The Internet Distinction

———- Forwarded message ———-
From: Seth Johnson <[protected]>
Date: Tue, Jan 14, 2014 at 5:19 PM
Subject: Followup: Seth’s Edits on C&I
To: “Chip Sharp (chsharp)” <[protected]>, Doreen McGirr <[protected]>, “Elizabeth Bacon ([protected])” <[protected]>, “[protected]” <[protected]>

Attaching my edits on WTDC 47 and the C&I Study Question, as promised.
WTDC 47 – ID Edits
Conformance & Interoperability Study Question – ID Edits

Much easier to use than my explanations, also forwarded below. But
you should be able to appreciate the importance of these edits more
and find answers in these comments originally sent this morning.

Seth

———- Forwarded message ———-
From: Seth Johnson <[protected]>
Date: Tue, Jan 14, 2014 at 9:35 AM
Subject: My Notes — Re: [ITAC-D] WTDC ITAC prep meeting Tuesday
January 14 2-4:30PM
To: Julian Minard <[protected]>
Cc: “[protected]” <[protected]>

A note regarding problems with this study question that I have already noted.

My comments on Conformance and Interoperability from back in April:

https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/

also/more particularly:

On Conformance Assessment, Confidence and the Likelihood of Interoperability:
https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#LikelyInteroperate

On Conformance Assessment and Quality of Service:
https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#QOS

Also note concerns about Identifiers here:
https://internetdistinction.com/wsisimpacts/2013/11/25/cybersecurity-ict-applications-ip-based-impacts-on-the-internet/#Identifiers

Some notes:

Conformance and interoperability testing might become a basis to promote (and enforce) new types of networks (and related technology), without understanding how they might impact the Internet, even replacing the Internet without bothering to recognize the tradeoffs in doing so.

This is particularly the case since this study question is geared toward ITU-T recommendations, which deal with identifiers in numerous ways and which may serve as a basis for technical approaches to policy
enforcement. This is clearly the case given C&I’s connection to the Technical Barriers to Trade treaty.

This version of the C&I question also phrases things in terms of the
“need for confidence,” which doesn’t get to the point that conformance
and interoperability assessment can serve to support confidence by
policy (of some legal standing) as well as by technical compatibility
in an open Internet context. The Internet already supports confidence
in interoperability across networks on the basis of technical
interoperability.

At the above links I address this concern in terms of specialized
functions like QOS that work within networks but not so well (on the
basis of technical interoperability) between networks. They could be
accomplished, of course, by enforcing policy of some legal status.
This point also applies much more generally from the perspective of
the role of identifiers as I point out at the last link above, which
can enforce numerous types of policies. In the context of current
activities in updating copyright (a new proposed “right to make
available”), and initiatives such as the proposal for a broadcasting
treaty, the need to be explicit when we’re talking about technical
interoperability and when we’re talking about new legal policies
becomes important.

Pulling out a couple of passages:

On Conformance Assessment, Confidence and the Likelihood of Interoperability:
https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#LikelyInteroperate

“WTSA 76 asserts that an increase in confidence in ICT equipment
conformance with ITU-T Recommendations will increase the probability
that equipment from different manufacturers will interoperate across
networks from end to end. This is reflected in an observation in
Guadalajara 177 that the conformance assessment regimes that it
invites Member States to adopt can lead to a higher probability that
equipment, services and systems will interoperate.

“Information Society initiatives for conformance and interoperability should recognize that confidence in end-to-end interoperability is already enabled for the Internet based on general purpose packet transmissions. However, for specialized functions that are not as readily supported across the autonomous networks that make up the Internet, these Resolutions appear to be designed to enable providers and manufacturers to certify their compatibility with particular specialized functions that may be supported by particular types of networks. These specialized functions, and the types of networks that support them, should be distinguished from the Internet. While conformance testing would help increase the likelihood of interoperability for networks supporting specialized functions on the basis of increased confidence, it also can support interoperability on the basis of fulfilling policies backed by an intergovernmental authority. As the Information Society contemplates the establishing of an intergovernmental framework for policymaking that may touch on the Internet, it is critical that a basis is established for identifying when policies would impact the Internet deleteriously, by distinguishing networks supporting more specialized functions from the Internet.”

On Conformance Assessment and Quality of Service:
https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#QOS

“Guadalajara 177 includes a particular note that conformance
assessment regimes adopted by Member States will lead to better
quality of service/quality of experience. Quality of service is a
characteristic often sought to be implemented as a specialized
function in networks that treat IP packets specially according to
types or categories. Providing for quality of service in this way
generally can only be readily implemented across routers within a
network governed by a core authority and/or policy, rather than across
the routers of independent internetworking providers. A conformance
and interoperability regime that recognizes the nature of the Internet
should address quality of service not only in these terms, but also in
terms that recognize the role that the actual capacity of networks
plays in quality of service.”

Original email forwarded below.

Seth

———- Forwarded message ———-
From: Seth Johnson <[protected]>
Date: Mon, Apr 29, 2013 at 4:58 PM
Subject: WTDC/Plenipot: 1) Conformance and Interoperability:
Understanding Impacts on the Internet (was: Re: Critical Notes for
WTDC Prep)
To: “[protected]” <[protected]>
Cc: “[protected]” <[protected]>

(Reposting, revised to paste only part of the rather extended text
here in the email. — Seth)

At the link below is an analysis showing where the Conformance and
Interoperability resolutions open up the risk of the Information
Society undermining the Internet. I have pasted the introductory text
below, including general concerns and some key points.

The analysis is designed to contribute to upcoming proceedings such
as the WTPF, the WTDC and High Level WSIS Review in April 2014,
preparing the way to the Plenipotentiary Meeting in October/November
2014, where the necessary actions can be taken.

The full analysis is here:
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/

Please take it into account on the next WTDC Prep, general ITAC, and
Council calls.

You can see two general concerns and a set of key points here:
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#TwoConcerns
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#KeyPoints

I will move on to the other development-related topic areas I
described in the last ITAC call next: the enabling
environment/inclusivity; cybersecurity, ICTs and the Internet; and
measures/results analysis.

There are a number of reports being prepared to be presented at upcoming proceedings that also need to incorporate this concern: ITU Council Reports to the Plenipotentiary Conference on Conformance and Interoperability/Guadalajara Resolution 177, on Bridging the Digital
Divide/Guadalajara Resolution 139, and on Bridging the Standardization
Gap/WTSA Resolution 44; the BDT Report with lessons learned to WTDC re Conformance and Interoperability/WTDC Resolution 47; and the TSB
Report to the Plenipotentiary Conference (and future WTSAs) on
Bridging the Standardization Gap/WTSA Resolution 44. Additional
reports like these will become relevant as I address the other topics.

The commentary gives a picture of how the fact that the Information
Society leaves out a proper treatment of the nature of the Internet
plays out, by analyzing the subset of resolutions that relate to the
topic of Conformance and Interoperability. While the implications are
diverse, the actual revisions called for would be straightforward.
They mostly entail adding onto some references to general terms like
ICTs or telecommunications/ICTs, additional phrases like “including
the Internet” or “including both general purpose internetworking and
networks supporting various specialized functions,” etc. Then one
general resolution might be issued to which others could refer,
“Resolution XX on Internet Key Characteristics and Properties.”

I will need to look at the US position on conformance and
interoperability, the action plan, and more of the plenipotentiary
resolutions. I also need to know how the conformance and
interoperability regime relates to the “interoperability rules” that
the FirstNet Board is apparently going to be issuing. Other items
that will need to be reviewed are listed in my blog analysis here:
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#ReviewCI
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#ReviewDD
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#ReviewSG

See introductory text below or at the blog link.

Seth

Conformance and Interoperability: Understanding Impacts on the Internet

> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/

Contents:

Introduction: Background, General Concerns, Key Points, Relevant Resolutions

Conformance and Interoperability
WTDC Resolution 47, Guadalajara Resolution 177, and WTSA Resolution 76
On Conformance Assessment and Quality of Service
On Conformance Assessment, Confidence and the Likelihood of
Interoperability

Bridging the Digital Divide
Lack of References to the Internet in Relation to the Digital Divide
No Mention of Internet Empowerment of End Users and Providers
On Interoperability, Interconnection and Global Connectivity
On Pro-Competitive Policies and Regulatory Contexts for Expanding Access

Bridging the Standardization Gap
Lack of References to the Internet in Relation to Bridging the
Standardization Gap
Strategic and High Priority Issues in Standardization
Regional Group Terms of Reference and Mobilization Programs

Introduction

Background

The World Summit for the Information Society (WSIS) harbors a
potential of undermining the Internet platform. Its framing documents
and resolutions use general terms such as “telecommunications/ICTs”
and make very little reference to the Internet or its special
characteristics, thus providing no basis for recognizing when the
Internet may be affected by its initiatives.

Among these framing resolutions are those that cover development
initiatives and provide the frame for the next World Telecommunication
Development Conference (WTDC) to be held in Sharm-el-Sheikh, Egypt
from March 31 to April 11, 2014. The WTDC and the High-Level WSIS
Review event taking place in April 2014, along with the
Plenipotentiary meeting in October-November 2014, represent the key
occasions to assure that the appropriate resolutions are issued or
revised to enable the impacts that WSIS development initiatives may
have on the Internet to be readily recognized.

The WTDC Resolutions related to the Conformance and Interoperability
initiative represent one thrust that indicates where revisions are
needed to enable us to recognize when the Information Society’s
development initiatives may affect the Internet. This commentary
identifies the resolutions related to Conformance and Interoperability
and analyzes them in light of this concern.

We begin with two general concerns, followed by a set of key points
covered with more specificity in the commentary.

Two General Concerns:

The first general concern here has to do with the prospect
that conformance and interoperability testing might become a basis for
enabling government or privileged providers to promote new types of
networks by appealing to intergovernmental standards, without
distinguishing them from the Internet or recognizing the tradeoffs
these types of networks bring as compared to the advantages of the
Internet. This could be a problem if these standards work against
connectivity in the form the Internet makes possible, or if their
promotion allows something different to be called Internet.

The other general concern here has to do with applying
conformance and interoperability certification in connection with a
range of public policy issues with which the Information Society is
concerned. If we set up a standardization process under the ITU, and
if it fails to recognize the key characteristics of the Internet while
it is connected to these public policy concerns, we could easily end
up normalizing, in the name of public policy concerns, forms of
telecommunications and related policies that are detrimental to the
advantages of the Internet, without recognizing that impact.

Some Key Points:

The conformance and interoperability framework should reflect the distinction between the general purpose form of connectivity that the Internet Protocol makes possible between independent networks, and connectivity that supports specialized functions that are not as readily supported by general purpose internetworking.

Capacity building in conformance and interoperability testing
should incorporate recognition of the empowerment of independent
operators and end users made possible by the general purpose internet
platform as well as recognizing other types of networks supporting
specialized functions.

Conformance and interoperability should address quality of
service not only as a specialized function in networks that treat IP
packets specially according to types or categories, but also based on
recognition of the role that the actual capacity of networks plays in
quality of service in general purpose internetworking.

The conformance and interoperability initiative should
recognize that confidence in end-to-end interoperability is already
enabled for the Internet based on general purpose packet
transmissions. While the likelihood of interoperability for other
kinds of networks or specialized services will increase on the basis
of confidence derived from conformance assessment, conformance
assessment can also support interoperability through the upholding of
policies backed by an intergovernmental authority, a prospect with
implications that should be understood and addressed.

The resolutions on bridging the digital divide make no mention
of the empowerment of end users and independent providers made
possible by the Internet, or of how those factors drive development

The references to interoperability, interconnection and global
connectivity in the resolutions do not necessarily mean connectivity
in terms of what we understand as the Internet platform, but are used
in ways that could easily support policies imposing connectivity in
other forms, without clearly recognizing their impact on the Internet

General references to pro-competitive policies and regulatory
contexts in relation to expanding access should be adapted to
recognize the general purpose Internet platform made possible by
interoperation among autonomous, competing providers at the physical
layer, and should not characterize the policy and regulatory context
solely in general terms that may support other types of networks
without specifically recognizing the Internet as well.

Recognition of impacts on the Internet should be identified as a high-level objective and priority in standardization, and strategic and high priority issues in standardization should distinctly recognize end user and independent provider empowerment as a result of the Internet as particularly important concerns for developing countries, along with standardization initiatives that may be geared toward other types of networks.

The advice of proponents of increased competition among
independent providers at the physical layer within the US should be
recognized and applied by TSAG as an explicit consideration within its
mandate to coordinate standardization topics.

For the purposes of commenting on the revisions needed in this area,
it’s most useful to group the relevant resolutions under three related
topic headers — Conformance and Interoperability, Bridging the Digital
Divide, and Bridging the Standardization Gap. Click below to see the
relationships among all the resolutions making up the overall
conformance and interoperability thrust.

Click here for Resolutions Related to Conformance and Interoperability:
> https://internetdistinction.com/wsisimpacts/2013/04/28/wsis-impacts-conformance-interoperability/#RelatedResolutions

Commentary:

Conformance and Interoperability

WTDC Resolution 47, Guadalajara Resolution 177, and WTSA
Resolution 76 fit under the general heading of conformance and
interoperability.

A conformance and interoperability framework that recognizes the
nature of the Internet needs to draw a clear distinction between
certification of conformance and interoperability in relation to the
general purpose form of connectivity that the Internet Protocol makes
possible between independent networks, and certification for
specialized functions that are not as readily supported by general
purpose internetworking across autonomous routers.

WTDC Resolution 47

WTDC Resolution 47 instructs the Director of the Telecommunications Development Bureau to assist developing countries in building their capacity to perform conformance testing of equipment and systems and to follow up on implementation, including a periodic report to the T-DAG and a report on lessons learned to the WTDC in 2014. It invites Member States and Sector Members to enhance knowledge and effective application of ITU-R and ITU-T Recommendations in developing countries, and to introduce best practices in applying these recommendations. It says nothing about Internet, but does talk about fiber optics, broadband networks, and next-generation networks, inviting Member States to introduce best-practice application of ITU Recommendations in those areas through training and workshops in developing countries.

This resolution needs to reflect the above distinction in the
identification of best practices that it calls for: best practices in
applying recommendations for interoperability by general purpose IP
transmissions among autonomous networks, versus best practices in
applying recommendations related to networks that provide specialized
functions among routers implementing specialized treatment of packets.
The list list of example topics mentioned above should be extended to
include specific mention of Internet networks as well.

On Fri, Jan 10, 2014 at 4:30 PM, Julian Minard <[protected]> wrote:
> We confirm that we will hold an ITAC adhoc on WTDC preps Tuesday January 14,
> BUT IT WILL BE FROM 2-4:30PM. Recall that FCC is hosting this meeting as
> follows:
>
>
>
> Federal Communications Commission
>
> 445 – 12th Street, SW
>
> Room 2-B516
>
> Washington, DC 20554
>
>
>
> We will have a conference bridge and draft agenda on Monday, but it will
> address the draft US contribution and the proposed new question on C&I. The
> draft C&I text is attached herewith; the draft Contribution will be out as
> soon as possible, probably sometime Monday.
>
>
>
> Julian Minard, secretariat

———- Forwarded message ———-
From: Seth Johnson <[protected]>
Date: Tue, Jan 14, 2014 at 5:19 PM
Subject: Followup: Seth’s Edits on Broadband Study Question
To: Flavia Alves <[protected]>, Doreen McGirr <[protected]>, Roxanne McElvane <[protected]>, “Elizabeth Bacon ([protected])” <[protected]>, “[protected]” <[protected]>

Attaching my edits on the Broadband Study Question, as promised.
Broadband Study Question 2 – ID Edits

Much easier to use than my explanations, also forwarded below. But you should be able to appreciate the importance of these edits more and find answers in these comments originally sent Friday morning.

These edits are relevant to assuring the ITU properly addresses wired facilities, and are critical to assure the US and the ITU do not simply apply the Title I and market failure analysis approach that the FCC has acceded to after the DC Circuit’s previous rulings. After today’s ruling, these revisions are likely even more critical.

So as I said, I strongly urge you to bear these in mind.

The US is moving toward a better approach, having gotten CITEL to add wired infrastructure to the broadband question, and coming to understand how the terms IP-based Networks, NGNs and Internet need to be properly understood — and how the ITU’s processes are leading to misunderstanding on those points. BUT this does not mean the US or CITEL or ITU will address the real policy implications that are important for wired infrastructure in relation to the Internet.

Seth

———- Forwarded message ———-
From: Seth Johnson <[protected]>
Date: Fri, Jan 10, 2014 at 9:55 AM
Subject: Re Deep Dive on IAPs – my broadband edit
To: Roxanne McElvane <[protected]>, Doreen McGirr
<[protected]>, “[protected]” <[protected]>

Please find attached my text inputs for the broadband study question.

What I did was add bits to make sure it articulates how deployment of
broadband in the sense of specialized service network frameworks such
as IMT should coexist with internetworking.

Two paragraphs of explanation. The role of policies related to
land-based infrastructure is critical, and this relates both to the
FCC’s current attempt to defend their Title I approach out of the Open
Internet proceeding, and the Title II approach that reflects the
actual nature of the Communications Act:

Among the considerations that are important in the context of
broadband deployment is the role of the open Internet and policies
that may apply to modalities such as land-based or wired
telecommunications infrastructures. Broadband in this context elicits
important questions including how frameworks for specialized services
such as are enabled for wireless by standards such as IMT should
coexist with the varied offerings of competing providers who rely on
the open Internet and policy frameworks affording competitive access
to shared physical public right-of-way facilities. These providers
rely on general purpose communications protocols to support a flexible
platform for independent innovation that enables them to compete even
as it assures interoperability and global connectivity for their own
services and those of innovating end users.

One of the key questions raised in the United States Federal Communications Commission’s National Broadband Plan and Open Internet Orders was how the Open Internet should coexist with specialized services. As we proceed to an emphasis on broadband access and uptake, questions become important regarding how standards such as IMT, which offers incentives for wireless providers, should relate to open Internet as well as issues of competition, the enabling environment, infrastructure development and empowerment of end users and independent providers in the context of other modalities such as land-based or wired facilities over which policies affording competitive access to the physical layer may apply.

Seth