Level 3 Communications Issues Statement Concerning Comcast's Actions

<http://www.marketwatch.com/story/level-3-communications-issues-statement-concerning-comcasts-actions-2010-11-29?reflink=MW_news_stmp>

I understand that politics is off-topic, but this policy affects operational aspects of the 'Net.

Just to be clear, L3 is saying content providers should not have to pay to deliver content to broadband providers who have their own product which has content as well. I am certain all the content providers on this list are happy to hear L3's change of heart and will be applying for settlement free peering tomorrow. (L3 wouldn't want other providers to claim the Vyvx or CDN or other content services provided by L3 are competing and L3 is putting up a "toll booth" on the Internet, would they?)

Essentially, the question is who has to pay for the infrastructure to support the bandwidth requirements of all of these new and booming streaming ventures. I can understand both the side taken by Comcast, and the side of the content provider, but I don't think it's as simple as the slogans spewed out regarding "Net Neutrality", which has become so misused and abused as a term that I don't think it has any credulous value remaining.

I'm hoping that there is an eventual meeting of the minds wherein some sort of collaboration takes place. If this gets additional government regulations I fear no one will like the result.

Sincerely,

Brian A . Rettke
RHCT, CCDP, CCNP, CCIP
Network Engineer, CableONE Internet Services

Between the lines: Comcast wants to end mutual peering agreements (due to:
ratios, politics , greed) but we are going to spin it due to net neutrality
making it main stream media and hoping we can get comcast clients to
complain...

Not the worse angle we've seen

I'd have to agree with Brian. There is no simple answer to this one... If the ultimate cause is the abuse of bandwidth, I can understand this... BUT if the underlying motive is to squash competition then shame on you!

A customer pays them for access to the Internet. If that access demands
more infrastructure then Comcast needs to build out the infrastructure and
pass on the costs to the customers demanding it.

I think it sets a very bad precedent that Level3 agreed to their terms. How
long would it have lasted with Comcast subscribers asking why they couldn't
download their movies?

Aaron

Is L3 really pushing more streaming traffic than LLNW? Is ending
settlement-free peering with Google (Youtube) coming down the pipeline?

"On November 19, 2010, Comcast informed Level 3 that, for the first time, it will demand a recurring fee from Level 3 to transmit Internet online movies and other content to Comcast's customers who request such content."

If the issue is bandwidth, then why not charge for bandwidth? Picking a specific service says we are trying to squash the competition.

I think Karl Denninger has this one called right:
http://market-ticker.org/post=173522

Is Level3 the content provider though? Or did Comcast just decide they
don't want to do the settlement free peering thing anymore for traffic
transiting via Level 3?

~Seth

But then Comcast might have to raise prices on their customers. This way
they don't.

~Seth

I agree. This type of maneuver is no different than ESPN3 charging the ISP for the ISP customers to access the content. Both are unscalable models that threaten the foundation of an open Internet.

As an ISP, I could care less what is in the packets my customers send and receive. The exception to this, of course, is malicious packets but they keep refusing to set the evil bit.

Jack

I'd have to disagree with his viewpoint. If customer is using resource X and
you're not able to remain profitable, than you're not charging customer
enough for the resource in question. This is just a backdoor attempt to
raise the cost to the customer without them seeing it.

If Comcast were to raise the price to the customer directly, I think you'd
see defection to other services (if available in the area, like DSL or
Clearwire).

Doesn't Verizon FIOS provide 50-150Mb/s to the home now for the same cost as
Comcast? Exhorting a carrier of content to your customer can't be a good
business decision.

A customer pays them for access to the Internet. If that access demands
more infrastructure then Comcast needs to build out the infrastructure and
pass on the costs to the customers demanding it.

s/Comcast/Level3/

I think it sets a very bad precedent that Level3 agreed to their terms. How
long would it have lasted with Comcast subscribers asking why they couldn't
download their movies?

Considering L3 was recently skating the border of the pink sheets,
it should be no wonder that it is a very different response than
the one given to Cogent, for example. Then again, who blinked first
there? It is amusing that the once-disruptive L3 is seeking to
defend its position in the so-called "tier 1 " carte^Wcabal by running
to the regulators. I wonder how its fellow members of the club will
like the idea of feds poking into their business when both sides of
the equation are examined...

Unless I am missing something, Level3 is just the transit provider. Level 3
(via one of their acquisition a few years back) does have a very popular CDN
product, but even if they are the source from an IP perspective, they still
do not own the content, that is still primarily the networks and studios.

Also as to GoogleTV, from what I have seen so far they are simply providing
an interface (via an OS for 3rd party hardware) to access already available
content, so yes they would be affected.

  -Scott

A customer pays them for access to the Internet. If that access demands
more infrastructure then Comcast needs to build out the infrastructure and
pass on the costs to the customers demanding it.

I'd change this to "A customer pays for SHARED access to the Internet." Unless your customer is paying for a direct fiber or internet circuit (~$500 - $10,000 per month) they aren't paying for independent and sole access to the internet. It's another term that I think has lost its actual meaning, "Unlimited access." I don't have a problem, as a customer or as a Service Provider, passing along the bill to the top 5% that are using a disproportionate amount of bandwidth.

I can see the Internet reaching a fair-use model, as opposed to a free-use model that is unsustainable, as was previously said.

Here's one specific example I can think of to discuss:

Netflix uses about a third of Internet bandwidth, in some cases going over the HTTP traffic use for most customers. Netflix charges customers a fee to use their service, but they don't pay the providers required to supply the bandwidth for the customer leg. I don't think ISPs charging Netflix is a sustainable model either. A mutual endeavor involving shared interconnect costs and intelligent placement of proxies would be something I could think of to make the process beneficial for all parties. The end goal would be that the "Shared Media Customer" has no idea what we are doing, but does not see performance degradation in their HTTP or Netflix traffic, and that it does not pass along additional cost to them. After all, to both Netflix and the ISP, it is in their best interests to keep that customer a happy and paying customer.

Sincerely,

Brian A . Rettke
RHCT, CCDP, CCNP, CCIP
Network Engineer, CableONE Internet Services

Is L3 hosting content for Netflix? Netflix has become a large source of
traffic going to end users. L3 likely could have held out on this one if
the content they were hosting is valuable enough to Comcast's customers,
but maybe what Comcast was asking for wasn't much in the grand scheme of
things.

Obviously someone has to pay for the access infrastructure and Comcast
would much rather get the content provider to pay for it versus passing it
along to their customers. I think they probably just took a stab and L3
complied.

Phil

My take on this is that settlement free peering only remains free as
long as it is beneficial to both sides, i.e. equal amounts of traffic
exchanged. If it becomes wildly lopsided in one direction, then it
becomes more like paying for transit.

Perhaps this is the "cost" of acquisitions and mergers, like acquiring a
CDN product that dramatically screws with your peering ratios.

~Seth

I'm a hosting provider - and I have to pay for upstream.
Perhaps I should setup a rule counting comcast traffic and send them a bill, because their customers download stuff at my site and generate costs?

Kind regards,
   Ingo Flaschberger

From: Rettke, Brian
Sent: Monday, November 29, 2010 2:41 PM
To: Patrick W. Gilmore; NANOG list
Subject: RE: Level 3 Communications Issues Statement Concerning
Comcast'sActions

Essentially, the question is who has to pay for the infrastructure to
support the bandwidth requirements of all of these new and booming
streaming ventures.

From a cultural standpoint, we in the US are used to a model where the

sender pays the postage for unsolicited content and the requestor pays
the shipping for requested content. So asking an ad network to pay
Comcast for shipping their ads is valid but in a request where the end
user specifically asked for a movie, the user should be expected to pay
for that. What Comcast appears to be doing is subsidizing "flat rate"
customer rates by charging the providers "metered" access (assuming the
fee charged the provider isn't also a "flat rate"). If so, that really
isn't fair because:

1. The provider has no control over the size of or number of requests
that are made. The provider is essentially agreeing to an unknown
quantity in advance.
2. There is no way to ensure that a request is legitimate and not a
request generated simply to generate revenue (sort of like click fraud
... stream fraud).
3. It opens the provider up to a "denial of sustainability" attack
where a bot net requests many copies of various streams, sends them to
the equivalent of /dev/null and the provider is presented with a huge
bill.
4. The only way a provider could mitigate increases in fees is to meter
access causing a sub-optimal user experience.

Shouldn't Level3 turn around and charge Comcast for distributing
NBC/Universal content?

The whole thing is like a movie theater charging the studios to show
movies while selling tickets to the public to watch them. Actualy, it
is like Universal opening their own movie theaters and charging
competing studios to show their movies while still charging the public
to see them. Comcast is simply imposing a tariff on competing content.
If I were level3, I would have denied the request. Customers on Comcast
would then discover they have sub-optimal Internet service and gone to a
competitor (AT&T Uverse or Verizon FIOS, for example).
  
As owner of NBC Universal, Comcast is a producer as well as a
distributor of content. That puts them in direct competition with other
producers regardless of the distributor. Level3 should deny the request
and Comcast users will have "Internet" access instead of Internet
access. Comcast doesn't have the captive audience they once had in many
places and when customers discover their choices are limited when they
choose Comcast, they will go elsewhere.

I hope Level3's acquiescence is temporary or the FTC puts a stop to it.
It is sort of like FedEx owning the freeway and charging UPS to use it.

It seems that Comcast(AS7922) peers directly with Netflix(AS2906)....?