Level 3 Communications Issues Statement Concerning Comcast's Actions

Leo Bicknell bicknell at ufp.org
Mon Nov 29 22:03:27 CST 2010

In a message written on Mon, Nov 29, 2010 at 10:22:34PM -0500, Christopher Morrow wrote:
> see craig's report from nanog47:
> <http://www.nanog.org/meetings/nanog47/presentations/Monday/Labovitz_ObserveReport_N47_Mon.pdf>
> not for a time has Comcast been solely an 'eye-ball' network... or so
> they think.

I think you are misreading the data.

From googling around it appears there are somewhere between 90 and
100 million "broadband subscribers" in the united states.  Comcast
claims to have somewhere between 15 and 17 million broadband
subscribers, and they are the largest cable company in the US.

With around 18-20% of all broadband end-users in the US Comcast,
if you believe Arbor's numbers, generate 3.12% of all Internet
traffic.  Comcast also sells business service (not cable modem, but
like GigE to the prem) which is propping that up a bit.

If the FCC wanted to do something useful they would look at the
combined ratio of all /customers/ of an ISP, and then require their
peering policy to allow for around 2x of that.

For instance, if you summed all Comcast customers and did the ratio
of out:in and got 3:1, they should at a minimum be required to peer
with someone at 6:1 IMHO.

I have no idea in Comcast's case specifically, or in any recent
case as my skin isn't in the game right now.  However I am quite
sure in the past I have delt with networks who wanted 2:1 on peering,
but where I was nearly positive their customer base was 3:1 or 4:1.
Basically the ratio became an excuse to depeer anyone they didn't
like, it was all a sham.

While I think ratio requirements are just plain stupid, I do think
it needs to be considered when looking at peering.  If you do hot
potato routing the person on the "wrong end" of the ratio ends up
carrying the traffic longer distances.  If you look at long haul
bandwidth on a bit-mile basis this can be unfair in some circumstances.
The thing is though it's easy to fix.  Networks could use MEDs (yes,
they work on Internet scale routing), selective leaking (w/no-export),
peering with regional ASN's (many of the large eyeball networks are
subdivided internally) or any number of other very simple configurations
to balance this issue.

But I come back to my fundamental beef with cable and DSL providers,
when you're selling 50/5 (10:1 ratio), 25/5 (5:1 ratio), 12/2 (6:1
ratio) services, you can't expect to maintain a 2:1 or 3:1 ratio
with your peers.

If you look at the TV side of the business the eyeball network is the
whipping boy 99 times out of 100.  Look at the recent Fox v Cable Vision
dispute, Cable Vision caved.  Users want content, users pay Cable
Vision, Cable VIsion gets millions of angry calls, Fox runs a few ads
how Cable Vision is the big bad guy and they have deals with everyone
else.  Go back to previous cases, almost always the eyeballs cave.

Provides are trying to change this in IP space, because they don't like
it.  They want Netflix/Amazon/Apple/RIAA/MPAA to pay, and not be in
charge.  For the moment this works, if Netflix can't deliver via the
Internet their users just request DVD's in the mail; a peering spat
hurts Netflix more than Comcast.

But, as users cut the cord, and get more of their content over the
Internet I think we'll see the same shift.  Outside of Nanog Ma and Pa
Citizen don't even know what the word peering means.  All they know is
when they can't get their Netfix streaming to work they call their
provider and complain, possibly going as far as to switch services.

Now, while it may seem I'm taking Level 3's side of this dispute I am
not.  Sadly when these things spill out in public like this it is
generally because both sides have been acting like idiots with each
other in private for months or years.  Maybe Level 3's been a model
citizen in this case and has been wronged, but I doubt it.  The problem
is it all happened in private, and nice press releases from both parties
aside we really have no idea what happened behind closed doors, who
asked for what, who's egos got out of control, etc.  I'm not going to
call a winner or a loser, just point out how broken some of the
arguments put forth are.....

       Leo Bicknell - bicknell at ufp.org - CCIE 3440
        PGP keys at http://www.ufp.org/~bicknell/
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