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Comcast's FCC Filing Today
From: David Farber <dave () farber net>
Date: Sat, 20 Sep 2008 05:15:26 -0400

Begin forwarded message:

From: "Livingood, Jason" <Jason_Livingood () cable comcast com>
Date: September 19, 2008 10:39:26 PM EDT
To: "Ted Koppel" <tkoppel () comcast net>, <nnsquad () nnsquad org>
Subject: [ NNSquad ] Re: Comcast's FCC Filing Today

Hi Ted -

My replies are inline below.


-----Original Message-----
From: Ted Koppel [mailto:tkoppel () comcast net]
Sent: Fri 9/19/2008 10:03 PM
To: Livingood, Jason; nnsquad () nnsquad org
Subject: Re: [ NNSquad ]  Comcast's FCC Filing Today


I'm a residential high speed customer with Comcast, as well as a
long-term NNSquad reader.  Earlier this week I received the official
e-mail from Comcast notifying me of the 250gb limits and assuring me
that only a small percentage of customers would be affected.  Wonderful.

As a customer, a reasonably heavy user of bandwidth for VOIP and file
transfer (for work, not P2P or entertainment) and a reasonably savvy
person on these issues, I see two big omissions in the announcement and
the policy.  I would appreciate it if you could address them publicly.

1) How will Comcast make it possible for me to know what my usage is on
an ongoing basis during the month, so that (if necesssary) I can adjust
my usage to remain under the limit each month.  Telling me afterwards
(on my bill) is too late.   How will Comcast provide me
close-to-real-time usage numbers?  (If Comcast can't or won't, then we
have a classic fox-watching-the-henhouse situation.   How do I know
whether to believe the bill?)

[JL] Today, usage statistics are gathered in one particular technical method. As we transition to the new congestion management technique, we are deploying some "statistics collection" servers which gather the stats using a different method. Technically those are IP Detail Record (IPDR) collectors. As we deploy those servers into the network, the system used to calculate monthly usage will start to draw stats from these new servers. One result, other than providing stats for the congestion management system, is that this will make possible a nifty little web-based usage meter that can then be displayed to a customer. The idea would be that you can check it at any time and it'd be reasonably up to date (though not necessarily up to the minute). As I am sure you might imagine, this could also enable you to receive notices as you approach a specific limit.

2) If I do exceed the 250gb limit, what are the consequences?  Is my
connection disabled?  Is my hand slapped?   When?  How fast is the
feedback when the limit is reached.

[JL] I'm in engineering, and not really in the 'policy enforcement' side of things for the 250GB limit - which is handled by Customer Security Assurance. My understanding is that that group would call you on the phone to discuss it. Often, this is due to some kind of a technical problem, like a user have an open WiFi access point that someone is hopping onto, or a computer on the network that has been compromised or has some technical fault. Anyway, they go over what may have caused it to help determine if it was intended traffic or some other problem, and that's that. If there is some sort of security or technical problem, they help customers solve those things. If you are contacted again within 6 months, they I believe the policy is something like you could be subject to termination.

I don't quarrel with the need for limits, but as a customer and a
reasonaly fair person, I think they should be implemented with
transparency and honesty so that users can get a clear picture of use
and santions.

[JL] Yup - I agree.

Ted Koppel
tkoppel () comcast net

Livingood, Jason wrote:

A short time ago, we filed our response electronically with the FCC.
Those documents will be made available to the public shortly (I'm
guessing within 2 hours) on our Network Management website at

_http://www.comcast.net/networkmanagement/_. News outlets are starting
to report on the story now, including ArsTechnica here at
_http://arstechnica.com/news.ars/post/20080919-comcast-loses-p2p-religion-goes-agnostic-on-throttling.html_ .

I hope you will agree that we've shared a great deal of information
with the FCC in an effort to be fully transparent anasisd share lots
of technical details. As an engineering leader who has been playing a
key role in the trials of our new congestion management technique, and
the transition to our new technique, I'm happy to answer technical
questions the best I can. :-)  ((As a regular reader and occasional
poster to the NNSquad list, I'll be watching the list over the weekend
and into next week if anyone has technical questions that I can try to


Jason Livingood
National Engineering & Technical Operations

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