Dean Bubley's Disruptive Wireless: My comments on BEREC's Net Neutrality guidelines consultation: "General comments:
There needs to be consideration of meshed, relayed or shared connections which run directly between users’ devices. In device-to-device scenarios, does the owner/operator of an intermediate device become responsible for the neutrality of the “onward” link to 3rd parties? (which could be via any technology such as WiFi, Bluetooth, wired USB port etc)
There needs to be consideration that some of the more invasive mechanisms for traffic discrimination and control will in future move from “the network” to becoming virtualised software (provided by an ISP) that reside in edge-nodes at the customer premise, or even in customers’ mobile devices. It is unclear how the implementation guidelines deal with predictable near/mid-term trends in NFV/SDN technology, especially where there is no clear “demarcation point” in ownership between ISP and end-user.
Equally, in future there may well be CAP companies that offer their services “in the network” itself, also with NFV/SDN. There needs to be careful thought given to how this intersects with Net Neutrality guidelines
The evolution of artificial intelligence & machine-learning means that workarounds or infringements may become automated, and perhaps even invisible to ISPs, in future. This may also impact the nature of QoS as used for different applications. See http://disruptivewireless.blogspot.co.uk/2016/04/telcofuturism-will-ai-machine-learning.html for more details
Where wholesale relationships occur – eg MNO/MVNO, “neutral host” networks using unlicenced-band LTE, or secondary ID on the same WiFi hotspot – and the traffic-management / IAS functions are co-managed, how do the guidelines apply? Which party/parties is responsible?"
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