US Telecom major AT&T has weighed in on India’s Net Neutrality debate, asking the Indian telecom regulator TRAI to create exceptions to Net Neutrality for a wide range of services, including online calling, video streaming, Internet of Things, enterprise and managed services, and even though this particular consultation is about throttling, it has asked for exemptions for such services even from the discriminatory pricing regulation, saying that the TRAI “should exempt enterprise services, specialized services and Internet of Things etc from any NN policy or regulation.”

Widening the scope of managed services to include everything

In particular, it cites the Department of Telecom report on Net Neutrality a couple of years ago (full report / summary), which said that it was of the view that “managed services are a necessary requirement for businesses and enterprises and suitable exceptions may be made for treatment of such services in the net neutrality context.”

What AT&T is trying to do, though, is to widen the scope of the term “managed services” in a manner that the managed services ecosystem includes all possible services, and at the same time, gets preferential treatment over the open Internet:

In its submission, AT&T says that the definition of Internet services should be limited to “only mass-market retail broadband Internet access services with the capability to transmit and receive data from all or substantially all Internet end-points and to expressly exclude from the definition specialised services, such as Internet VoIP or IPTV, the internet of things (IoT) and also enterprise services such as managed services, virtual private networks, content delivery networks (CDNs), hosting or data storage services or Internet backbone services.”

User-driven traffic differentiation

AT&T says that “Open Internet Policies should not restrict user-driven traffic differentiation”, which it says is “essential for many enterprise applications, from banking to emergency services, to streaming video. AT&T supports a distinction between traffic differentiation that is not directed by end users, and traffic differentiation arrangements that are user driven. ”

Comments on specific service types

1. VPNs: AT&T highlights virtual private networks (VPNs) as an example of enterprise services, which are “typically offered to larger organisations through customised or individually negotiated arrangements.” This is clearly an attempt to mislead the regulator, since VPNs are fairly common among consumers as well, especially those who wish to retain the privacy of their Internet consumption and wish to bypass geo-restrictions on Internet access. VPNs are clearly not just an enterprise service. Remember Netflix blocking consumer VPN access?

2. VoIP and Video: AT&T says that telecom companies “…VoIP and Video require the application of class of service to enable the near real-time delivery of voice applications or to support streaming video”…

3. IoT and M2M: AT&T believes that Machine to Machine and IoT should be outside of the Net Neutrality policy. “Internet connectivity is but a piece of any IOT solution provided by one of the many stakeholders involved in the IOT chain that includes Network Operators, System Integrators (Sis), software developers, vendor companies, solution providers, distributor or sellers etc. Also, IOT applications require connectivity neutral platform that will work so long as there is underlying connectivity (from any operator)”. As connectivity is but one element of a larger solution, IOT applications should not be subject to NN policy, as done in the United States, EU and several other jurisdictions. Different applications have varying needs for delay, delay variation (jitter), bandwidth, packet loss and availability. Hence, enterprise customers negotiate service level agreements to ensure that the network supports the Quality of Service (QoS) that they need in order to meet the different requirements of such applications”

4. Content delivery networks: “enable the acceleration and compression of data through the cloud to allow for faster browsing experience to be enjoyed by end-users. This is achieved through the use of a global network of service nodes containing specialized web acceleration and streaming servers, dynamic site acceleration, secure delivery of HTTPS traffic and additional security and reporting features. As recognized by the FCC in the 2015 Open Internet Order, broadband Internet access service does not include virtual private network (VPN) services, content delivery networks (CDNs), hosting or data storage services, or Internet backbone services (to the extent those services are separate from broadband Internet access service).”