Internet Engineering Task Force                               C. Bastian
Internet-Draft                                                T. Klieber
Intended status: Informational                         J. Livingood, Ed.
Expires: December 28, 2009                                      J. Mills
                                                               R. Woundy
                                                                 Comcast
                                                           June 26, 2009


        Comcast's Protocol-Agnostic Congestion Management System
               draft-livingood-woundy-congestion-mgmt-00

Status of this Memo

   This Internet-Draft is submitted to IETF in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF), its areas, and its working groups.  Note that
   other groups may also distribute working documents as Internet-
   Drafts.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   The list of current Internet-Drafts can be accessed at
   http://www.ietf.org/ietf/1id-abstracts.txt.

   The list of Internet-Draft Shadow Directories can be accessed at
   http://www.ietf.org/shadow.html.

   This Internet-Draft will expire on December 28, 2009.

Copyright Notice

   Copyright (c) 2009 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents in effect on the date of
   publication of this document (http://trustee.ietf.org/license-info).
   Please review these documents carefully, as they describe your rights
   and restrictions with respect to this document.






Bastian, et al.         Expires December 28, 2009               [Page 1]


Internet-Draft     An ISP Congestion Management System         June 2009


Abstract

   This document describes the congestion management system of Comcast
   Cable, a large cable broadband Internet Service Provider (ISP) in the
   U.S. Comcast completed deployment of this congestion management
   system on December 31, 2008.


Table of Contents

   1.  Introduction . . . . . . . . . . . . . . . . . . . . . . . . .  3
   2.  Key Terminology  . . . . . . . . . . . . . . . . . . . . . . .  3
   3.  Historical Overview  . . . . . . . . . . . . . . . . . . . . .  7
   4.  Summary  . . . . . . . . . . . . . . . . . . . . . . . . . . .  7
   5.  Implemetation and Configuration  . . . . . . . . . . . . . . .  9
     5.1.  Thresholds For Determining When a CMTS Port Is in a
           Near Congestion State  . . . . . . . . . . . . . . . . . . 13
     5.2.  Thresholds For Determining When a User Is in an
           Extended High Consumption State and for Release from
           that Classification  . . . . . . . . . . . . . . . . . . . 14
     5.3.  Effect of BE Quality of Service on Users&apos
           Broadband Experience . . . . . . . . . . . . . . . . . . . 17
     5.4.  Equipment/Software Used and Location . . . . . . . . . . . 19
   6.  Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . 21
   7.  Exceptional Network Utilization Considerations . . . . . . . . 21
   8.  Security Considerations  . . . . . . . . . . . . . . . . . . . 21
   9.  IANA Considerations  . . . . . . . . . . . . . . . . . . . . . 21
   10. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . 22
   11. Change Log . . . . . . . . . . . . . . . . . . . . . . . . . . 22
   12. Open Issues  . . . . . . . . . . . . . . . . . . . . . . . . . 22
   13. Informative References . . . . . . . . . . . . . . . . . . . . 22
   Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . . 24



















Bastian, et al.         Expires December 28, 2009               [Page 2]


Internet-Draft     An ISP Congestion Management System         June 2009


1.  Introduction

   Comcast Cable is a large broadband Internet Service Provider (ISP),
   based in the U.S., serving the majority of its customers via cable
   modem technology.  During the late part of 2008, and completing on
   December 31, 2008, Comcast deployed a new congestion management
   system across its entire network.  This new system was developed in
   response to dissatisfaction in the Internet community as well as
   complaints to the U.S. Federal Communications Commission (FCC)
   regarding Comcast's old system, which targeted specific peer-to-peer
   (P2P) applications.  This new congestion management system is
   protocol-agnostic, meaning that it does not examine or impact
   specific user applications or network protocols, which is perceived
   as a more fair system for managing network resources at limited times
   when congestion may occur.

   The purpose of this document is to describe how this example of a
   large scale congestion management system functions.  This is
   primarily in response to questions from other ISPs as well as
   solution developers, who are interested in learning from and/or
   deploying similar systems in other networks.


2.  Key Terminology

   This section defines the key terms used in this document.  Some terms
   below refer to elements of the Comcast network.  As a result, it may
   be helpful to refer to Figure 1 when reviewing some of these terms.

2.1.  Cable Modem

   A device located at the customer premise used to access the Comcast
   High Speed Internet (HSI) network.  In some cases, the cable modem is
   owned by the customer, and in other cases it is owned by the cable
   operator.  This device has an interface (i.e., someplace to plug in a
   cable) for connecting the coaxial cable provided by the cable company
   to the modem, as well as one or more interfaces for connecting the
   modem to a customer's PC or home gateway device (e.g., home gateway,
   router, firewall, access point, etc.).  In some cases, the cable
   modem function, i.e., the ability to access the Internet, is
   integrated into a home gateway device or Embedded Multimedia Terminal
   Adapter (eMTA).  Once connected, the cable modem links the customer
   to the HSI network and ultimately the broader Internet.

2.2.  Cable Modem Termination System (CMTS)

   A piece of hardware located in a cable operator's local network
   (generally in a "headend", Section 2.10) that acts as the gateway to



Bastian, et al.         Expires December 28, 2009               [Page 3]


Internet-Draft     An ISP Congestion Management System         June 2009


   the Internet for cable modems in a particular geographic area.  A
   simple way to think of the CMTS is as a router with interfaces on one
   side leading to the Internet and interfaces on the other connecting
   to Optical Nodes and then customers, in a so-called "last mile""
   network.

2.3.  Cable Modem Termination System (CMTS) Port

   Also referred to simply as a "port".  A port is a physical interface
   on a device used to connect cables in order to connect with other
   devices for transferring information/data.  An example of a physical
   port is a CMTS port.  A CMTS has both upstream and downstream network
   interfaces to serve the local access network, which are referred to
   as upstream or downstream ports.  A port generally serves a
   neighborhood of hundreds of homes.  Over time, CMTS ports tend to
   server fewer and fewer homes, as the network is segmented for
   capacity growth purposes.  Prior to DOCSIS version 3, a single CMTS
   physical port was used for either transmitting or receiving data
   downstream or upstream to a given neighborhood.  With DOCSIS version
   3, and the channel bonding feature, multiple CMTS physical ports can
   be combined to create a virtual port.  A CMTS is also briefly defined
   in Section 2.6 of [RFC3083].

2.4.  Channel Bonding

   A technique for combining multiple downstream and/or upstream
   channels to increase customers' download and/or upload speeds,
   respectively.  Multiple channels from the Hybrid Fiber Coax (HFC,
   Section 2.11) network can be bonded into a single virtual port
   (called a bonded group), which acts as a large single channel or port
   to provide increased speeds for customers.  Channel bonding is a
   feature of Data Over Cable Service Interface Specification (DOCSIS)
   version 3.

   [EDITORIAL NOTE: Any other good DOCSIS 3.0 channel bonding references
   to include here?]

2.5.  Coaxial Cable (Coax)

   A type of cable used by a cable operator to connect customer premise
   equipment (CPE) -- such as TVs, cable modems (including eMTAs), and
   Set Top Boxes -- to the HFC network.  This cable may be used both
   within the home as well as in segments of the last mile network
   running to a home or customer premise location.  There are many
   grades of coaxial cable that are used for different purposes.
   Different types of coaxial cable are used for different purposes on
   the network.




Bastian, et al.         Expires December 28, 2009               [Page 4]


Internet-Draft     An ISP Congestion Management System         June 2009


2.6.  Comcast High Speed Internet (HSI)

   A service/product offered by Comcast for delivering Internet service
   over a broadband connection.

2.7.  Customer Premise Equipment (CPE)

   Any device that resides at the customer's residence.

2.8.  Data Over Cable Service Interface Specification (DOCSIS)

   A reference standard developed by CableLabs that specifies how
   components on cable networks need to be built to enable HSI service
   over an HFC network.  These standards define the specifications for
   the cable modem and the CMTS such that any DOCSIS certified cable
   modem will work on any DOCSIS-certified CMTS, independent of the
   selected vendor.  The interoperability of cable modems and CMTSs
   allows customers to purchase a DOCSIS-certified modem from a retail
   outlet and use it on their cable-networked home.  These standards are
   available to the public at the CableLabs website, at
   http://www.cablelabs.com.

   [EDITORIAL NOTE: Any other good DOCSIS references to include here?]

2.9.  Downstream

   Description of the direction in which a signal travels, in this case
   from the network to a user.  Downstream traffic occurs when users are
   downloading something from the Internet, such as watching a web-based
   video, reading web pages, or downloading software updates.

2.10.  Headend

   A cable facility responsible for receiving TV signals for
   distribution over the HFC network to the end customers.  This
   facility typically also houses one or more CMTSs.  This is sometimes
   also called a "hub".

2.11.  Hybrid Fiber Coax (HFC)

   A network architecture used primarily by cable companies, comprised
   of fiber optic and coaxial cables that currently deliver Voice,
   Video, and Internet services to customers.

2.12.  Internet Protocol Detail Record (IPDR)

   Standardized technology for monitoring and/or recording subscribers'
   upstream and downstream Internet usage data based on their cable



Bastian, et al.         Expires December 28, 2009               [Page 5]


Internet-Draft     An ISP Congestion Management System         June 2009


   modem.  The data is collected from the CMTS and sent to a server for
   further processing.  Additional information is available at
   http://www.ipdr.org, as well as [IPDR Standard] and [CableLabs DOCSIS
   IPDR Support].

2.13.  Optical Node

   A component of the HFC network generally located in customers' local
   neighborhoods which is used to convert the optical signals sent over
   fiber-optic cables to electrical signals that can be sent over
   coaxial cable to customers' cable modems, or vice versa.  A fiber
   optic cable connects the Optical Node, through distribution hubs, to
   the CMTS and coaxial cable connects the Optical Node to customers'
   cable modems.

2.14.  Provisioned Bandwidth

   The peak speed associated with a tier of service purchased by a
   customer.  For example, a customer with a 50 Mbps downstream and 10
   Mbps upstream speed tier would be said to be provisioned with 50 Mbps
   of downstream bandwidth and 10 Mbps of upstream bandwidth.  This is
   often referred to as 50/10 service in industry parlance.

   The Provisioned Bandwidth is the speed that a customer's modem is
   configured (and the network is engineered) to deliver on a regular
   basis (which is not the same as a "Committed Information Rate" or a
   guaranteed rate).  Internet speeds are generally a best efforts
   service that are dependent on a number of variables, many of which
   are outside the control of an Internet Service Provide (ISP).  In
   general, speeds do not typically exceed a customer's provisioned
   speed.  Comcast, however, invented a technology called "PowerBoost"
   [EDITORIAL NOTE: Include external technical references to
   PowerBoost?] that, for example, enables users to experience brief
   boosts above their provisioned speeds while they transfer large files
   over the Internet, by utilizing excess capacity which may be
   available in the network at that time.

2.15.  Quality of Service (QoS)

   Set of techniques to manage network resources to ensure a level of
   performance to specific data flows.  One method for providing QoS to
   a network is by differentiating the type of traffic by class or flow
   and assigning priorities to each type.  When the network becomes
   congested, the data packets that are marked as having higher priority
   will have higher likelihood of being serviced.

   [EDITORIAL NOTE: Any good QoS references to include here?]




Bastian, et al.         Expires December 28, 2009               [Page 6]


Internet-Draft     An ISP Congestion Management System         June 2009


2.16.  Upstream

   Description of the direction in which a signal travels, in this case
   from the user to the network.  Upstream traffic occurs when users are
   uploading something to the network, such as sending email, sending
   files to another computer, or uploading photos to a digital photo
   website.


3.  Historical Overview

   Comcast began the engineering project to develop a new congestion
   management system in March 2008, the same month that Comcast hosted
   the 71st meeting of the IETF in Philadelphia, PA, USA.  On May 28,
   2008, Comcast participated in an IETF Peer-to-Peer Infrastructure
   Workshop [I-D.p2pi-cooper-workshop-report], hosted by the
   Massachusetts Institute of Technology (MIT) in Cambridge, MA, USA.

   In order to participate in this workshop, interested attendees were
   asked to submit a paper to a technical review team, which Comcast did
   on May 9, 2008, in the [Comcast P2Pi Position Paper].  Comcast
   subsequently attended and participated in this valuable workshop.
   During the workshop, Comcast outlined the high-level design for a new
   congestion management system [Comcast IETF P2P Infrastructure
   Workshop Presentation] and solicitied comments and other feedback
   from attendees and other members of the Internet community
   (presentations were also posted to the IETF's P2Pi mailing list).
   The congestion management system outlined in that May 2008 workshop
   was later tested in trial markets and is in essence what was then
   deployed by Comcast later in 2008.

   Following an August 2008 [FCC Memorandum and Opinion] regarding how
   Comcast managed congestion on its High-Speed Internet ("HSI")
   network, Comcast disclosed to the FCC and the public additional
   technical details of the congestion management system that it
   intended to and did implement by the end of 2008, including the
   thresholds involved in this new system.  That system is detailed in
   this document.  While the description of how this system is deployed
   in the Comcast network is necessarily specific to the various
   technologies and designs specific to that network, a similar system
   could be deployed on virtually any large scale ISP network or other
   IP network.


4.  Summary

   Comcast's HSI network has elements which are shared across many
   subscribers.  This means that Comcast's HSI customers share upstream



Bastian, et al.         Expires December 28, 2009               [Page 7]


Internet-Draft     An ISP Congestion Management System         June 2009


   and downstream bandwidth with their neighbors.  Although the
   available bandwidth is substantial, so, too, is the demand.  Thus,
   when a relatively small number of customers in a neighborhood place
   disproportionate demands on network resources, this can cause
   congestion that degrades their neighbors' Internet experience.  The
   goal of Comcast's new congestion management system is to enable all
   users of our network resources to access a "fair share" of that
   bandwidth, in the interest of ensuring a high-quality online
   experience for all of Comcast's HSI customers.

   Importantly, the new approach is protocol-agnostic; that is, it does
   not manage congestion by focusing on the use of the specific
   protocols that place a disproportionate burden on network resources,
   or any other protocols.  Rather, the new approach focuses on managing
   the traffic of those individuals who are using the most bandwidth at
   times when network congestion threatens to degrade subscribers'
   broadband experience and who are contributing disproportionately to
   such congestion at those points in time.

   Specific details about these practices, including relevant threshold
   information, the type of equipment used, and other particulars, are
   discussed at some length later in this document.  At the outset,
   however, we present a very high-level, simplified overview of how
   these practices work.  Despite all the detail provided further below,
   the fundamentals of this approach can be summarized succinctly:

   1.  Software installed in the Comcast network continuously examines
       aggregate traffic usage data for individual segments of Comcast's
       HSI network.  If overall upstream or downstream usage on a
       particular segment of Comcast's HSI network reaches a pre-
       determined level, the software moves on to step two.

   2.  At step two, the software examines bandwidth usage data for
       subscribers in the affected network segment to determine which
       subscribers are using a disproportionate share of the bandwidth.
       If the software determines that a particular subscriber or
       subscribers have been the source of high volumes of network
       traffic during a recent period of minutes, traffic originating
       from that subscriber or those subscribers temporarily will be
       assigned a lower priority status.

   3.  During the time that a subscriber's traffic is assigned the lower
       priority status, such traffic will not be delayed so long as the
       network segment is not actually congested.  If, however, the
       network segment becomes congested, such traffic could be delayed.

   4.  The subscriber's traffic returns to normal priority status once
       his or her bandwidth usage drops below a set threshold over a



Bastian, et al.         Expires December 28, 2009               [Page 8]


Internet-Draft     An ISP Congestion Management System         June 2009


       particular time interval.

   Comcast undertook considerable effort, over the course of many
   months, to formulate our plans for this congestion management
   approach, adjusting them, and subjecting them to real-world trials.
   Market trials were conducted in Chambersburg, PA; Warrenton, VA; Lake
   City, FL; East Orange, FL; and Colorado Springs, CO, between June and
   September, 2008.  This enabled us to validate the utility of the
   general approach and collect substantial trial data to test multiple
   variations and alternative formulations.


5.  Implemetation and Configuration

   To understand exactly how these new congestion management practices
   work, it is helpful to have a general understanding of how Comcast's
   HSI network is designed.  Comcast's HSI network is what is commonly
   referred to as a hybrid fiber-coax network, with coaxial cable
   connecting each subscriber's cable modem to an Optical Node, and
   fiber optic cables connecting the Optical Node, through distribution
   hubs, to the Cable Modem Termination System (CMTS), which is also
   known as a "data node".  The CMTSes are then connected to higher-
   level routers, which in turn are connected to Comcast's Internet
   backbone facilities.  Today, Comcast has over 3,200 CMTSes deployed
   throughout our network, serving over 15 million HSI subscribers.

   Each CMTS has multiple "ports" that handle traffic coming into and
   leaving the CMTS.  In particular, each cable modem deployed on the
   Comcast HSI network is connected to the CMTS through the ports on the
   CMTS.  These ports can be either "downstream" ports or "upstream"
   ports, depending on whether they send information to cable modems
   (downstream) or receive information from cable modems (upstream)
   attached to the port.  (Note that the term "port" as used here
   generally contemplates single channels on a CMTS, but these
   statements will apply to virtual channels, also known as "bonded
   groups", in a DOCSIS 3.0 environment.)  Currently, on average,
   approximately 275 cable modems share the same downstream port and
   about 100 cable modems share the same upstream port, however this is
   constantly changing (both numbers generally become smaller over
   time).  Both types of ports can experience congestion that could
   degrade the broadband experience of our subscribers and, unlike with
   the previous congestion management practices, both upstream and
   downstream traffic are be subject to management in this new
   congestion management system.

   To implement Comcast's new protocol-agnostic congestion management
   practices, Comcast purchased new hardware and software that was
   deployed near the Regional Network Routers ("RNRs") that are further



Bastian, et al.         Expires December 28, 2009               [Page 9]


Internet-Draft     An ISP Congestion Management System         June 2009


   upstream in Comcast's network.  This new hardware consists of
   Internet Protocol Detail Record ("IPDR") servers, Congestion
   Management servers, and PacketCable Multimedia ("PCMM") servers.
   Further details about each of these pieces of equipment can be found
   below, in Section 5.4.  It is important to note here, however, that
   even though the physical location of these servers is at the RNR, the
   servers communicate with -- and manage individually -- multiple ports
   on multiple CMTSes to effectuate the practices described in this
   document.  That is to say, bandwidth usage on one CMTS port will have
   no effect on whether the congestion management practices described
   herein are applied to a subscriber on a different CMTS port.

   Figure 1 provides a simplified graphical depiction of the network
   architecture just described:

   Figure 1: Simplified Network Diagram Showing High-Level Comcast
   Network and Servers Relevant to Congestion Management

                                  -----------------
                             /////                 \\\\\
                            | Comcast Internet Backbone |
                             \\\\\                 ------
                                 ----------------//      \\
   +------------+                                /         \
   | Congestion |                               |  Internet |
   | Management |<+++GigE++++             +---->|  Backbone |
   |   Server   |           +             |     |   Router  |
   +------------+           +             |      \         /
                            +           Fiber     \\     //
   +------------+           +             |         -----
   |    QoS     |           +             |
   |   Server   |<+++GigE++++             \/
   |            |           +           -----
   +------------+           +         //     \\
                            +        /         \
   +------------+           +       |  Regional |
   | Statistics |           +++++++>|  Network  |
   | Collection |<+++GigE++++       |   Router  |
   |   Server   |                    \         /
   +------------+     +---Fiber------>\\     //<------Fiber----+
                      |                 -----                  |
                      |                                        |
                      \/                                       \/
                    -----                                     -----
                  //     \\                                 //     \\
                 /         \                               /         \
                |   Local   |                             |   Local   |
                |   Market  |                             |   Market  |



Bastian, et al.         Expires December 28, 2009              [Page 10]


Internet-Draft     An ISP Congestion Management System         June 2009


                |   Router  |                             |   Router  |
                 \         /                               \         /
       +--------->\\     //<------------+                   \\     //
       |            -----               |                     -----
       |             /\                 |                       /\
     Fiber           |                 Fiber                    |
       |           Fiber                |                      Fiber
       |             |                  |                       |
       \/            \/                 \/                      \/
    //----\\      //----\\           //----\\                //----\\
   |  CMTS  |    |  CMTS  |         |  CMTS  |              |  CMTS  |
    \\----//      \\----//           \\----//                \\----//
       /\            /\                 /\                      /\
       |             |                  |                       |
      Fiber         Fiber              Fiber                   Fiber
       |             |                  |                       |
       \/            \/                 \/                      \/
   +---------+   +---------+       +---------+             +---------+
   | Optical |   | Optical |       | Optical |             | Optical |
   |  Node   |   |  Node   |       |  Node   |             |  Node   |
   +---------+   +---------+       +---------+             +---------+
       /\          /\   /\                /\                /\     /\
       ||          ||   ||______          ||           _____||     ||
      Coax        Coax  |__Coax|         Coax         |Coax__|    Coax
       ||          ||         ||          ||          ||           ||
       \/          \/         \/          \/          \/           \/
   +=======+   +=======+   +=======+   +=======+   +=======+   +=======+
   = Cable =   = Cable =   = Cable =   = Cable =   = Cable =   = Cable =
   = Modem =   = Modem =   = Modem =   = Modem =   = Modem =   = Modem =
   +=======+   +=======+   +=======+   +=======+   +=======+   +=======+


   ================================================================
   + Note: This diagram is a simplification of the actual network +
   +  and servers, which in actuality includes redundant network  +
   +   links, redundant network devices, redundant servers, and   +
   +         other details too complex to represent here.         +
   ================================================================

                                 Figure 1

   Each Comcast HSI subscriber's cable modem has a "bootfile", which is
   essentially a configuration file that contains certain pieces of
   information about the subscriber's service to ensure that the service
   functions properly.  (Note: No personal information is included in
   the bootfile; it only includes information about the service that the
   subscriber has purchased.)  For example, the bootfile contains
   information about the maximum speed (what we refer to in this



Bastian, et al.         Expires December 28, 2009              [Page 11]


Internet-Draft     An ISP Congestion Management System         June 2009


   document as the "provisioned bandwidth") that a particular modem can
   achieve based on the tier (personal/residential, commercial, etc.)
   the customer has purchased.  Bootfiles are generally reset from time
   to time to account for changes in the network and other updates, and
   this is usually done through a command sent from the network and
   without any effect on the subscriber.  In preparation for the
   transition to this new congestion management system, Comcast sent new
   bootfiles to our HSI customers' cable modems that created two Quality
   of Service ("QoS") levels for Internet traffic going to and from the
   cable modem: (1) "Priority Best-Effort" traffic ("PBE"); and (2)
   "Best-Effort" traffic ("BE").  As with previous changes to cable
   modem bootfiles, the replacement of the old bootfile with the new
   bootfile requires no active participation by Comcast customers.

   Thereafter, all traffic going to or coming from cable modems on the
   Comcast HSI network is designated as either PBE or BE.  PBE is the
   default status for all Internet traffic coming from or going to a
   particular cable modem.  Traffic is designated BE for a particular
   cable modem only when both of two conditions are met:

   o  First, the usage level of a particular upstream or downstream port
      of a CMTS, as measured over a particular period of time, must be
      nearing the point where congestion could degrade users'
      experience.  We refer to this as the "Near Congestion State" and,
      based on the technical trials we have conducted, we have
      established a threshold, described in more detail below, for when
      a particular CMTS port enters that state.

   o  Second, a particular subscriber must be making a significant
      contribution to the bandwidth usage on the particular port, as
      measured over a particular period of time.  We refer to this as
      the "Extended High Consumption State" and, based on the technical
      trials we have conducted, we have established a threshold,
      described in more detail below, for when a particular user enters
      that state.

   When, and only when, both conditions are met, a user's upstream or
   downstream traffic (depending on which type of port is in the Near
   Congestion State) is designated as BE.  Then, to the extent that
   actual congestion occurs, any delay resulting from the congestion
   will affect BE traffic before it affects PBE traffic.

   We now explain the foregoing in greater detail in the following
   sections.







Bastian, et al.         Expires December 28, 2009              [Page 12]


Internet-Draft     An ISP Congestion Management System         June 2009


5.1.  Thresholds For Determining When a CMTS Port Is in a Near
      Congestion State

   For a CMTS port to enter the Near Congestion State, traffic flowing
   to or from that CMTS port must exceed a specified level (the "Port
   Utilization Threshold") for a specific period of time (the "Port
   Utilization Duration").  The Port Utilization Threshold on a CMTS
   port is measured as a percentage of the total aggregate upstream or
   downstream bandwidth for the particular port during the relevant
   timeframe.  The Port Utilization Duration on the CMTS is measured in
   minutes.

   Values for each of the thresholds to be used as part of this new
   management technique have been tentatively established after an
   extensive process of lab tests, simulations, technical trials, vendor
   evaluations, customer feedback, and a third-party consulting
   analysis.  In the same way that specific anti-spam or other network
   management practices are adjusted to address new issues that arise,
   it is a near certainty that these values will change over time, as
   Comcast gathers more data and performs additional analysis resulting
   from wide-scale use of the new technique.  Moreover, as with any
   large network or software system, software bugs and/or unexpected
   errors may arise, requiring software patches or other corrective
   actions.  As always, Comcast's decisions on these matters are driven
   by the marketplace imperative that we deliver the best possible
   experience to our HSI subscribers.

   Given our experience so far, we have determined that a starting point
   for the upstream Port Utilization Threshold should be 70 percent and
   the downstream Port Utilization Threshold should be 80 percent.  For
   the Port Utilization Duration, we have determined that the starting
   point should be approximately 15 minutes (although some technical
   limitations in some newer CMTSes deployed on Comcast's network may
   make this time period vary slightly).  Thus, over any 15-minute
   period, if an average of more than 70 percent of a port's upstream
   bandwidth capacity or more than 80 percent of a port's downstream
   bandwidth capacity is utilized, that port is determined to be in a
   Near Congestion State.

   Based on the trials conducted and operational experience to date, a
   typical CMTS port on our HSI network is in a Near Congestion State
   only for relatively small portions of the day, if at all, though
   there is no way to forecast what will be the busiest time on a
   particular port on a particular day.  Moreover, the trial data and
   operational experience indicate that, even when a particular port is
   in a Near Congestion State, the instances where the network actually
   becomes congested during the Port Utilization Duration are few, and
   managed users whose traffic is delayed during those congested periods



Bastian, et al.         Expires December 28, 2009              [Page 13]


Internet-Draft     An ISP Congestion Management System         June 2009


   perceive little, if any, effect, as discussed below.

5.2.  Thresholds For Determining When a User Is in an Extended High
      Consumption State and for Release from that Classification

   Once a particular CMTS port is in a Near Congestion State, the
   software examines whether any cable modems are consuming bandwidth
   disproportionately.  (Note: Although each cable modem is typically
   assigned to a particular household, the software does not and cannot
   actually identify individual users or analyze particular users'
   traffic.)  For purposes of this document, we use "cable modem",
   "user", and "subscriber" interchangeably to mean a subscriber account
   or user account and not an individual person.).  For a user to enter
   an Extended High Consumption State, he or she must consume greater
   than a certain percentage of his or her provisioned upstream or
   downstream bandwidth (the "User Consumption Threshold") for a
   specific length of time (the "User Consumption Duration").  The User
   Consumption Threshold is measured as a user's consumption of a
   particular percentage of his or her total provisioned upstream or
   downstream bandwidth.  That bandwidth is the maximum speed that a
   particular modem can achieve based on the tier (personal/residential,
   commercial, etc.) the customer has purchased.  For example, if a user
   buys a service with speeds of 8 Mbps downstream and 1 Mbps upstream,
   then his or her provisioned downstream speed is 8 Mbps and
   provisioned upstream speed is 1 Mbps.  It is also important to note
   that because the User Consumption Threshold is a percentage of
   provisioned bandwidth for a particular user account, and not a static
   value, users of higher speed tiers have correspondingly higher User
   Consumption Thresholds.  Lastly, the User Consumption Duration is
   measured in minutes.

   Following lab tests, simulations, technical trials, customer
   feedback, vendor evaluations, and a third-party consulting analysis,
   we have determined that the appropriate starting point for the User
   Consumption Threshold is 70 percent of a subscriber's provisioned
   upstream or downstream bandwidth, and that the appropriate starting
   point for the User Consumption Duration is 15 minutes.  That is, when
   a subscriber uses an average of 70 percent or more of his or her
   provisioned upstream or downstream bandwidth over a particular 15-
   minute period, that user is then in an Extended High Consumption
   State.  The User Consumption Thresholds have been set sufficiently
   high that using the HSI connection for VoIP or most streaming video
   cannot alone cause subscribers to our standard-level HSI service to
   exceed the User Consumption Threshold.  For example, while Comcast's
   standard-level HSI service provisions downstream bandwidth at 12
   Mbps, today, streaming video (even some HD video) from Hulu uses less
   than 2.5 Mbps, a Vonage or Skype VoIP call uses less than 131 Kbps,
   and streaming music uses less than 128 kbps (in this example, 70



Bastian, et al.         Expires December 28, 2009              [Page 14]


Internet-Draft     An ISP Congestion Management System         June 2009


   percent of 12 Mbps is 8.4 Mbps).  As noted above, these values are
   subject to change as necessary in the same way that specific anti-
   spam or other network management practices are adjusted to address
   new issues that arise, or should unexpected software bugs or other
   problems arise.

   Based on data collected from the trial markets where the new
   management practices are being tested, on average less than one-third
   of one percent of subscribers have had their traffic priority status
   changed to the BE state on any given day.  For example, in Colorado
   Springs, CO, the largest test market, on any given day in August
   2008, an average of 22 users out of 6,016 total subscribers in the
   trial had their traffic priority status changed to BE at some point
   during the day.

   A user's traffic is released from a BE state when the user's
   bandwidth consumption drops below 50 percent of his or her
   provisioned upstream or downstream bandwidth for a period of
   approximately 15 minutes.  These release criteria are intended to
   minimize (and hopefully prevent) user QoS oscillation (hysteresis),
   i.e., a situation in which a particular user could cycle repeatedly
   between BE and PBE.  NetForecast, Inc., an independent consultant
   retained to provide analysis and recommendations regarding Comcast's
   trials and related congestion management work, suggested this
   approach, which has worked well in our ongoing trials and lab
   testing.  In trials, we have observed that user traffic rarely
   remains in a managed state longer than the initial 15-minute period.

   Simply put, there are four steps to determining whether the traffic
   associated with a particular cable modem is designated as PBE or BE:

   1.  Determine if the CMTS port is in a Near Congestion State.

   2.  If yes, determine whether any users are in an Extended High
       Consumption State.

   3.  If yes, change those users' traffic to BE from PBE.  If the
       answer at either step one or step two is no, no action is taken.

   4.  If a user's traffic has been designated BE, check user
       consumption at next interval.  If user consumption has declined
       below predetermined threshold, reassign the user's traffic as
       PBE.  If not, recheck at next interval.

   Figure 2 graphically depicts how this congestion management process
   works, using an example of a situation where upstream port
   utilization may be reaching a Near Congestion State (the same
   diagram, with different values in the appropriate places, could be



Bastian, et al.         Expires December 28, 2009              [Page 15]


Internet-Draft     An ISP Congestion Management System         June 2009


   used to depict the management process for downstream ports, as well):

   Figure 2: Upstream Congestion Management Decision Flowchart

                       /\
                      /  \
 +------------+      /    \           +---------+            +---------+
 |   Start    |     /      \          |         |           /         /
 | Congestion |    /        \         |         |          /         /
 | Management +-->+ Question +--YES-->| Result  |--THEN-->/ ACTION  /
 | Process    |    \   #1   /         |   #1    |        /   #1    /
 |            |     \      /          |         |       /         /
 +------------+      \    /           +---------+      +---------+
                      \  /                                    |
                       \/                                     |
                       |                                     THEN
                       |                                      |
                       NO                                     |
                       |                                      \/
                       |                                      /\
                       \/                                    /  \
                  +---------+                               /    \
                  |         |                              /      \
                  |         |                             /        \
                  | Result  |<-------------NO------------+ Question +
                  |   #2    |                             \   #2   /
                  |         |                              \      /
                  +---------+                               \    /
                                                             \  /
                                                              \/
                                                              |
                                                              |
                                                             YES
                                                              |
                          /\                                  |
                         /  \                                 \/
  +---------+           /    \                           +---------+
  |         |          /      \                          |         |
  |         |         /        \        THEN, AT         |         |
  | Result  |<--YES--+ Question + <---NEXT ANALYSIS------+ Result  |
  |   #4    |         \   #3   /         POINT        /\ |   #3    |
  |         |          \      /                       |  |         |
  +---------+           \    /                        |  +---------+
                         \  /                         |
                          \/                          |
                          |                           |
                          |                           |
                          +------------NO-------------+



Bastian, et al.         Expires December 28, 2009              [Page 16]


Internet-Draft     An ISP Congestion Management System         June 2009


 KEY TO FIGURES ABOVE:
  Question #1: Is the CMTS Upstream Port Utilization at an average
               of OVER 70% for OVER 15 minutes?
  Result #1: CMTS marked in a Near Congestion State, indicating
             congestion MAY occur soon.
  Action #1: Search most recent analysis timeframe (approx. 15 mins.)
             of IPDR usage data.
  Question #2: Are any users consuming an average of OVER 70% of
               provisioned upstream bandwidth for OVER 15 minutes?
  Result #2: No action taken.
  Result #3: Change user's upstream traffic from Priority Best Effort
             (PBE) to Best Effort (BE).
  Question #3: Is the user in Best Effort (BE) consuming an average
               of LESS THAN 50% of provisioned upstream bandwidth?
  Result #4: Change user's upstream traffic back to Priority Best
             Effort (PBE) from Best Effort (BE).

                                 Figure 2

5.3.  Effect of BE Quality of Service on Users&apos Broadband Experience

   When a CMTS port is in a Near Congestion State and a cable modem
   connected to that port is in an Extended High Consumption State, that
   cable modem's traffic is designated as BE.  Depending upon the level
   of congestion in the CMTS port, this designation may or may not
   result in the user's traffic being delayed or, in extreme cases,
   dropped before PBE traffic is dropped.  This is because of the way
   that the CMTS handles traffic.  Specifically, CMTS ports have what is
   commonly called a "scheduler" that puts all the packets coming from
   or going to cable modems on that particular port in a queue and then
   handles them in turn.  A certain number of packets can be processed
   by the scheduler in any given moment; for each time slot, PBE traffic
   is given priority access to the available capacity, and BE traffic is
   processed on a space-available basis.  (It is important to note that
   congestion can occur in any IP network, and, when it does, packets
   can be delayed or dropped.  As a result, applications and protocols
   have been designed to deal with this reality.  Our congestion
   management systems attempts to ensure that, in those rare cases where
   packets may be dropped, BE packets are dropped before PBE packets are
   dropped.)

   A rough analogy would be to busses that empty and fill up at
   incredibly fast speeds.  As empty busses arrive at the figurative
   "bus stop" -- every two milliseconds in this case -- they fill up
   with as many packets as are waiting for "seats" on the bus, to the
   limits of the bus' capacity.  During non-congested periods, the bus
   will usually have several empty seats, but, during congested periods,
   the bus will fill up and packets will have to wait for the next bus.



Bastian, et al.         Expires December 28, 2009              [Page 17]


Internet-Draft     An ISP Congestion Management System         June 2009


   It is in the congested periods that BE packets will be affected.  If
   there is no congestion, packets from a user in a BE state should have
   little trouble getting on the bus when they arrive at the bus stop.
   If, on the other hand, there is congestion in a particular instance,
   the bus may become filled by packets in a PBE state before any BE
   packets can get on.  In that situation, the BE packets would have to
   wait for the next bus that is not filled by PBE packets.  In reality,
   this all takes place in two-millisecond increments, so even if the
   packets miss 50 "busses", the delay only will be about one-tenth of a
   second.

   During times of actual network congestion, when BE traffic might be
   delayed, there are a variety of effects that could be experienced by
   a user whose traffic is delayed, depending upon what applications he
   or she is using.  Typically, a user whose traffic is in a BE state
   during actual congestion may find that a webpage loads sluggishly, a
   peer-to-peer upload takes somewhat longer to complete, or a VoIP call
   sounds choppy.  Of course, the same thing could happen to the
   customers on a port that is congested in the absence of any
   congestion management; the difference here is that the effects of any
   such delays are shifted toward those who have been placing the
   greatest burden on the network, instead of being distributed randomly
   among the users of that port without regard to their consumption
   levels.

   NetForecast, Inc. explored the potential risk of a worst-case
   scenario for users whose traffic is in a BE state: the possibility of
   "bandwidth starvation" in the theoretical case where 100 percent of
   the CMTS bandwidth is taken up by PBE traffic for an extended period
   of time.  In theory, such a condition could mean that a given user
   whose traffic is designated BE would be unable to effectuate an
   upload or download (as noted above, both are managed separately) for
   some period of time.  However, when these management techniques were
   tested, first in company testbeds and then in our real-world trials
   conducted in the five markets, such a theoretical condition did not
   occur.  In addition, trial results demonstrated that these management
   practices have very modest real-world impacts.  In addition, Comcast
   did not receive a single customer complaint in any of the trial
   markets that could be traced to the new congestion management system,
   despite having broadly publicized these trials.

   Comcast continues to monitor how user traffic is affected by these
   new congestion management techniques and will make the adjustments
   necessary to ensure that all Comcast HSI customers have a high-
   quality Internet experience.






Bastian, et al.         Expires December 28, 2009              [Page 18]


Internet-Draft     An ISP Congestion Management System         June 2009


5.4.  Equipment/Software Used and Location

   The above-mentioned functions are carried out using three different
   types of application servers, supplied by three different vendors.
   As mentioned above, these servers are installed near Comcast's
   regional network routers.  The exact locations of various servers is
   not particularly relevant to this document, as this does not change
   the fact that they manage individual CMTS ports.

   The first application server is an IPDR server, which collects
   relevant cable modem volume usage information from the CMTS, such as
   how many aggregate upstream or downstream bytes a subscriber uses
   over a particular period of time.  IPDR has been adopted as a
   standard by many industry organizations and initiatives, such as
   CableLabs, ATIS, ITU, and 3GPP, among others.

   The second application server is the Congestion Management server,
   which uses Simple Network Management Protocol ("SNMP") [RFC3410] to
   measure CMTS port utilization and detect when a port is in a Near
   Congestion State.  When this happens, the Congestion Management
   server then queries the relevant IPDR data for a list of cable modems
   meeting the criteria set forth above for being in an Extended High
   Consumption State.

   If one or more users meet the criteria to be managed, then the
   Congestion Management server notifies a third application server, the
   PCMM application server, as to which users have been in an Extended
   High Consumption State and whose traffic should be treated as BE.
   The PCMM servers are responsible for signaling a given CMTS to set
   the traffic for specific cable modems with a BE QoS, and for tracking
   and managing the state of such CMTS actions.  If no users meet the
   criteria to be managed, no users will have their traffic managed.

   Figure 3 graphically depicts the high-level management flows among
   the congestion management components on Comcast's network, as
   described above:

   Figure 3: Simplified Diagram Showing High-Level Management Flows
   Relevant to the System

   +---------------+                            +---------------+
   |  Congestion   |     Instruct QoS Server    |      QoS      |
   |  Management   |******to Change QoS for****>|     Server    |
   |    Server     |         a Device           |               |
   +----+---+------+                            +-------+-------+
        /\  /\                                          *
        |   |                                           *
        X   |    Relay Selected                         *



Bastian, et al.         Expires December 28, 2009              [Page 19]


Internet-Draft     An ISP Congestion Management System         June 2009


        |   +---Statistics: Bytes---+                   *
        X       Up/Down by Device   |               QoS Action:
        |                           |             Change from PBE
        X                  +-------+-------+     to BE, or from
        |                  |  Statistics   |       BE to PBE
        X                  |  Collection   |            *
    Periodic SNMP          |    Server     |            *
     Requests to           +---------------+            *
   Check CMTS Port                 /\                   *
    Utilization                    |                    *
      Levels                 Statistics Sent            *
        X                 Periodically From CMTS        *
        |                          |                    *
        X                  +-------+-------+            *
        |                  |     CMTS      |            *
        +-X-X-X-X-X-X-X-X->|      in       |<************
                           |    Headend    |
                           +---------------+
                             H   /\ /\  H
                             H Internet H
                             H Traffic  H
                             H to/from  H
                             H   User   H
                             H  \/ \/   H
                        /-------------------\
                       /+-------------------+\
                      / |   User's Home     | \
                     /  |                   |  \
                        |       +---------+ |
                        |       |  Cable  | |
                        |       |  Modem  | |
                        |       +---------+ |
                        |                   |
                        +-------------------+

   =================================================================
   = Notes:                                                        =
   = 1-Statistics Collection Servers use IP Detail Records (IPDR). =
   = 2-QoS Servers use PacketCable Multimedia (PCMM)               =
   =   to set QoS gates on the CMTS.                               =
   = 3-This figure is a simplificiation of the actual network and  =
   =   servers, which included redundancies and other complexities =
   =   not necessary to depict the functional design.              =
   =================================================================

                                 Figure 3





Bastian, et al.         Expires December 28, 2009              [Page 20]


Internet-Draft     An ISP Congestion Management System         June 2009


6.  Conclusion

   Comcast's transition to this new protocol-agnostic congestion
   management system began in October 2008, and Comcast completed the
   transition on December 31, 2008.  As described above, the new
   approach does not manage congestion by focusing on managing the use
   of specific protocols.  Nor will this approach use TCP "reset
   packets" [RFC3360].  Rather, the new system acts such that (1) during
   periods when a CMTS port is in a Near Congestion State, (2) it
   identifies the subscribers on that port who have consumed a
   disproportionate amount of bandwidth over the preceding 15 minutes,
   (3) it lowers the priority status of those subscribers' traffic to BE
   status until those subscribers meet the release criteria, and (4)
   during periods of congestion, delay BE traffic before PBE traffic is
   delayed.  Our trials and our network-wide deployment indicate that
   this new congestion management system ensures a quality online
   experience for all of our HSI customers.


7.  Exceptional Network Utilization Considerations

   This system was developed to cope with somewhat "normal" occurrences
   of congestion that could occur on virtually any IP network.  It
   should also be noted, however, that such a system could also prove
   particularly useful in the case of "exceptional network utilization"
   events which existing network usage models do not or cannot
   accurately predict.  For example, in the case of a severe global
   pandemic, it may be expected that large swaths of the population may
   need to work remotely, via their Internet connection.  In such a
   case, a largely unprecedented level of utilization may occur.  In
   such cases, it may be helpful to have a flexible congestion
   management system that could adapt to this situation and help
   allocate network resources while additional capacity is being brought
   online or while a temporary condition persists.


8.  Security Considerations

   There are no security considerations in this document.

   NOTE TO RFC EDITOR: PLEASE REMOVE THIS NULL SECTION PRIOR TO
   PUBLICATION.


9.  IANA Considerations

   There are no IANA considerations in this document.




Bastian, et al.         Expires December 28, 2009              [Page 21]


Internet-Draft     An ISP Congestion Management System         June 2009


   NOTE TO RFC EDITOR: PLEASE REMOVE THIS NULL SECTION PRIOR TO
   PUBLICATION.


10.  Acknowledgements

   The authors wish to acknowledge the hard work of the many people who
   helped to develop and/or review this document, as well as the people
   who helped deploy the system in such a short period of time.


11.  Change Log

   NOTE TO RFC EDITOR: PLEASE REMOVE THIS SECTION PRIOR TO PUBLICATION.

   o  v00 2009-06-26 first version published


12.  Open Issues

   NOTE TO RFC EDITOR: PLEASE REMOVE THIS SECTION PRIOR TO PUBLICATION.

   1.  Review the Terminology section, add external references as needed

   2.  Need to add more stable URL references for FCC docs in
       Informative Refs - change from Comcast file locations to FCC file
       locations.

   3.  Change reference in text to draft-p2pi-cooper-workshop-report-01
       to a normal xref once an RFC is issued

   4.  Make the ASCII art a bit smaller (vertically)

   5.  Double-check IPDR references - ensure most recent version of
       standard is referenced (incl. possibly DOCSIS 3.0 reference w/r/t
       IPDR)

   6.  May need to add references to the DOSCIS standard in Section 2.8

   7.  Close out any editorial notes in the document


13.  Informative References

   [CableLabs DOCSIS IPDR Support]
              Yassini, R., "Data-Over-Cable Service Interface
              Specifications - DOCSIS 2.0 - Operations Support System
              Interface Specification", DOCSIS 2.0 CM-SP-OSSIv2.0-C01-



Bastian, et al.         Expires December 28, 2009              [Page 22]


Internet-Draft     An ISP Congestion Management System         June 2009


              081104, November 2008, <http://www.cablelabs.com/
              specifications/CM-SP-OSSIv2.0-C01-081104.pdf>.

   [Comcast IETF P2P Infrastructure Workshop Presentation]
              Livingood, J. and R. Woundy, "Comcast's IETF P2P
              Infrastructure Workshop Presentation on May 28, 2008", FCC
              Filings Comcast Network Management Proceedings, May 2008,
              <http://trac.tools.ietf.org/area/rai/trac/raw-attachment/
              wiki/PeerToPeerInfrastructure/02-Comcast-IETF-P2Pi.pdf>.

   [Comcast P2Pi Position Paper]
              Livingood, J. and R. Woundy, "Comcast's IETF P2P
              Infrastructure Workshop Position Paper", FCC
              Filings Comcast Network Management Proceedings, May 2008,
              <http://trac.tools.ietf.org/area/rai/trac/raw-attachment/
              wiki/PeerToPeerInfrastructure/
              16%20ietf-p2pi-comcast-20080509.pdf>.

   [FCC Filing - Attachment A: Old Congestion Management System]
              Zachem, K., "Attachment A: Comcast Corporation Description
              of Current Network Management Practices", FCC
              Filings Comcast Network Management Proceedings,
              September 2008, <http://downloads.comcast.net/docs/
              Attachment_A_Current_Practices.pdf>.

   [FCC Filing - Attachment B: New Congestion Management System]
              Zachem, K., "Attachment B: Comcast Corporation Description
              of Planned Network Management Practices to be Deployed
              Following the Termination of Current Practices", FCC
              Filings Comcast Network Management Proceedings,
              September 2008, <http://downloads.comcast.net/docs/
              Attachment_B_Future_Practices.pdf>.

   [FCC Filing - Attachment C: Implementation and Compliance Plan]
              Zachem, K., "Attachment C: Comcast Corporation Network
              Management Transition Compliance Plan", FCC
              Filings Comcast Network Management Proceedings,
              September 2008, <http://downloads.comcast.net/docs/
              Attachment_C_Compliance_Plan.pdf>.

   [FCC Filing - Congestion Management Deployment Completion Letter]
              Zachem, K., "Letter to the FCC Advising of Successful
              Deployment of Comcast's New Congestion Management System",
              FCC Filings Comcast Network Management Proceedings,
              January 2009, <http://downloads.comcast.net/docs/
              comcast-nm-transition-notification.pdf>.

   [FCC Filing - Cover Letter]



Bastian, et al.         Expires December 28, 2009              [Page 23]


Internet-Draft     An ISP Congestion Management System         June 2009


              Zachem, K., "Cover Letter to the FCC Regarding Comcast's
              Network Management Techniques", FCC Filings Comcast
              Network Management Proceedings, September 2008,
              <http://downloads.comcast.net/docs/Cover_Letter.pdf>.

   [FCC Memorandum and Opinion]
              Martin, K., Copps, M., Adelstein, J., Tate, D., and R.
              McDowell, "FCC Memorandum and Opinion Regarding Reasonable
              Network Management", File No. EB-08-IH-1518 WC Docket No.
              07-52, August 2008, <http://hraunfoss.fcc.gov/
              edocs_public/attachmatch/FCC-08-183A1.pdf>.

   [I-D.p2pi-cooper-workshop-report]
              Peterson, J. and A. Cooper, "Report from the IETF workshop
              on P2P Infrastructure, May 28, 2008",
              draft-p2pi-cooper-workshop-report-01 (work in progress),
              February 2009.

   [IPDR Standard]
              Cotton, S., Cockrell, B., Walls, P., and T. Givoly,
              "Network Data Management - Usage (NDM-U) For IP-Based
              Services Service Specification - Cable Labs DOCSIS 2.0
              SAMIS", IPDR Service Specifications NDM-U, November 2004,
              <http://www.ipdr.org/public/Service_Specifications/3.X/
              DOCSIS(R)3.5-A.0.pdf>.

   [RFC3083]  Woundy, R., "Baseline Privacy Interface Management
              Information Base for DOCSIS Compliant Cable Modems and
              Cable Modem Termination Systems", RFC 3083, March 2001.

   [RFC3360]  Floyd, S., "Inappropriate TCP Resets Considered Harmful",
              BCP 60, RFC 3360, August 2002.

   [RFC3410]  Case, J., Mundy, R., Partain, D., and B. Stewart,
              "Introduction and Applicability Statements for Internet-
              Standard Management Framework", RFC 3410, December 2002.















Bastian, et al.         Expires December 28, 2009              [Page 24]


Internet-Draft     An ISP Congestion Management System         June 2009


Authors' Addresses

   Chris Bastian
   Comcast Cable Communications
   One Comcast Center
   1701 John F. Kennedy Boulevard
   Philadelphia, PA  19103
   US

   Email: chris_bastian@cable.comcast.com
   URI:   http://www.comcast.com


   Tom Klieber
   Comcast Cable Communications
   One Comcast Center
   1800 Bishops Gate Drive
   Mount Laurel, NJ  08054
   US

   Email: tom_klieber@cable.comcast.com
   URI:   http://www.comcast.com


   Jason Livingood (editor)
   Comcast Cable Communications
   One Comcast Center
   1701 John F. Kennedy Boulevard
   Philadelphia, PA  19103
   US

   Email: jason_livingood@cable.comcast.com
   URI:   http://www.comcast.com


   Jim Mills
   Comcast Cable Communications
   One Comcast Center
   1800 Bishops Gate Drive
   Mount Laurel, NJ  08054
   US

   Email: jim_mills@cable.comcast.com
   URI:   http://www.comcast.com







Bastian, et al.         Expires December 28, 2009              [Page 25]


Internet-Draft     An ISP Congestion Management System         June 2009


   Richard Woundy
   Comcast Cable Communications
   27 Industrial Avenue
   Chelmsford, MA  01824
   US

   Email: richard_woundy@cable.comcast.com
   URI:   http://www.comcast.com











































Bastian, et al.         Expires December 28, 2009              [Page 26]