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Internet Engineering Task Force (IETF)                        C. BastianRequest for Comments: 6057                                    T. KlieberCategory: Informational                                     J. LivingoodISSN: 2070-1721                                                 J. Mills                                                               R. Woundy                                                                 Comcast                                                           December 2010Comcast's Protocol-Agnostic Congestion Management SystemAbstract   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.Status of This Memo   This document is not an Internet Standards Track specification; it is   published for informational purposes.   This document is a product of the Internet Engineering Task Force   (IETF).  It represents the consensus of the IETF community.  It has   received public review and has been approved for publication by the   Internet Engineering Steering Group (IESG).  Not all documents   approved by the IESG are a candidate for any level of Internet   Standard; seeSection 2 of RFC 5741.   Information about the current status of this document, any errata,   and how to provide feedback on it may be obtained athttp://www.rfc-editor.org/info/rfc6057.Copyright Notice   Copyright (c) 2010 IETF Trust and the persons identified as the   document authors.  All rights reserved.   This document is subject toBCP 78 and the IETF Trust's Legal   Provisions Relating to IETF Documents   (http://trustee.ietf.org/license-info) in effect on the date of   publication of this document.  Please review these documents   carefully, as they describe your rights and restrictions with respect   to this document.  Code Components extracted from this document must   include Simplified BSD License text as described in Section 4.e of   the Trust Legal Provisions and are provided without warranty as   described in the Simplified BSD License.Bastian, et al.               Informational                     [Page 1]

RFC 6057           An ISP Congestion Management System     December 2010Table of Contents1. Introduction ....................................................22. Applicability to Other Types of Networks ........................33. Key Terminology .................................................34. Historical Overview .............................................75. Summary .........................................................86. Relationship between Managing Congestion and Adding Capacity ....97. Implementation and Configuration ...............................10      7.1. Thresholds for Determining When a CMTS Port Is in a Near           Congestion State ..........................................14      7.2. Thresholds for Determining When a User Is in an           Extended High Consumption State and for Release from           That Classification .......................................15      7.3. Effect of BE Quality of Service on Users'           Broadband Experience ......................................197.4. Equipment/Software Used and Location ......................218. Conclusion .....................................................239. Exceptional Network Utilization Considerations .................2310. Limitations of This Congestion Management System ..............2411. Low Extra Delay Background Transport and Other Possibilities ..2412. Security Considerations .......................................2413. Acknowledgements ..............................................2514. Informative References ........................................261.  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.   It is important for readers to note that congestion can occur in any   IP network, and, when it does, packets can be delayed or dropped.  As   Bob Briscoe has pointed out on an IETF mailing list, some amount of   packet loss can be normal and/or tolerable, noting "But a single TCP   flow with a round trip time (RTT) of 80 ms can attain 50 Mbps with a   loss fraction of 0.0013% (1 in ~74,000 packets) so there's no need to   try to achieve loss figures much lower than this.  And indeed, ifBastian, et al.               Informational                     [Page 2]

RFC 6057           An ISP Congestion Management System     December 2010   flows aren't bottlenecked elsewhere, TCP will drive the system until   it gets such loss levels.  If, instead, a customer is downloading   five separate 10 Mbps TCP flows still with an 80-ms RTT, TCP will   drive losses up to 1 in ~3,000, or 0.03%, and any lower loss rates   won't be able to improve performance".  As a result, applications and   protocols have been designed to deal with the reality that congestion   can occur in any IP network, the mechanics of which we explain in   detail later in this document.   The purpose of this document is to describe how this example of a   large-scale congestion management system functions.  This is   partially 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.  In addition, it is   hoped that such a document may help inform new work in the IETF, in   the hope that better systems and protocols may be possible in the   future.  Lastly, the authors wish to transparently and openly   document this system, so that there could be no doubt about how the   system functioned.2.  Applicability to Other Types of Networks   Several document reviewers and other IETF participants have pointed   out that, though we refer to functional elements that are specific to   a Data Over Cable Service Interface Specification (DOCSIS)-based   network implementation, this type of congestion management system   could be generally applied to nearly any type of network.  Thus, it   is important for readers to take note of this and take into   consideration that this sort of protocol-agnostic congestion   management system could certainly fit in a wide variety of network   types and implementations.3.  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 (seeSection 7) when reviewing some   of these terms.3.1.  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,Bastian, et al.               Informational                     [Page 3]

RFC 6057           An ISP Congestion Management System     December 2010   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.3.2.  Cable Modem Termination System (CMTS)   A piece of hardware located in a cable operator's local network   (generally in a "headend",Section 3.10) that acts as the gateway to   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.3.3.  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   serve 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 inSection 2.6 of [RFC3083].3.4.  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)   network (Section 3.11) 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, as described in [DOCSIS_MULPI].Bastian, et al.               Informational                     [Page 4]

RFC 6057           An ISP Congestion Management System     December 20103.5.  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 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.3.6.  Comcast High Speed Internet (HSI)   A service/product offered by Comcast for delivering Internet service   over a broadband connection.3.7.  Customer Premise Equipment (CPE)   Any device that resides at the customer's residence, connected to the   Comcast network, whether controlled by Comcast or not.3.8.  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, as noted in [DOCSIS_CM2CPE], [DOCSIS_PHY],   [DOCSIS_MULPI], [DOCSIS_SEC], and [DOCSIS_OSSI].  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.  All DOCSIS-related standards are available to the   public at the CableLabs website, athttp://www.cablelabs.com.3.9.  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.3.10.  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".Bastian, et al.               Informational                     [Page 5]

RFC 6057           An ISP Congestion Management System     December 20103.11.  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, as defined in Section 1.2   of [DOCSIS_MULPI].3.12.  Internet Protocol Detail Record (IPDR)   Standardized technology for monitoring and/or recording subscribers'   upstream and downstream Internet usage data based on their cable   modem.  The data is collected from the CMTS and sent to a server for   further processing.  Additional information is available athttp://www.ipdr.org, as well as [IPDR_Standard] and [DOCSIS_IPDR].3.13.  Optical Node   A component of the HFC network generally located in customers' local   neighborhoods that 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.3.14.  Provisioned Bandwidth   The peak speed associated with a tier of service purchased by a   customer.  For example, a customer with a 105 Mbps downstream and   10 Mbps upstream speed tier would be said to be provisioned with   105 Mbps of downstream bandwidth and 10 Mbps of upstream bandwidth.   This is often referred to as 105/10 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 effort   service that are dependent on a number of variables, many of which   are outside the control of an Internet Service Provider (ISP).  In   general, speeds do not typically exceed a customer's provisioned   speed.  Comcast, however, invented a technology called "PowerBoost"   [PowerBoost_Specification] 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   that may be available in the network at that time.Bastian, et al.               Informational                     [Page 6]

RFC 6057           An ISP Congestion Management System     December 20103.15.  Quality of Service (QoS)   A set of techniques to manage network resources to ensure a level of   performance to specific data flows, as described in [RFC1633] and   [RFC2475].  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.3.16.  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.4.  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 [RFC5594], 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 [COMCAST_P2PI_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_P2PI_PRES] and solicited 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 document [FCC_Memo_Opinion] regarding   how Comcast managed congestion on its High-Speed Internet ("HSI")   network, Comcast disclosed to the FCC [FCC_Net_Mgmt_Response] and the   public additional technical details of the congestion management   system that it intended to and did implement by the end of 2008   [FCC_Congest_Mgmt_Ltr], including the thresholds involved in this newBastian, et al.               Informational                     [Page 7]

RFC 6057           An ISP Congestion Management System     December 2010   system.  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.5.  Summary   Comcast's HSI network has elements that are shared across many   subscribers.  This means that Comcast's HSI customers share upstream   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.Bastian, et al.               Informational                     [Page 8]

RFC 6057           An ISP Congestion Management System     December 2010      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, their packets will not be delayed or dropped so      long as the network segment is not actually congested.  If,      however, the network segment becomes congested, their packets      could be intermittently delayed or dropped.   4. The subscriber's traffic returns to normal priority status once      his or her bandwidth usage drops below a set threshold over a      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.6.  Relationship between Managing Congestion and Adding Capacity   Many people have questioned whether congestion should ever exist at   all, if an ISP was adding sufficient capacity.  There is certainly a   relationship between capacity and congestion.  But there are two   types of congestion that generally present themselves in a network.   The first general type of congestion is regularly occurring and is   the result of gradually increasing traffic levels up to a point where   typical usage peaks cause congestion on a regular basis.  Comcast,   like many ISPs, has a set capacity management process by which   capacity additions are automatically triggered based on certain usage   trends; this process is geared towards bringing additional capacity   to the network prior to the onset of regularly occurring congestion.   As such, capacity is added when needed and before it presents   noticeable effects.  This process is in place since capacity   additions are not instantaneous and in many cases require significant   physical work.   The second general type of congestion is unpredictable congestion,   which can occur for a wide range of reasons.  One example may be due   to current events, where users may be all rushing to access specific   content at the exact same time, and where the systems serving thatBastian, et al.               Informational                     [Page 9]

RFC 6057           An ISP Congestion Management System     December 2010   content may not be able to keep up with demand.  Another example may   be due to a localized disaster, where some network paths have been   destroyed or otherwise impaired, and where many users are attempting   to communicate with one another at traffic levels significantly above   normal.   Thus, in both cases, even with continuous upgrades and constant   investment in additional capacity, the fact remains that network   capacity is not unlimited.  A congestion management system, absent   superior protocol-based solutions that do not currently exist, can   therefore help manage the effects of congestion on users, improving   their Internet experience.7.  Implementation and Configuration   It is important to note that the implementation details below and the   overall design of the system are matched to traffic patterns that   exist on the Internet today and that the authors believe will exist   in the near future.  While the authors desired to make the system   highly adaptable and a good long-term network investment, significant   changes in such traffic patterns may necessitate a change in the   configuration of the system or, in extreme cases, a different type of   system altogether.   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 CMTSs are then connected to higher-level   routers, which in turn are connected to Comcast's Internet backbone   facilities.  Today, Comcast has over 3,200 CMTSs 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 "bondedBastian, et al.               Informational                    [Page 10]

RFC 6057           An ISP Congestion Management System     December 2010   groups", in a DOCSIS 3.0 environment.)  Even without channel bonding,   multiple channels are usually configured to come out of each physical   port.  Said another way, there is generally a mapping of multiple   channels to each physical port.   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, based on current DOCSIS technology).  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 subject to management in this new congestion management system.   Based upon the design of the network and traffic patterns observed,   the most likely place for congestion to occur is on these CMTS ports.   As a result, the congestion management system measures the traffic   conditions of CMTS ports, and applies any policy actions to traffic   on those ports (rather than some other, more distant segment of the   network).   To implement Comcast's new protocol-agnostic congestion management   practices, Comcast purchased new hardware and software that were   deployed near the Regional Network Routers ("RNRs") that are further   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, inSection 7.4.  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 CMTSs 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:Bastian, et al.               Informational                    [Page 11]

RFC 6057           An ISP Congestion Management System     December 2010   Figure 1: Simplified Network Diagram Showing High-Level Comcast   Network and Servers Relevant to Congestion Management                              -------------------------                             /                         \                            | Comcast Internet Backbone |                             \                      -----   +------------+             --------------------/       \   | Congestion |                                /         \   | Management |<+++GigE++++             +---->|  Internet |   |   Server   |           +             |     |  Backbone |   +------------+           +             |      \ Router  /                            +           Fiber     \       /   +------------+           +             |         -----   |    QoS     |           +             |   |   Server   |<+++GigE++++             \/   |            |           +           -----   +------------+           +         /       \                            +        /         \   +------------+           +       |  Regional |   | Statistics |           +++++++>|  Network  |   | Collection |<+++GigE++++       |   Router  |   |   Server   |                    \         /   +------------+     +---Fiber------>\       /<------Fiber----+                      |                 -----                  |                      \/                                       \/                    -----                                     -----                  /       \                                 /       \                 /  Local  \                               /  Local  \                |   Market  |                             |   Market  |                 \  Router /                               \  Router /       +--------->\       /<------------+                   \       /       |            -----               |                    ------       |             /\                 |                       /\     Fiber           |                 Fiber                    |       |           Fiber                |                      Fiber       |             |                  |                       |       \/            \/                 \/                      \/    /------\      /------\           /------\                /------\   |  CMTS  |    |  CMTS  |         |  CMTS  |              |  CMTS  |    \------/      \------/           \------/                \------/       /\            /\                 /\                      /\       |             |                  |                       |      Fiber         Fiber              Fiber                   Fiber       |             |                  |                       |       \/            \/                 \/                      \/Bastian, et al.               Informational                    [Page 12]

RFC 6057           An ISP Congestion Management System     December 2010   +---------+   +---------+       +---------+             +---------+   | 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 significant     +   +  redundancy 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   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 the subscriber noticing.  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" ("PBE") traffic; and (2) "Best   Effort" ("BE") traffic.  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:Bastian, et al.               Informational                    [Page 13]

RFC 6057           An ISP Congestion Management System     December 2010   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 (further validated      in our full deployment), 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 an extended, high      contribution to the bandwidth usage on the particular port,      relative to the service tier they purchased, 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 (further validated in our full deployment), 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.7.1.  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 that are used as part of this   congestion 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, asBastian, et al.               Informational                    [Page 14]

RFC 6057           An ISP Congestion Management System     December 2010   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 as described above, we 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 determined that   the starting point should be approximately 15 minutes (although some   technical limitations in some newer CMTSs 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 packets may be intermittently delayed or dropped   during those congested periods perceive little, if any, effect, as   discussed below.7.2.  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 the number of users sharing a   cable modem, 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.  ThatBastian, et al.               Informational                    [Page 15]

RFC 6057           An ISP Congestion Management System     December 2010   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 50 Mbps downstream and 10 Mbps upstream, then his or her   provisioned downstream speed is 50 Mbps and provisioned upstream   speed is 10 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 an independent 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 (this has been further validated in our full deployment).   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.  Therefore, this is a consumption-based threshold   and not a peak-speed-based threshold.  Thus, the Extended High   Consumption State is not tied to whether a user has bursted once or   more above this 70% threshold for a brief moment.  Instead, it is   consumption-based, meaning that a certain bitrate must be exceeded   over at least the entire User Consumption Duration.   The User Consumption Thresholds have been set sufficiently high that   using the HSI connection for Voice over IP (VoIP), gaming, web   surfing, or most streaming video cannot alone cause subscribers to   our standard-level HSI service to exceed the User Consumption   Threshold.  For example, while one of Comcast's common HSI service   tiers has a provisioned downstream bandwidth of 22 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 percent   of 22 Mbps is 15.4 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   congestion management practices were tested (further validated in our   full deployment), 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, theBastian, et al.               Informational                    [Page 16]

RFC 6057           An ISP Congestion Management System     December 2010   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, i.e., a   situation in which a particular user could cycle repeatedly between   BE and PBE.  Thus, without this lower release criteria, we were   concerned that certain users would oscillate between BE and PBE   states for an extended period, without clear benefit to the system   and other users, and would place an unnecessary signaling burden on   the system.  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 trials, lab testing, and subsequent national   deployment.   Simply put, there are four steps for 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 the next interval.  If user consumption has declined below the      predetermined threshold, reassign the user's traffic as PBE.  If      not, recheck at the next interval.   In cases where a CMTS regularly enters a Near Congestion State, and   where congestion subsequently does occur, but where no users match   the criteria to be classified in an Extended High Consumption State,   this may indicate the congestion observed is regularly occurring,   rather than unpredictable congestion.  As such, this may be an   additional data point in favor of considering whether and when to add   capacity.Bastian, et al.               Informational                    [Page 17]

RFC 6057           An ISP Congestion Management System     December 2010   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   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.               Informational                    [Page 18]

RFC 6057           An ISP Congestion Management System     December 2010 KEY TO FIGURE 2 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               over a period of 15 minutes?    Result #4: Change user's upstream traffic back to Priority Best               Effort (PBE) from Best Effort (BE).                                 Figure 27.3.  Effect of BE Quality of Service on Users' 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 utilization on 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.   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 theBastian, et al.               Informational                    [Page 19]

RFC 6057           An ISP Congestion Management System     December 2010   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.   It is during 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 will only be about one-   tenth of a second.   During times of actual network congestion, when packets from BE   traffic might be intermittently delayed, there is 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.  As a matter of fact, our studies concluded   that the experience of the PBE subscribers improves when this   congestion management system is enabled.  This conclusion is based on   network measurements, such as latency.   NetForecast 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 (further validated in our full   deployment), such a theoretical condition did not occur.  In   addition, our experience with the system as fully deployed in our   production network demonstrates 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 this congestion management system, despite having   broadly publicized these trials.  In our subsequent nationalBastian, et al.               Informational                    [Page 20]

RFC 6057           An ISP Congestion Management System     December 2010   deployment into our production network, we still have yet to find a   specific complaint that can be traced back to the effect of this   congestion management system.   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.7.4.  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 these servers are   not particularly relevant to this document, as this information does   not change the fact that the servers 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, the Alliance for Telecommunications Industry Solutions   (ATIS), the International Telecommunication Union (ITU), and the   Third Generation Partnership Project (3GPP), among others.  The IPDR   software deployed was developed by Active Broadband Networks, and is   noted as the Statistics Collection Server in Figure 3.   The second application server is the Congestion Management server,   which uses the 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.  The Congestion Management server software   deployed was developed by Sandvine.   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.   The PCMM software deployed was developed by Camiant, and is noted as   the QoS Server in Figure 3.Bastian, et al.               Informational                    [Page 21]

RFC 6057           An ISP Congestion Management System     December 2010   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           |               |   +----+---+------+                            +-------+-------+        /\  /\                                          *        |   |    Relay Selected                         *        X   +---Statistics: Bytes---+               QoS Action:        |       Up/Down by Device   |             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            *        |                 Periodically From CMTS        *        X                          |                    *        |              +-----------+-----------+        *        +-X-X-X-X-X-X->|   CMTS in Headend     |<********                       +-----------------------+                          H   /\        /\   H                          H Internet Traffic H                          H  to/from 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 simplification of the actual network and   =   =     servers, which included redundancies and other complexities =   =     not necessary to depict the functional design.              =   ===================================================================                                 Figure 3Bastian, et al.               Informational                    [Page 22]

RFC 6057           An ISP Congestion Management System     December 20108.  Conclusion   Comcast started design and development of this new protocol-agnostic   congestion management system in March 2008.  Comcast shared the   design with the IETF and others in the Internet community, as well as   with an independent consultant, incorporating feedback we received   into the final design.  Following lab testing, the system was tested   in Comcast's production network in trial markets between June and   September 2008.  Comcast's production network transition to this new   protocol-agnostic congestion management system began in October 2008   and was completed on December 31, 2008.   As described herein, the new approach does not manage congestion by   focusing on managing the use of specific protocols.  Nor does this   approach use TCP "reset packets" [RFC3360].  Rather, the system acts   such that during periods when a CMTS port is in a Near Congestion   State, the system (1) identifies the subscribers on that port who   have consumed a disproportionate amount of bandwidth over the   preceding 15 minutes and (2) lowers the priority status of those   subscribers' traffic to BE status until those subscribers meet the   release criteria.  During periods of actual congestion, the system   handles PBE traffic before BE traffic.  Comcast's trials and   subsequent national deployment indicate that this new congestion   management system ensures a quality online experience for all of   Comcast's HSI customers.9.  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 that existing network usage models do not or cannot accurately   predict.  Some network operators refer to these exceptional events as   "surges" in utilization, similar to sudden surges in demand in   electrical power grids, with which many people may be familiar.   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.Bastian, et al.               Informational                    [Page 23]

RFC 6057           An ISP Congestion Management System     December 201010.  Limitations of This Congestion Management System   The main limitations of the system include:   o  The system is not an end-to-end congestion management system, nor      does it enable one.   o  The system does not signal the presence of congestion to user      applications or to all devices on the network path.   o  The system does not explicitly enable additional user and/or      application responses to congestion.   o  The system does not enable distributed denial-of-service (DDoS)      mitigation or other capabilities.11.  Low Extra Delay Background Transport and Other Possibilities   There are several new IETF working group efforts that are focused on   the question of congestion and its effects, avoiding congestion,   managing congestion, and communicating congestion information.  This   includes the Congestion Exposure (CONEX) working group, the   Application Layer Transport Optimization (ALTO) working group, and   the Low Extra Delay Background Transport (LEDBAT) working group.   Should one or more of these working groups be successful in producing   useful work, it is possible that the design or configuration of the   system documented here may need to change.  For example, this   congestion management system does not currently have a way to take   into account differing classes of data transfer, such as a class of   data transfer that LEDBAT may specify, which may better yield to   other traffic than existing transport protocols.  In addition, CONEX   may specify methods for this or other systems to signal congestion   state or expected congestion to other parts of the network, and/or to   hosts on either end of a particular network flow.  Furthermore, it is   conceivable that the result of current or future IETF work could   obviate the need for such a congestion management system entirely.12.  Security Considerations   It is important that an ISP secure access to the Congestion   Management servers and the QoS Servers, as well as QoS signaling to   the CMTSs, so that unauthorized users and/or hosts cannot make   unauthorized changes to QoS settings in the network.   It is also important to secure access to the Statistics Collection   Server since this contains IPDR-based byte transfer data that is   considered private by end users on an individual basis.  In addition,   this data is considered ISP-proprietary traffic data on an aggregateBastian, et al.               Informational                    [Page 24]

RFC 6057           An ISP Congestion Management System     December 2010   basis.  Access to the Statistics Collection Server should also be   secured so that false usage statistics cannot be fed into the system.   It is important to note that IPDR data contains a count of bytes sent   and bytes received, by cable modem MAC address, over a given interval   of time.  This data does not contain things such as the source and/or   destination Internet address of that data, nor does it contain the   protocols used, ports used, etc.13.  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.   The authors also wish to acknowledge the following individuals for   performing a detailed review of this document and/or providing   comments and feedback that helped to improve and evolve this   document:   - Kris Bransom   - Bob Briscoe   - Lars Eggert   - Ari Keranen   - Tero Kivinen   - Matt Mathis   - Stanislav ShalunovBastian, et al.               Informational                    [Page 25]

RFC 6057           An ISP Congestion Management System     December 201014.  Informative References   [COMCAST_P2PI_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>.   [COMCAST_P2PI_PRES]               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>.   [DOCSIS_CM2CPE]               CableLabs, "Data-Over-Cable Service Interface               Specifications - DOCSIS 3.0 - Cable Modem to Customer               Premise Equipment Interface Specification", DOCSIS               3.0 CM-SP-CMCIv3-I01-080320, March 2008,               <http://www.cablelabs.com/cablemodem/specifications/specifications30.html>.   [DOCSIS_IPDR]               Yassini, R., "Data-Over-Cable Service Interface               Specifications - DOCSIS 2.0 - Operations Support System               Interface Specification", DOCSIS 2.0 CM-SP-OSSIv2.0-C01-               081104, November 2008, <http://www.cablelabs.com/cablemodem/specifications/specifications30.html>.   [DOCSIS_MULPI]               CableLabs, "Data-Over-Cable Service Interface               Specifications - DOCSIS 3.0 - MAC and Upper Layer               Protocols Interface Specification", DOCSIS 3.0 CM-SP-               MULPIv3.0-I11-091002, October 2009, <http://www.cablelabs.com/cablemodem/specifications/specifications30.html>.   [DOCSIS_OSSI]               CableLabs, "Data-Over-Cable Service Interface               Specifications - DOCSIS 3.0 - Operations Support System               Interface Specification", DOCSIS 3.0 CM-SP-OSSIv3.0-I10-               091002, October 2009, <http://www.cablelabs.com/cablemodem/specifications/specifications30.html>.Bastian, et al.               Informational                    [Page 26]

RFC 6057           An ISP Congestion Management System     December 2010   [DOCSIS_PHY]               CableLabs, "Data-Over-Cable Service Interface               Specifications - DOCSIS 3.0 - Physical Layer               Specification", DOCSIS 3.0 CM-SP-PHYv3.0-I08-090121,               January 2009, <http://www.cablelabs.com/cablemodem/specifications/specifications30.html>.   [DOCSIS_SEC]               CableLabs, "Data-Over-Cable Service Interface               Specifications - DOCSIS 3.0 - Security Specification",               DOCSIS 3.0 CM-SP-SECv3.0-I11-091002, March 2008, <http://www.cablelabs.com/cablemodem/specifications/specifications30.html>.   [FCC_Congest_Mgmt_Ltr]               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://fjallfoss.fcc.gov/ecfs/document/view?id=6520192582>.   [FCC_Memo_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>.   [FCC_Net_Mgmt_Response]               Zachem, K., "Letter to the FCC Regarding Comcast's               Network Management Practices", FCC Filings Comcast               Network Management Proceedings, September 2008, <http://fjallfoss.fcc.gov/ecfs/document/view?id=6520169715>.   [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>.Bastian, et al.               Informational                    [Page 27]

RFC 6057           An ISP Congestion Management System     December 2010   [PowerBoost_Specification]               Comcast Cable Communications Management LLC, "Comcast               PowerBoost Specification", Website Comcast.com,               June 2010, <http://customer.comcast.com/Pages/               FAQListViewer.aspx?topic=Internet&               folder=8b2fc392-4cde-4750-ba34-051cd5feacf0>.   [RFC1633]   Braden, B., Clark, D., and S. Shenker, "Integrated               Services in the Internet Architecture: an Overview",RFC 1633, June 1994.   [RFC2475]   Blake, S., Black, D., Carlson, M., Davies, E., Wang, Z.,               and W. Weiss, "An Architecture for Differentiated               Services",RFC 2475, December 1998.   [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.   [RFC5594]   Peterson, J. and A. Cooper, "Report from the IETF               Workshop on Peer-to-Peer (P2P) Infrastructure, May 28,               2008",RFC 5594, July 2009.Bastian, et al.               Informational                    [Page 28]

RFC 6057           An ISP Congestion Management System     December 2010Authors' 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   1306 Goshen Parkway   West Chester, PA  19380   US   EMail: tom_klieber@cable.comcast.com   URI:http://www.comcast.com   Jason Livingood   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   Richard Woundy   Comcast Cable Communications   27 Industrial Avenue   Chelmsford, MA  01824   US   EMail: richard_woundy@cable.comcast.com   URI:http://www.comcast.comBastian, et al.               Informational                    [Page 29]

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