Friday, 19 December 2008 15:32

Aussie System Admin Guild says NO to net filtering

The System Administrators Guild of Australia (SAGE-AU) has sent an open letter to Australia’s Minister for Communications, stating that it is “unable to support the Federal Government’s proposed Internet filtering initiative”, explaining the reasons why and outlining its “significant concerns”.

More opposition has emerged in the face of the Australian Government’s plan to filter and censor the Internet for Australia’s citizens in the form of an open letter to Australia’s Minister for Communications, Senator Stephen Conroy, the chief proponent of the dastardly censorship plan.

The letter is from the System Administrator’s Guide of Australia (SAGE-AU) and is as follows:

Open letter from SAGE-AU to Minister for Broadband, Communications and the Digital Economy, Stephen Conroy

December 18, 9008

The Hon. Senator Stephen Conroy

Minister for Broadband, Communications and the Digital Economy
Parliament House, Canberra

Dear Minister:

Re. SAGE-AU opposition to the proposed Internet filtering initiative

As the representative organisation for Australian system administrators, SAGE-AU is writing to state that it is unable to support the Federal Government’s proposed Internet filtering initiative and to outline the significant concerns that inform SAGE-AU’s position on this issue.

The System Administrators Guild of Australia (SAGE-AU) represents professional system administrators across Australia. System administrators are the technical people behind commercial networks and computing systems, large and small.  Accordingly, we believe SAGE-AU is in an excellent position to contribute to the discussion of the technical issues with your Department's proposed network filter.  Our Code of Ethics [1] requires that we communicate with users regarding computing issues likely to affect them; and thus we feel it essential that we explain these issues to you.  We trust that you will find this letter helpful.

The proposed Internet filter cannot achieve its stated goal

In summary, the current proposals -- to be trialled by commercial ISPs including Optus [2] for potential mandatory implementation -- cannot and will not achieve the stated goal of providing safer Internet access for all Australians.  Moreover, the trial, and any subsequent implementation, cannot and will not have any impact on any illegal activities being undertaken on the Internet.

There are several inherent flaws with the filters as proposed.  The evidence of this is in the Australian Communications and Media Authority's own report on the matter [3].  The ACMA noted that filters were incapable of dealing with traffic utilising communication protocols other than HTTP (traditional "web" traffic).  However, several major Internet Service Providers report that HTTP traffic now consists of less than 50 per cent of a typical day's Internet use).  There are also concerns with the performance of the filters, both in terms of reliability, and in terms of speed.

Fast-functioning filters block one in 12 legitimate websites

The worst performing in terms of filtering capability were the fastest in terms of network traffic throughput; the fastest resulted in a two per cent slowdown under test conditions, but blocked eight per cent - or one in twelve - of the legitimate websites tested.  This level of unreliability would result in every Australian Internet user being denied access to legitimate websites on a daily basis.  This filter also failed to detect twelve per cent of the illegal content against which it was tested; an unacceptably large failure rate if the intention is to stop access to illegal or unwanted content.

Slow filters decrease Internet speeds by as much as 87 per cent

The converse is also true.  The most effective filter decreases performance against the baseline by 87 per cent.  This is an unacceptable performance reduction for modern Internet users.  However, even this filter was still unable to detect three per cent of the illegal content presented to it, and blocked one per cent of the legitimate websites presented to it.

An application of Bayes' Theorem, shows that even for the most generous interpretation of the filters' accuracy, the chance of a randomly selected page actually containing unwanted material when it is blocked is only 55%; the remaining blocked pages will be collateral damage and contain no such illegal material. [4]

DBCDE testing mechanisms do not reflect actual patterns of internet use

The testing mechanisms proposed [5] by the Department of Broadband, Communications, and the Digital Economy are also of concern.  These methods do not reflect the use patterns of the regular Internet-using population, so the results are unlikely to be unrepresentative.

The testing framework also explicitly ignores connection speeds above 12Mbps.  This is troubling, as your Government's own Next-Generation Broadband Network plans call for 12Mbps or faster connection speeds to 98 per cent of Australians; failing to test the filter under these conditions is short-sighted at best.

The letter from SAGE-AU to Australia's Minister for Communications, Senator Stephen Conroy, continues on page 2. Please read on.

The testing framework further fails to adequately address the following questions:

1.    Exactly how much performance degradation, both in terms of added latency and reduced bandwidth would be considered "acceptable" for the purposes of the trial?

2.    Exactly which protocols are to be inspected and potentially blocked by the filter, and under what circumstances?

3.    During the trial, will there be any method of community oversight of the blocking lists to ensure that unreasonable overblocking is not occurring? If a plan for oversight exists, exactly who will be involved in this oversight?

4.    What recourse will exist for businesses and other website holders who host legitimate and "wanted" content when it is found that their sites are being blocked?

5.    For both the purposes of this trial and for any future filtering, will website owners be notified of their inclusion in the "unwanted" or "not safe for children" lists?

6.    If a business or other website owner suspects that their website is mistakenly being blocked, is there (or will there be) a way to confirm it?  Will there be a method to resolve matters such that such pages (if legitimate) are no longer blocked?

7.    For any user trials, will there be a way to distinguish between a site being unavailable due to other issues and a site being unavailable due to it being blocked?  Will there be a way for any user to request that a page that is being blocked be reconsidered for such cases where the page may be misclassified?

8.    Can you define "unwanted content" and promise that any filter will not be subject to scope-creep where "unwanted content" expands to cover more and more things without public input?

9.    What criteria will be utilised to determine the success or otherwise of this trial?

Problems with filter list maintenance

SAGE-AU also has concerns about how the filtering list will be maintained.  On one hand, illegal website owners are suspected of changing their internet information regularly to avoid being found by law enforcement, so the list will need to be updated daily - in some cases, hourly - in order to be effective.  On the other hand, due to the list's exemption from Freedom of Information requests and other public review, no mechanism exists to ensure that legal and child-safe sites are not accidentally blocked.  In fact, website owners will be unable to confirm whether website issues are due to the filter or other technical reasons.

The test framework refers to the blacklist as containing a "majority of [...] material that would likely be classified RC by the Classification Board", but does not state whether the Classification Board will have input into the filtered content's actual classification level.

SAGE-AU suggests alternative use of funds allocated for proposed Internet filtering system

None of these issues have, to date, been addressed by the Department of Broadband, Communications, and the Digital Economy, by the Australian Communications and Media Authority or by Enex TestLab as appropriate.  As such, SAGE-AU cannot support the proposed trial or any future implementation of this style of mandatory filtering scheme.

We instead suggest that a better use of public monies earmarked to fund any trial or future implementation, would instead available to the Australian Federal Police, specifically the Online Child Sex Exploitation Team and/or the Australian High-Tech Crime Centre.  

Rather than unsuccessfully attempting to filter undesirable material in transit, it would be a more effective use of public funds to support law enforcement in preventing the creation and consumption of this material at its end points, just as is the case for all traditional carriage services.

We, and our members, look forward to your reply.

Yours faithfully

Donna Ashelford
on behalf of SAGE-AU and the SAGE-AU Committee of Management
SAGE-AU Code of Ethics. 
Accessed Sunday, 7 December, 2008 from SAGE-AU web site:

Optus, iiNet put filters to the test. 
Accessed Saturday, 6 December, 2008 from
Computerworld web site:

Closed Environment Testing of ISP-Level Internet Content Filtering. 
Accessed Friday, 24 October, 2008 from ACMA web site:

Bayes' Theorem 1, Mandatory Filtering 0. 
Accessed Monday, 8 December 2008:

Testing Framework. 
Accessed Monday, 8 December, 2008 from DBCDE web site:


That’s the letter in full, and this open letter from SAGE-AU is yet another nail in the coffin for consensus on the Internet censorship issue.

In short, no-one wants it, except those who seek to brand all who oppose it as “child pornographers”, which is simply an outrage.

Free thinking Australians will not put up with censorship. There may well have been jokes about Australia’s Prime Minister Kevin Rudd being “Chairman Rudd” in the style of Chairman Mao.

How horrific for Australia if it actually were to come true.

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