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Comments on NTIA’s proposed Performance Measures for BEAD Last-Mile Networks

Comments on NTIA’s proposed “Performance Measures for BEAD Last-Mile Networks”

NTIA URL: https://www.ntia.gov/funding-programs/internet-all/broadband-equity-access-and-deployment-bead-program/program-documentation/draft-performance-measures-bead-last-mile-networks-policy-notice-public-comment

From: Karl Auerbach
CEO/CTO InterWorking Labs
Scotts Valley, California
karl@iwl.com (email)
https://iwl.com/ (corporate website)
https://cavebear.com/ (personal website)

Date: November 13, 2024

Permanent URL to these comments: https://www.cavebear.com/cavebear-blog/ntia-bead-dec2024/

Who Am I

I am Karl Auerbach, I am the CEO and CTO of InterWorking Labs (IWL). My CV may be viewed on my website at https://www.cavebear.com/about/karl-cv-long/

I have been involved with the development and deployment of the Internet since 1972.

Our business at IWL ( https://iwl.com/ ) is to create network emulation products that help network developers bench test their code against less-than-perfect network conditions to find problems before their own customers do.

As such, we (and I) deal daily with issues of network imperfections, including latency (including jitter/packet delay variation), bandwidth, packet loss, duplication, out of order packet delivery, and so on.

Overview Of Comments

I appreciate and support the thrust of the BEAD performance measures effort.

However, I find the proposals ambiguous, simplistic, and insufficient. Those inadequacies can be remedied.

My remarks are in four major parts. The first part deals with bandwidth and bandwidth measuring. The second part is similar, but on the topic of latency. The third part is about aspects of network performance that ought to be part of the BEAD Performance Measurement framework. The fourth part is a catch-all of other suggestions.

One point that is made multiple times below is the need for clarity with regard to the point of demarcation between a customer and network provider.

Network Operations On A Public Utility Internet

Permanent URL: https://www.cavebear.com/cavebear-blog/nanog-keynote-as-spoken/
Revised: March 3, 2023

I gave one of the two keynote presentations at NANOG (North American Network Operators' Group) in the fall of 2019.

There were two parts to the talk.

The first part deals with the responsibilities, obligations, and liabilities of being an operator of parts of an Internet that was becoming a lifeline grade public utility.

The second part shifts to ways we design and implement the Internet to improve its resiliance to errors, problems, and attacks. I suggest that we look beyond traditional methods of designing and implementing computer systems. In particular I urge that we take a look at the methods used by living things to improve their ability to survive.

Below the break is the textual transcript of the talk.

In case the video does not start at the right place, my presentation begins at 7:43.

Here is the transcript:

Internet: Quo Vadis (Where are you going?)

ArcadiaArticles, blogs, and meetings about the internet of the future are filled with happy, positive words like "global", "uniform", and "open".

The future internet is described in ways that seem as if taken from a late 1960’s Utopian sci-fi novel: the internet is seen as overcoming petty rivalries between countries, dissolving social rank, equalizing wealth, and bringing universal justice.

If that future is to be believed, the only obstacle standing between us and an Arcadian world of peace and harmony is that the internet does not yet reach everyone, or that network carriers are unfairly giving different treatment to different kinds of traffic, or that evil governments are erecting “Great Walls”, or that IPv6 is not yet everywhere, or that big companies are acquiring top level domains, or that encryption is not ubiquitous … The list goes on and on.

I do not agree.

I do not believe that the future internet will be a Utopia. Nor do I believe that the future internet will be like some beautiful angel, bringing peace, virtue, equality, and justice.

Big BrotherInstead I believe that there are strong, probably irresistible, forces working to lock-down and partition the internet.

I believe that the future internet will be composed of “islands'.

These islands will tend to coincide with countries, cultures, or companies.

There will be barriers between these islands. And to cross those barriers there will be explicit bridges between various islands.

Network traffic that moves over these bridges will be observed, monitored, regulated, limited, and taxed.

The future internet will be used as a tool for power, control, and wealth.

And to a large degree the users of this future internet will not care about this.

This paper describes this future - a future more likely than the halcyon world painted by others.