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TAP Letter to NSF

CPSR News Volume 12, Number 3: Summer 1994

Dear Steve:

It is our understanding that the National Science Foundation (NSF) and other federal agencies are developing a new architecture for the Internet that will utilize four new Network Access Points (NAPs), which have been described as the new "cloverleaves" for the Internet. You have indicated that NSF is awarding contracts for four NAPs, which will be operated by telephone companies (Pac Bell, S.F.; Ameritech, Chicago; Sprint, NY; and MFS, Washington, DC). We further understand that NSF has selected MCI to operate its new very high speed backbone (vBNS) facility.

There is broad public interest in the outcome of the negotiations between NSF and the companies that will operate the NAPs and vBNS. We are writing to ask that NSF consider the following objectives in its negotiations with these five firms:

PRICING

We are concerned about the future pricing systems for Internet access and usage. Many users pay fixed rates for Internet connections, often based upon the bandwidth of the connection, and do not pay for network usage, such as the transfer of data using email, ftp, Gopher or Mosaic. It has been widely reported on certain Internet discussion groups, such as com-priv, that the operators of the NAPs are contemplating a system of usage based pricing.

We are very concerned about any movement toward usage based pricing on the Internet, and we are particularly concerned about the future of the Internet Listserves, which allow broad democratic discourse on a wide range of issues. We believe that the continued existence and enhancement of the Internet discussion groups and distribution lists is so important that any pricing scheme for the NAPs that would endanger or restrict their use should be rejected by the NSF.

It is important for NSF to recognize that the Internet is more than a network for scientific researchers or commercial transactions. It represents the most important new effort to expand democracy into a wide range of human endeavors. The open communication and the free flow of information have made government and private organizations more accountable, and allowed citizens to organize and debate the widest range of matters. Federal policy should be directed at expanding public access to the Internet, and it should reject efforts to introduce pricing schemes for Internet usage that would mimic commercial telephone networks or expensive private network services such as MCI mail. Announce or Com-Priv. It is not unusual for a popular Internet discussion group to have several thousand members, and send out more than 100,000 email messages per day. These discussion groups and distribution lists are the backbones of democratic discourse on the Internet, and it is doubtful that they would survive if metered pricing of electronic mail is introduced on the Internet.

Usage based pricing would also introduce a wide range of problems regarding the use of ftp, gopher and mosaic servers, since it conceivable that the persons who provide "free" information on servers would be asked to pay the costs of "sending" data to persons who request data. This would vastly increase the costs of operating a server site, and would likely eliminate many sources of data now "published" for free.

We are also concerned about the types of accounting mechanisms which may be developed or deployed to facilitate usage based pricing schemes., which raise a number of concerns about personal privacy. Few Internet users are anxious to see a new system of "surveillance" that will allow the government or private data vendors to monitor and track individual usage of Information obtained from Internet listserves or fileserves.

ANIT-COMPETITTVE PRACTICES

We are also concerned about the potential for anti-competitive behavior by the firms that operate the NAPs. Since 1991 there have been a number of criticisms of ANS pricing practices, and concerns about issues such as price discrimination or preferential treatment are likely to become more important as the firms operating the NAPs become competitors of firms that must connect to the NAPs. We are particularly concerned about the announcements by PAC-Bell and Ameritech that they will enter the retail market for Internet services, since both firms were selected by NSF to operate NAPs. It is essential that the contracts signed by NSF include the strongest possible measures to insure that the operators of the NAPs do not unfairly discriminate against unaffiliated companies.

RECOMMENDATIONS:

As the Internet moves from the realm of the research community to a more vital part of the nation's information infrastructure, the NSF must ensure that its decisions reflect the needs and values of a much larger community.

1. The NSF contracts with the NAPs operators will include clauses that determine how the NAP services will be priced. It is Important that NSF disclose and receive comment on all pricing proposals before they become final. NSF should create an online discussion list to facilitate public dialog on the pricing proposals, and NSF should identify its criteria for selecting a particular pricing mechanism, addressing the issue of how the pricing system will impact the Internet's role in facilitating democratic debate.
2. NSF should create a consumer advisory board which would include a broad cross section of consumer interests, including independent network service providers (NSPs), publishers of Internet discussion groups and distribution lists, academic networks, librarians, citizen groups and individual users. This advisory board should review a number of policy questions related to the operation of the Internet, including questions such as the NAP pricing, NAP operator disclosure of financial, technical and operational data, systems of Internet accounting which are being tested on the vBNS, and other topics.
3. NSF should solicit public comment, though an online discussion group, of the types of safeguards against anticompetitive behavior by the NAPs which should be addressed in the NSF/NAPs contracts, and on issues such as NAPs pricing and Internet accounting systems.

TAP-INFO is an Internet Distribution List provided by the Taxpayer Assets Project (TAP). TAP was founded by Ralph Nader to monitor the management of government property, including information systems and data, government funded R&D, spectrum allocation and other government assets. TAP-INFO reports on TAP activities relating to federal information policy. tap-info is archived at ftp.cpsr.org; gopher.cpsr.org and wais.cpsr.org

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