Comcast's Congestion Catch-22

One source indicated Comcast may even be considering going that direction in the long term, but because it needed to speed its new solution into production to meet FCC deadlines – and perhaps also to keep costs down – it went for a simpler solution not built around real-time packet inspection. Indeed, providing QoS-as-a-service to third-party providers is definitely part of the justification for moving to next-generation telco IP Multimedia Subsystem and cable PacketCable/DOCSIS systems in the first place. But then we are back to the net neutrality issue of not treating every packet equally.

The shocking thing is just how big a Pandora’s box the FCC has appeared to open – and it just keeps getting bigger. When the FCC first started addressing bandwidth usage and DPI issues, it quickly found itself up to its knees in network management minutia. Not long after that, it followed another logical path of the DPI question and asked service providers and Web companies about their use of DPI for behavioral targeting. Now it seemingly has opened up huge questions about what it means to be a voice carrier in the age of IP. It’s not hard to imagine the next step: What about video? Telco IPTV services are delivered in roughly the same way as carrier VoIP services – via packets running on the same physical network but a prioritized logical signaling stream. Is that fair to over-the-top video service providers?

Said one source: “These topics may sound small and bordered, but once you open a dialogue up about them, a host of issues suddenly appear.”

In the end, the technical issues may fall aside, and regulatory and political deal-making will likely determine the ultimate next steps.

“If cable MSOs can’t provide VoIP and get $40 per month for doing it, then what they’ll say is that the business case for deploying broadband falls apart. The same thing for telcos and IP-based video services,” one source said. “I’m really surprised this even came up. This was always part of the devil’s bargain: We’ll build out broadband if we can include these kinds of services in our network to build out our business case. The government and the FCC always agreed, ok, that’s a good deal.”

Perhaps in a best-case scenario, the FCC’s latest letter to Comcast may result in further tweaking of congestion management systems to something that truly makes sense – both technically and politically.

“I think there’s no question all operators—telcos and cable MSOs—are moving to some type of usage control or tiered service offering based on monthly usage,” said Infonetics Research analyst Jeff Heynen. “Although operators have many tools at their disposal to increase bandwidth to each subscriber, I think they all feel it’s the best time to culturally get people used to the fact that they have to manage how much bandwidth they use per month. DPI platforms alone can’t handle this task, which is where policy servers come in. If Comcast and other operators can tie in these bandwidth and resource usage controls to subscriber profiles, which are part of a contract you sign with the operator, then they won’t continue to run afoul of the FCC. I think subscribers and the FCC just want a bit more transparency from the network operators.”