consumers and businesses. The placement of cell towers as well as any other configuration of the network has impact that prefers one person’s communications over the other. It is technically impossible to do it otherwise.
The network is not oxygen – it’s not a virtually infinite resource we all consume in a similar manner. It is a finite resource that is disproportionately used and useful. Service providers need to continue to invest heavily in maintaining and building out the network required for our exceedingly connected and high-bandwidth-demanding lives. The mere operation of the network in order to fairly serve the existing users requires active policy enforcement for the general population of users. Supporting innovators requires service providers to invest and experiment with various methods to condition the network. Such investment is not rewarded by significant regulation in the how’s and when’s of managing networks.
To learn more
We’ve included both our responses to the inquiries (Amdocs Response to Ofcom inquiry regarding Net Neutrality and Amdocs Response to European Commission’s Net Neutrality Consultation), should you wish to dive into the matter in greater detail and to see more explanations and justifications. We do realize this is an emotional debate, and one which strikes right at the heart at one of the catalysts for the global economy. We just felt the time was right to state what we think is an appropriate case, and continue to watch the debate with very high interest. Naturally of course, your comments are part of this debate, so they are very welcome!