Comcast fesses to FCC: yeah we have right to, and we do, mess with some P2P packets

In a filing with the FCC yesterday, Comcast admits it messes with certain "P2P protocols."

Plain English: When Comcast subscribers are exchanging large files- Comcast sees these as poential factors in slowing down its network, and reserves the right to employ digital chicanery to interrrupt these sessions. Even if these sessions are being participated in by paying Comcast subscribers.

Readers, I'd like you to peruse through highlights from this filing, and then submit a Comment as to whether or not you think these practices Comcast admits to here should be condoned.

Here then, are Quotes from the Comments of Comcast Corporation in the Matter of Broadband Industry Practices – FCC WC Docket No. 07-52

“The carefully limited measures that Comcast takes to manage traffic on its broadband network -- including its very limited management of certain P2P protocols -- are a reasonable part of Comcast’s strategy to ensure a high-quality, reliable Internet experience for all Comcast High-Speed Internet customers. Importantly, in managing its network, Comcast does not block any content, application, or service; discriminate among providers; or otherwise violate any aspect of the principles set forth in the Internet Policy Statement.” Pg 2.

“Comcast recognizes the importance of providing its customers with appropriate disclosures about the services they purchase. Accordingly, Comcast’s customer service agreements and policies have always informed Comcast customers that broadband capacity is not unlimited, and that the network is managed for the benefit of all customers.” Pg 4.

“Network management is best left to the sound, good-faith judgment of the engineers and proprietors who run and own the networks and who are best able to remedy customer service issues promptly, rather than to regulation.” Pg 5.

“[A] very small number of broadband users employ certain P2P protocols that utilize immense amounts of bandwidth in ways that are unpredictable and inconsistent and that can threaten to overwhelm network capacity and harm the online experience of other users. That is why, even with continuous upgrades and constant investment, the fact remains that network capacity is not -- and never will be -- unlimited.” Pg 14.

“They [P2P protocols] are not designed to make reasonable use of a resource shared among millions of users. As the inventor of BitTorrent (the most popular P2P protocol currently being used) was recently quoted explaining, “My whole idea was, ‘Let’s use up a lot of bandwidth.’ . . . I had a friend who said, ‘Well, ISPs won’t like that.’ And I said, ‘Why should I care?’” Pg 15.

“Without network management, the success of new applications and services that are sensitive to interference caused by network congestion-- such as Joost, iChat, and Veoh -- is likely to be impaired.” Pg 17.

“Simply stated, there is nothing “neutral” about a network that is not managed. An unmanaged network simply means that users who make disproportionately resource-intensive demands on the network can crowd out fellow users. . . .Even Vuze concedes that ‘network operators certainly should have the ability to engage in reasonable network management.’” Pg 18.

"Significantly, service providers in other countries similarly manage their networks.” Pg 22.

“If Comcast did not engage in such responsible and limited management in those limited geographic areas and at those limited times when it is required, the user experience for all customers, including the users of the managed protocols, would deteriorate to unacceptable levels.” Pg 24.

"Independent research has shown that as few as 15 simultaneous BitTorrent sessions . . . in a geographic area served by a single node . . . can severely slow down the time it takes for all users in that area to surf the Web and can degrade the quality and reliability of VoIP calls below the threshold of what is considered to be on par with traditional phone service.” Pg 26.

“This action is nothing more than the system saying that it cannot, at that moment, process additional high-resource demands without becoming overwhelmed, just as a traffic ramp control light regulates the entry of additional vehicles onto a freeway during rush hour. One would not claim that the car is ‘blocked’ or ‘prevented’ from entering the freeway; rather, it is briefly delayed, then permitted onto the freeway in its turn while all other traffic is kept moving as expeditiously as possible.” Pg 29.

“For example, many of the network management practices that Comcast uses are undertaken specifically to combat malicious uses such as network hacking, viruses, Trojan horses, and spam. Making public every aspect of Comcast’s network management practices would not be helpful to the overwhelming majority of Comcast’s subscribers -- or application or service developers -- but would certainly facilitate exactly the kinds of practices that Comcast is trying to defend against.” Pg 41-42.

Readers, what do you think?