By Sara Jerome - 09/14/10 11:43 AM EDT
The commission could revise the FCC's Form 477 review to collect more information, Google said in its filing. Such an effort would take the FCC's open data initiatives "to the next level," according to Derek Slater, a senior policy analyst at Google.
Google said the Form 477 review, already on the books, should be revised so that wireline providers have to report to the FCC on their network management practices. That includes cases when the practices affect the performance of content and applications or when they reduce the speed or quality of a connection below its advertised rate.
"Relevant network management practices include traffic prioritization, traffic blocking or throttling, processes to address traffic congestion such as usage download or upload restrictions, content/message examination processes (e.g., deep packet inspection), and traffic routing processes that are based on sender/receiver, or type of traffic," the filing said.
The company wants the information to be available to developers and content providers "as such practices impact their ability to design and invest in their offerings."
"For example," Google writes, "consider a practice that prioritizes traffic from a particular application. A broadband provider should disclose what application is being prioritized and how that will impact performance (e.g., this application will have a guaranteed low latency, even at times of congestion)."
Public advocates said more network management information is needed, but that the Form 477 process has problems of its own, including that the data is not as reliable or granular as they would like.
"The FCC absolutely needs to collect network management information, but it already has a backlog of Form 477 reforms on its plate that must be addressed," said Derek Turner, research director at advocacy group Free Press.
It has been two years since the FCC promised to use Form 477 to collect basic information about where broadband is deployed, according to Turner.
"While we support the FCC seeking public comment on Google's idea, it is far past time for the Commission to take action on basic Form 477 reform," he said.
Google also wants the FCC to collect more data from broadband providers on issues including broadband availability, adoption and competition, on actual (rather than advertised) levels of consumer service, and about network management practices. The company also recommended that broadband providers submit a semiannual report on broadband deployment and uptake.
Anne Veigle, a spokeswoman for the broadband association U.S. Telecom, said the FCC should focus on ensuring that consumers have the information they need to effectively and safely use broadband services.
"For example," she said, "our companies are working closely with FCC technical staff and an FCC-selected vendor to help develop a sound approach to broadband performance testing."
She said it is generally recognized that "how well traffic flows over the Internet" is a shared responsibility between "networks, content providers and developers."
Google received a wave of criticism last month for a net-neutrality proposal that ardent "open Internet" supporters saw as too weak. The proposal emphasized transparency on both wireline and wireless networks, but failed to push further than that for wireless providers.