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FTTH Council Calls on FCC to Allow "Reasonable Network Management Practices"

WASHINGTON - Should the Federal Commission decide to adopt so-called "net neutrality" rules, it is essential that broadband Internet service providers be permitted to engage in reasonable network management practices so that they can maintain the highest level of service quality, according to a brief filed with the Commission by the Fiber-to-the-Home Council.

In today's filing, the Council, a non-profit organization of 200 companies and other organizations dedicated to expanding the deployment of all-fiber networks, suggested that any open Internet rules should include "well-defined reasonable management practices that are used today in the normal course of business and that will provide network managers with sufficient certainty so they can continue to manage their networks in the face of congestion, constantly evolving threats to the network, and legal requirements."

The Council submitted as an addendum to the filing a detailed primer on network management developed by network engineers, A Network Engineer's Primer on Broadband Internet Access Services and Reasonable Network Management Practices for Wireline Networks, which sets forth a series of proposals to define this term. The primer represents the combined recommendations of a number of experienced network managers from a variety of types of service provider organizations.

Download a copy of the filing and the addendum here.

Praising the FCC for its existing open Internet principles, the Council noted that they have helped prevent "systematic and significant anti-competitive acts that might harm users and content and applications providers."

However, the Council added that "despite a few isolated events that have been promptly caught and addressed, there is still no proof of widespread anti-competitive practices to justify codification of the principles or extension of them by inclusion of rules regarding non-discrimination and transparency."

Nevertheless, if the Commission proceeds with codification of its net neutrality principles, it should ensure that allowable network management practices are well defined and that network operators are given ample guidance on how to comply with any new regulations.

"Because each of the rules is subject to reasonable network management practices - and because network management is so critical to the proper functioning of modern communications networks -- it important to define this term precisely," the Council wrote. "Without adequate precision, the rules would likely engender uncertainty and have a chilling effect on legitimate management activities. Network managers would then be unable perform their jobs adequately and ensure all users have a satisfactory experience."

The Council also noted that one of the network engineers who worked on the primer commented: "It would be a nightmare for users if I had to check with my lawyers every time I needed to make a decision. The network would shut down."

In the comments, the Council proposed a series of rules developed by network engineers that would provide this necessary certainty. These include applying any new network roles solely to the provision of Internet service and not to the offering, operation, or management of any other services, including managed or specialized services, and allowing Internet service providers to offer differently-priced tiers of service based on bandwidth and consumption.

In addition, the Council urged that Internet providers, when meeting certain conditions, be allowed to offer quality of service guarantees, throttle and shape Internet access traffic pursuant to reasonable limitations, permit CDNs or others to install and have traffic directed towards local caching equipment, and restrict spam, malware, and similar traffic harmful to the network, as well as provide priorities for emergency traffic and secure transmissions.

The Council pointed to the increasingly complex and constantly shifting tasks that network managers undertake with a growing array of sophisticated tools - all with the objective of providing users with a satisfactory experience.

"A 'day in the life' of network managers is filled with constant challenges as they handle traffic surges, an evolving set of applications, spam and malware, and emergency messages along with demands from a diverse array of customers with much different requirements," the Council wrote. "In many instances, they need to make snap decisions to prevent networks from crashing. Therefore, should the government wish to intervene in their activities, 'bright-line' rules are essential to enable them to perform critical tasks in the time required."

About the Fiber-to-the-Home Council

Now in its ninth year, the Fiber-to-the-Home (FTTH) Council is a non-profit association consisting of companies and organizations that deliver video, Internet and/or voice services over high-bandwidth, next-generation, direct fiber optic connections - as well as those involved in planning and building FTTH networks. The Council works to create a cohesive group to share knowledge and build industry consensus on key issues surrounding fiber to the home. Its mission is to educate the public and government officials about FTTH solutions and to promote and accelerate deployment of fiber to the home and the resulting quality of life enhancements such networks make possible. More information about the Council can be found at www.ftthcouncil.org.

Media Contact:

David St. John
Media Relations
FTTH Council
315.849.3800
media@ftthcouncil.org