Transcript Document

Critique of Layered Regulatory
Model
David Reed
EVP and Chief Strategy Officer,
CableLabs
Silicon Flatirons Conference
February13, 2005
Key Points
• Proposed public policy framework regulating
along horizontal network “layers” misses the mark
– Loss of Technical Neutrality in Regulation
– Layering (aka Unbundling) Will Degenerate Into
Simple Price Regulation
– Regulators Will Control Network Evolution and Path of
Innovation
• Best alternative pursues on-going promotion of the
development of facilities-based competition
among broadband service providers
Methodology
• Assume 4-layer model that has been roughly
proposed by many sources
– Layers: Physical Network, Logical Network,
Application, and Content
– No critique of a specific proposal, instead focus on
concerns raised by the general idea
• Lack of proposal consensus is a red flag on complexity
• Interdisciplinary critique on technical, economic,
and public policy grounds
• Key view: what is good for the engineer may not
be for the regulator (e.g., Video Dialtone)
Technical Concerns
• Examined the software stacks of some cable
platforms to gauge how well they might
map to a 4-layer regulatory model
– DOCSIS
– PacketCable
– CableHome
DHCP Client
TFTP Client
SNMP
V3
Security
Mgmt
TCP/UDP
Software Stacks
Are Complex
IP (private addr), ARP
DIX/802 .2 LLC
DIX/802.3 MAC
DIX/802 .3 MAC bridge and filters
BPI+
Ethernet Mgmt &
Framing
DOCSIS MAC
(DQOS)
Ethernet Protocol
MPEG
(d/s only )
Ethernet
PHY
DOCSIS PHY
DOCSIS Software Stack
DOCSIS Stack
DHCP
Client
TFTP
Client
SNMP
V3
Security
Mgmt
Content
Layer
Application
Layer
TCP/UDP
Logical Network
Layer
IP (private addr), ARP
DIX/802.2 LLC
DIX/802.3 MAC
DIX/802.3 MAC bridge and filters
BPI+
Ethernet Mgmt
& Framing
DOCSIS MAC
(DQOS)
Ethernet
Protocol
MPEG
(d/s only)
Ethernet
PHY
DOCSIS PHY
Physical Network
Layer
Technical Concerns Beyond
Complexity
• Existing platforms not isolated to single layers
– Real world: cross-layer interdependencies common
• Network design challenges
– Network evolution requires cross-layer coordination
• Regulatory control of innovation
– Regulators have key decision-making role in innovation
– Whither an application like Bandwidth Management?
Economic Concerns
• Layered approach really is just another framework for
unbundling – which is all about pricing and network access
– Highly-invasive regulatory model in light of alternatives
• Unbundling precludes realizing economies of scale and
scope across the unbundled interfaces
– Embedded interfaces provide example of potential lost economies
• Complexity of model fueled by disparate economic
interests
– Let the regulatory games begin…
– …along with the protocol wars!
Public Policy Concerns
• Loss of technology neutrality in regulation
• Layered (aka Unbundling) will degenerate
into price regulation
– Old-style way of regulating in new age
• Regulators will control network evolution
Better Alternative: Patient, FacilitiesBased Competition Policy