A Brief Response To Richard Bennett's New Paper

I salute Richard Bennett’s new paper Designed for Change, in which he traces the engineering history of the end-to-end principle. It is a serious paper and deserving of serious response. Unfortunately, it being right before Yom Kippur and various deadlines, that more serious response will need to come from elsewhere. I can give only a brief, surface response — reality is messy.

OK, too brief. A bit more elaboration. Richard Bennett is eminently qualified to write the technical history and draw engineering conclusions. As are a large number of other folks who take very different views on the issue of net neutrality and the virtues of end-to-end (Vint Cerf, David Reed and kc claffy to name a few folk of my acquaintance). The history described by Richard is layered onto an equally rich history of political and economic events which all interweave, and continue to interweave, to create a complex and messy reality in which public policy tries (in my opinion) to set rules to create the strongest likelihood of the best possible outcome.

More below . . . .

Bennett’s essential argument, if I grasp it correctly, is that certain difficulties most agree are substantial problems would be far easier to solve if we gave the network operators greater freedom to manipulate traffic. While possibly true in the abstract, I am much less convinced it will play out that way in reality. For one thing, when Comcast was forced to disclose its network management practices, it turned out that Comcast was not actually experiencing significant network congestion. Instead, it was proactively solving the fear of future network congestion by going after the top 1000 users every month and targeting what it considered the most significant applications that could cause congestion in the future. That had the virtue of cheap efficiency for Comcast, but it had significant costs to others.

Furthermore, the evolution of the the wireless network, and the domain name system (DNS) bear me out. In both cases, allowing the network operators unrestrained freedom to develop engineering solutions that suited the needs of the network operator has created a cost in terms of innovation and investment. In the case of wireless, despite a recent explosion of applications, the limits on what equipment can be attached to the network and on the applications one can run have resulted in a world less robust, interesting or useful than the wireline or unlicensed wireless world. To take a simple example, I have a choice of many laptops and an infinite number of applications I could run it them via my Verizon FIOS connection and my wifi router. I have no problem watching TV in my workroom using Slingbox while working on my HP G60-235DX Notebook PC. For my Verizon wireless connection, I have a far more limited set of choices.

The situation is worse for DNS, which has undergone very limited evolution in the last 15 or so years. We are still struggling with interntionalized domain names, DNSSEC, and have introduced only a handful of new gTLDs, despite demand from many would-be TLD administrators.

To all these one may add a “yes but,” explaining the differences in such systems or the advantages obtained from this stability. But it is stability that comes at a cost. I can think of no significant application that evolved in the licensed wireless universe in the last five years which did not first evolve in the wireline universe — whereas I can think of several in the unlicensed world (albeit these are more localized and less well known, wifi dog being the first that comes to mind). Venture Capitalists are giving up on licensed wireless, despite the continued growth in importance of mobile services, because the more controlled environment of mobile makes it much harder to develop the sort of disruptive innovation that pays huge dividends for VCs simply cannot occur under the existing licensed wireless rules.

Which brings me to my conclusion. It is as wrong to conclude that the network neutrality question is solely an engineering question, or an economic question, or a legal question. As I have argued before, the ability to tier traffic has serious implications for the cost of political speech, our civil liberties generally, the cost and structure of ecommerce, and the potential for virtual redlining. These are not questions to be answered solely by recourse to engineering anymore than they can be answered without a serious examination of the underlying engineering. We cannot guard against these possibilities without cost, nor can we ignore them without consequences.

In the end, the network neutrality debate is a debate on what our priorities will be for our digital future. We may elevate autonomy for network operators for any of a variety of reasons, ranging from a Libertarian belief that regulation is inherently wrong or harmful to a desire for engineering elegance and centralized control. We may restrict the network and empower developers at the edge of the network for an equally wide range of reasons. It is not a debate in which well reasoned arguments of opponents should be lightly cast aside — either because we consider the source suspect or the discipline of study less relevant. But for the same reason, it is not a debate in which a single argument or a single set of costs or a single set of benefits will automatically prevail. It will be a very messy argument in which we must balance a great many things to set the course for the world in which we wish to live. For this reason I respect the arguments Richard Bennett makes, even if I think the world under the rules he proposes would be a poorer world than the one that I hope will exist under the rules I would like to see.

Stay tuned . . . .

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  1. John says:


    I agree with you 100%.

    I must say that I was disappointed in the response from the Public Knowledge guy at the Brookings Institution forum when he was asked about the significance of Net Neutrality and he said it was about his daughter being able to get a Skype phone. That was a pathetically lame response.

    To me Net Neutrality is about free speech, democracy, or, as Professor Weiner said at the Harvard FCC hearing “everyone’s ability to communicate with everyone else”. Without Net Neutrality the corporations win, period, corporatocracy will be entrenched forever. I know that sounds hyperbolic, but that’s the damn truth.

    I know you said that you have other responsibilities and things to attend to after the Holy Day, but please, come back and resume this discussion. You’re one of the best voices we have for making the case against people like Bennett.

    Richard Bennett knows he is welcome here as a commenter; as you say, his arguments are made in good faith — unlike those of so many other (i.e. corporate) actors in this discussion. But a mere engineering analysis of a question that goes to the heart of what kind of society we want to have is necessarily going to be off the mark.

  2. Brett Glass says:

    Where to begin? Well, Harold, you could start, by spelling Richard’s last name correctly. (Hint: It’s “Bennett,” with two t’s.) Secondly, you could avoid misrepresenting or oversimplifying what he has to say. Among Richard’s key observations is the simple fact that engineers — not lawyers, bureaucrats, lobbyists or corporate “evangelists” (which Vint Cerf now is; he has long ceased to be a computer scientist or network engineer) — are the people best suited to making architectural decisions about networks. You have no business sticking your nose into how networks are designed or operated, and insufficient knowledge even to understand the details much less dictate rules.

    Your remarks about wireless and DNS both bear this out. You simply have no knowledge of the technology or its challenges. What you do have is money — from Google — to lobby to restrict engineers in a way that Google believes will give it a business advantage.

    Your remarks about supposed “threats” to political speech are likewise those of a lobbyist trying to conjure an imaginary
    bogeyman rather than those of someone who actually understands the workings of the Net.

    In short, you are simply not qualified to judge Richard’s ideas, or to make any claims about how they would influence the Internet or the world at large.

    But of course, in DC that doesn’t matter. It’s who has the big lobbying bucks from Google, right?

  3. John says:


    Change your tone or be banned from my site. If you’re going to accuse Harold of being a shill for Google or anybody else, either substantiate your claims or fuck off.

    Simply civility will allow you to continue to have posting privileges here.

    Harold has not asked me to say this; I’m saying this on my own as the owner or the Wetmachine domain.

    If you don’t like my policy, get your own site and build a readership such as Harold has done. That’s how the magical free market of ideas works, after all.


  4. John says:

    P.S. I’ve corrected the spelling of Mr. Bennett’s name.

  5. @Brett:

    “…engineers — not lawyers, bureaucrats, lobbyists or corporate ‘evangelists’… — are the people best suited to making architectural decisions about networks.”

    Correct. Lawyers, bureaucrats, lobbyists evangelists and activists are the ones who define the problem, and the requirements for a solution. An engineer will either listen and architect a successful technology solution or he won’t, but to try to pretend that the client (i.e. the world) doesn’t exist outside your mom’s basement has been the stuff of geek jokes since the first caveman started experimenting with rolling things.

    I think that’s what Harold’s getting at above. An engineering solution will certainly be part of the solution, but defining requirements based on a strategic direction for the internet? This is likely to involve actors other than an engineer.

    Full disclosure before someone calls me a shill: I just launched a startup to build websites for nonprofits, so no one pays me for anything at the moment 😛

  6. Brett Glass says:

    John: I’ll say this very simply and in civil language: It is well known that Harold’s employer — the lobbying group Public Knowledge — accepts both money and in-kind contributions of labor from Google. Don’t take my word for it; the group admits to this fact on its own Web site.

    David: Engineers do not merely exist to do menial work for the lawyers and politicians of the world. We create; in fact, we created the Internet. The lawyers and politicians showed up later, only after we made it something of value, to try to bend it to the will of their patrons.

  7. John says:


    Public Knowledge accepts money from lots of corporations and foundations and individuals, many of whom are competitors. It’s good to be aware of that, but that doesn’t mean that PK itself or Harold in particular is a “shill”, a word that to me implies somebody who does work-for-hire to dishonestly promote something he doesn’t believe in. You know the connotations of the word, certainly, despite being an engineer.

    To say that engineers should control the evolution of the internet without regard to the wishes of non-engineers is like saying that only civil engineers are capable of deciding where to put interstate highways, or that gun manufacturers are the only ones capable of making policy on firearms, etc. It’s just silly.

    As for “you” engineers who “created” the internet, did you do it without government funding? Hmmm . . . And somehow I don’t recall having seen your name among the long list of people who “created” the internet. Did you do that from Wyoming? OF course, everybody who runs an ISP, etc, does contribute to the development of the net. So I’ll give you a point on that. But if I understand your resume, while you were a grad student doing a grad student project, I was a senior software engineering manager at Sun Microsystems and chair of Sun’s Software Development Architecture Team. So do I get to join your engineers’s club and am I entitled to voice an opinion on these topics? Or did I lose that right when I changed profession?

  8. Harold says:


    Don’t feed the troll. There is a division of opinion among us in DC whether Brett is just a psychotic with bizarre fixations or whether he is being subsidized to spend this much time harassing us and other NN supporters. Despite the fact that he spends more time doing this than is compatible with actually running an ISP, my personal bet is that he is a genuine, sincere, highly motivated nutbar who survives by being the monopoly provider in his neighborhood.

    For example, he will feel compelled to reply to his post with some large mound of personal invective and a critique that simply does not make sense and concludes with a “that shows what a hypocrite you really are!” (another sign that Brett is genuinely deranged and not a shill, his responses follow the same general pattern of believing that those who disagree with him over time are obviously liars because if they are in possession of the facts and don’t agree with him they must be liars). It kinda takes me back to my Usenet days.

  9. John says:


    OK, I will follow your advice and not feed the troll. That’s my general policy.

    However, I don’t generally like banning people, and as you say, Bennett’s paper should be taken seriously. I would like to have this site be a place where people can debate Net Neutrality & similar things. So I was trying to strike a balance. But you correctly state that one can not strike a balance with a troll. Point taken.

  10. Brett Glass says:

    John writes:

    <i>As for “you” engineers who “created” the internet, did you do it without government funding? Hmmm . . . </i>

    Are you asserting that anything that was in any way aided by government funding should be subject to onerous regulation? Maybe anything that, say, was done by anyone who drove to work on a government-built highway? (Gee; that pretty much would give you unlimited license to regulate <i>anything</i<, wouldn’t it.)

    <i>And somehow I don’t recall having seen your name among the long list of people who “created” the internet.</i>

    Many of us worked on it behind the scenes, and deserve due credit even if we didn’t have the time or money to fly to ITIF meetings. I debugged hosts and networks at Stanford, where I worked as a graduate student during the transition to TCP/IP (which really was the birth of the Internet). I then worked on radio technology which was later incorporated into what is now known as “Wi-Fi.”

    <i>Did you do that from Wyoming?</i>

    I founded the world’s first wireless ISP (WISP) in Wyoming in 1992. So, yes, you might say that I did at least some of that from Wyoming.

    <i>OF course, everybody who runs an ISP, etc, does contribute to the development of the net. So I’ll give you a point on that.</i>

    I am building out the Internet every day — seven days a week. (I haven’t taken a vacation in several years, and the only time I have been away from my business is when I have been on business trips — many of them to speak to regulators to ensure that the innovation-killing regulation that Harold is advocating is not put into place.) I’ve put thousands of people on the Internet — many of whom would have no high speed terrestrial connection had I not made one for them with my own hands. And it’s likewise my duty to ensure that the network I’ve built is sustainable and reliable and is able to continue to serve my community; hence my tireless advocacy online and off. The lobbyists have big money to spend; I, not being funded by anyone, have only what little time I have left to give after a typical 12-hour workday. But I must give it, for the sake of my users and the customers of other small, independent and rural ISPs like me.

    <i>But if I understand your resume, while you were a grad student doing a grad student project, I was a senior software engineering manager at Sun Microsystems and chair of Sun’s Software Development Architecture Team. </i>

    Again, you don’t know my background. Before returning to school at Stanford, I was on the development team for the TMS380 802.5 Token Ring chipset — the first VLSI Token Ring implementation. The standard itself was developed concurrently with the chip. So, I wasn’t just hacking UNIX (I did that a bit as an undergrad). I was intimately involved in the architecture of networks.

    <i>So do I get to join your engineers’s club and am I entitled to voice an opinion on these topics? Or did I lose that right when I changed profession? </i>

    Anyone is entitled to voice an opinion. However, the lawyers and lobbyists’ output should be taken with the understanding that in those two professions one is paid to represent the interests of the client. It is a simple fact that a substantial portion of every paycheck that Mr. Feld receives comes from Google. It’s simply good sense to bear that in mind when evaluating his writings. Including his ad hominem attack on me immediately above (which includes exactly the sort of unsubstantiated claims which you say are unacceptable on your site).

  11. Thanks for the write-up Harold, you seem to grasp the points I tried to make in the paper extremely well. I’m trying to add some technical depth to the net neutrality discussion, not necessarily answer all the questions. And I do say in the paper that the NN debate encompasses a number of issues about equities and ownership that are far outside the skill set of engineers. I’m urging caution wrt being too eager to offer regulatory prescriptions that aggravate the emerging technical issues. While the Internet is 35 years old, we’re facing some issues today that have never been faced before, so in some respects it might as well be only a few months old. There are increasingly diverse uses of the Internet today in terms of applications, and an increasingly diverse user population than ever before. So some regulatory frameworks that seemed sensible in the past may not have great utility in the future, and could have the effect of limiting utility of the Internet as an engine of free speech and political organizing.

    We already have a situation on our hands where effective video distribution requires the use of a CDN like Akamai or YouTube, and even YouTube doesn’t deliver consistently good streaming quality. There are underlying technical issues that cause this to be case, and we can’t resolve them merely by clamping down on the ISPs. Developing sensible two-way communication between national telecom regulators such as the FCC and its counterparts and the IETF may help move the ball down the road. Adding services to the network core in a principled and sound way should actually increase the value of the Internet for users as well as operators.

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