ITU (again)

[Richard J. Sexton]

Comments of the United States ITU Association
on the
Secretary-General's IP Networks Report

The United States ITU Association offers these
comments to the Department of State on the
report entitled "Activities of General
Secretariat and ITU Sectors Underway with
Regard to IP-Based Networks and Cooperation
with Other International Organizations" (the
Report). The Association asks that these
comments be reflected in the official comments
of the United States Government to the ITU on
the Report.

The Association understands the ITU's interest
in the development of the Internet and IP
networks. This development is plainly one of
great historical significance. But the
Association believes the ITU must proceed with
extreme caution in expanding its role in this
area. It has grave concerns about the premise
apparently underlying the Report-namely, that
the ITU-and particularly the ITU
Secretariat-should become more involved in
Internet governance and policy.

The Internet and IP Networks

It is almost impossible to overstate the
importance of the Internet. It has been
described as "the most important communications
medium in history," and "the most powerful
driver for innovation the world has ever seen."
There is little doubt that the Internet has
begun to change the way the entire world
communicates, learns, shops, and interacts.
Without belaboring the point, the Internet, and
the IP networks that it is built upon, have
been described as helping bring about "the
death of distance." This will, in turn, lead
to a host of benefits for humanity-and, in
particular, for those in developing countries
who for the first time have access to
information that was once restricted to the
industrial world.

One characteristic of the Internet is
particularly essential to its phenomenal growth
and potential to change the world for the
better: namely, it is fundamentally global.
For example, the World Wide Web itself-perhaps
the single most important reason behind the
Internet's recent growth-was invented not by an
American, but by a British researcher at the
CERN particle physics laboratory in
Switzerland, using a globally available
platform. Indeed, IP networks are most
valuable insofar as they are global. This
phenomenon is known as "Metcalfe's Law," which
states that the value of any network increases
exponentially with each additional connected
user, since each person on the network can
reach a greater number of persons. In other
words, the Internet derives much of its current
value from the fact that a user can read the
day's issue of Le Monde, e-mail a file to a
business colleague in South Africa, or listen
to a radio program from Montreal. Take any of
those options away, and the Internet loses the
"universal connectivity" that makes it worth
the user's while. But add to the options and
the Internet becomes much more valuable.

Non-Regulation as Contributing to the
Internet's Success

The Association believes that one of the most
important factors behind the astonishing
success of the Internet is the absence of
governmental (and supra-governmental)
governance and policy regulation of IP
networks. In the United States, where the
Internet first took root, the government has
refrained from regulating computer-based
telecommunications services. At the risk of
simplifying, the U.S. government (and other
governments) have wisely recognized the
distinction between traditional telephone
service (for which regulation has been
necessary to limit anti-competitive conduct by
those with market power) and the competitive
markets for IP services (for which such
regulation has been unnecessary). The
Association believes that, by deciding not to
impose intrusive regulation on IP networks,
governments have enabled market forces to
create the vibrant, growing Internet that
exists today.

The Association's Concerns

In the Association's view, then, the Internet
may become one of the most important
communications media in the history of the
world. Its success is surely related to the
decisions made by governments and international
organizations not to engage in the governance
and policy regulation of IP networks.

For the Association, this suggests that the
ITU-and particularly the Secretariat-should
proceed with the utmost caution before
expanding its role with respect to IP networks.
Some of the policy activities already being
considered by the ITU would constitute serious
policy mistakes. For example, Study Group 3 of
the ITU-T is discussing "tariff and accounting
principles as well as related
telecommunications economic and policy issues
specific to IP Network offerings." The
Association strongly opposes ITU consideration
of such activities. Fundamentally, accounting
principles of the sort at issue here were
developed as a way to allow monopoly telephone
operators to do business with one another, and
have absolutely no application in today's
vibrant, competitive, IP networked world. In
the Association's view, for the ITU to even
consider them would risk retarding the
extraordinary-and extraordinarily
beneficial-growth of the Internet and IP
networks.

The Association's View of the ITU's Role

There have been, and are likely to be in the
future, occasions where the Internet community
itself calls on the ITU to play a role in
addressing specific issues on an ad hoc, short
term basis. For example, one can imagine the
ITU being called on to play a role for devices
that roam on IP networks. The ITU has already
been asked to administer .INT domain name-a
discrete but important mission. We can also
imagine the ITU Development Sector being asked
to play a role in creating a list of "best
practices" for Internet growth in developing
nations.

However, the Association notes that, in each of
these cases, the ITU has been-or would be-asked
to play a role in conjunction with the Internet
community, and particularly with the private
sector. The Association believes that, in
those cases where the ITU is asked to
intervene, coordination with the Internet
community should be the model.

What the Association fears is the ITU's seeming
wish to become involved in governance and
policy regulation of the Internet and IP
networks. This is, in our view, both
unnecessary and unwise.

Conclusion

The ITU is fundamentally correct in recognizing
the significance of the growth of the Internet
and IP networks. Its instinct to wish to
become more deeply involved in this phenomenon
is surely understandable. But an expansion of
the ITU's involvement into Internet or IP-based
network governance seems largely unnecessary,
and could be enormously counterproductive.
Thus, the ITU should not be actively seeking to
insert itself into governance of the Internet
or IP networks.

--
Richard Sexton | ric...@tangled.web | http://dns.vrx.net/tech/rootzone
http://killifish.vrx.net http://www.mbz.org http://lists.aquaria.net
Bannockburn, Ontario, Canada, 70 & 72 280SE, 83 300SD +1 (613) 473-1719