[liberationtech] Urgent M-LAB issue at FCC

[Yosem Companys]

From: Vint Cerf <vint at google.com>
Date: Sun, Jul 15, 2012 at 1:04 AM
Subject: Urgent M-LAB issue at FCC
Cc: Meredith Whittaker <meredithrachel at google.com>

I’m writing with an urgent request for your support on an issue that’s
crucial to proper scientific treatment of open broadband Internet
access measurement.

For over two years the FCC has been using M-Lab as the foundation of
their broadband measurement program. This was great for policy, and
great for accountability, because it meant that the official
statistics reported in their publications were made openly available,
and that researchers could access the open data and reproduce and
expand on the published results.

Recently, the FCC measurement program has backed sharply away from
their commitment to transparency, apparently at the bidding of the
telcos in the program. The program is now proposing to replace the
M-Lab platform with only ISP-managed servers. This effectively
replaces transparency with a closed platform in which the ISPs --
whose performance this program purports to measure -- are in control
of the measurements. This closed platform would provide the official
US statistics on broadband performance. I view this as scientifically
unacceptable.

For the health of the Internet, and for the future of credible
data-based policy, the research community must push back against this
move.

To do this, I am attaching a copy of a joint letter to the FCC. This
letter explains why openness is crucial for good science, and rejects
the FCC’s move toward closed measurement. I will be signing, and I
request your signature.

Our deadline for filing this letter is tight. We would like to file
before July 19th. Given the nature of the politics here we weren’t
able to predict the necessity until recently.

I have CCed Meredith Whittaker, who’s managing this effort. She can
answer any questions, and will be happy to have a quick call to
discuss details. All of the claims made above are thoroughly
documented, so please feel free to ask any and all questions.

If you will confirm your willingness to sign to Meredith, she can
compose the letter with your endorsements and send to the FCC by the
19th.

Thank you in advance.

vint cerf

TEXT OF PROPOSED LETTER TO THE FCC

Open data and an independent, transparent measurement framework must
be the cornerstones of any scientifically credible broadband Internet
access measurement program.

Measuring network performance is complex. Even among those of us who
focus on this topic as our life’s work, there are disagreements. The
scientific process happens best in the sunlight and that can only
happen when as many eyes as possible are able to look at a shared set
of data, work to replicate results, and assess its meaning and impact.
This ensures the conclusions from the broadband measurement allow for
meaningful, data-driven policy making.

Since the inception of the broadband measurement program, those of us
who work on Internet research have lauded its precedent-setting
commitment to open-data and transparency. Many of us have engaged with
this program, advising on network transparency and measurement
methodology and using the openly-released raw data as a part of our
research.

However, we understand that some participants in the program have
proposed significant changes that would transform an open measurement
process into a closed one. Specifically, that the Federal
Communications Commission (FCC) is considering a proposal to replace
the Measurement Lab server infrastructure with closed infrastructure,
run by the participating Internet service providers (ISPs) whose own
speeds are being measured.

In order for the scientific process to work, measurement data must be
openly available as well as access to methodologies, and explicit
cataloging of assumptions is essential if results are to be confirmed
and replicated. A switch from an open to a closed infrastructure makes
this process impossible or, at best, questionable.

We strongly oppose any decision by the FCC to run a closed measurement
program. We urge the managers of the program to reconsider any steps
to run measurement tests over closed infrastructure. If expansion of
the current infrastructure is needed, those wishing to provision
measurement servers should be encouraged to contribute resources to
the Measurement Lab Consortium. Measurement Lab is a research network,
and operates its servers in a consistent, openly documented manner.
This ensures comparable, credible data, and enables the research
community to put our faith in the measurement results, and to stake
our professional reputations on conclusions based on the data.

Sincerely,

The undersigned.
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