[178546] in North American Network Operators' Group
Re: Verizon Policy Statement on Net Neutrality
daemon@ATHENA.MIT.EDU (Lamar Owen)
Sat Feb 28 12:26:12 2015
X-Original-To: nanog@nanog.org
Date: Sat, 28 Feb 2015 12:24:23 -0500
From: Lamar Owen <lowen@pari.edu>
To: nanog@nanog.org
In-Reply-To: <54F0E669.50007@satchell.net>
Errors-To: nanog-bounces@nanog.org
On 02/27/2015 04:49 PM, Stephen Satchell wrote:
> So did I. Also, do you recall that the FCC changed the definition of=20
> "broadband" to require 25 Mbps downstream? Does this mean that all=20
> these rules on "broadband" don't apply to people providing Internet=20
> access service on classic ADSL?
The FCC regulations do not have to use consistent definitions (and many=20
times definitions are not consistent!); the local-to-the-section=20
definition usually (but not always; it's always up for interpretation at=20
hearing time!) trumps any other. The local definitions for the context=20
of 47CFR=A78 are found in =A78.11, and do not mention required bandwidth.=
=20
It seems to include any 'eyeball' network, regardless of bandwidth. The=20
definition in 47CFR=A78.11(a) is classic FCC wordsmithing.
Think of 'scope of definition' as being similar to 'longest prefix=20
matching' in routing, and it will be clear what is going on here. Hint:=20
a particular section of the Rules can hijack a term out from under the=20
general definitions, much like prefixes can be hijacked out from under=20
their containing prefix. The difference is that in the Rules, a=20
particular paragraph or subparagraph can hijack a term and say 'for the=20
purposes of this paragraph, term 'A' means the opposite of what it means=20
everywhere else' and that definition in that scope will stand the test=20
of hearing.
