Tony Pearson is a Master Inventor and Senior IT Architect for the IBM Storage product line at the
IBM Executive Briefing Center in Tucson Arizona, and featured contributor
to IBM's developerWorks. In 2016, Tony celebrates his 30th year anniversary with IBM Storage. He is
author of the Inside System Storage series of books. This blog is for the open exchange of ideas relating to storage and storage networking hardware, software and services.
(Short URL for this blog: ibm.co/Pearson )
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In his blog Rough Type, Nick Carr asks Where is my CloudBook?and points to John Markoff's 2-part series in the New York Times on computing in the clouds.(Read it here: Part 1, Part 2)
At first, I thought he meant computing while in an airplane, but instead, he is talking about computing on a laptop or other hand-held device that does not have an internal disk drive, no installedoperating system, no internal data storage. Instead, the idea is that you boot from a CD, accessyour data, and even some of your programs, over the internet. John used an Ubuntu Linux LiveCD in his example.
This week, I am in Sao Paulo, Brazil, and was "in the clouds" for over 10 hours flying from Dallas to here.The one time I am guaranteed "off-line" from the internet is on the plane, and I spend enough time on planesthat I am able to get work done despite being "disconnected".
The same reasons people want to get out of having a disk drive on their laptop, are the reasons data centersare getting out of internal disk on their servers.
disks crash, and typically are not protected in any RAID configuration on most laptops
operating systems get infected with viruses and malware
storage on one server is generally inaccessible to every other server
Booting from CD is especially clever. No more worrying about fixing your Windows registry, viruses,corrupted operating system files, or the cruft that accumulates on your C: drive that slowsyou down. The CD is the sameevery time, so it is like running your system with a freshly installed operating system every day.
The need for central repositories of data harkens back to the years of the IBM mainframe. Of course, whatmade sense back then continues to make sense now. The old 3270 terminals stored no data, and instead merelyprovided keyboard input and display text screen output to the vast amount of data stored on the central system.Today, the inputs are different, using your finger or mouse instead to point to what you want, sliding itacross to make things happen, and the output may now include photos, audio and video, but the concept isstill the same.
I carry my Ubuntu Linux LiveCD with me on every business trip. Combined with externally rewriteable media,such as a USB key, you can get work done even when you are in an airplane, and upload it whenyou are back on the net.
The IBM Storage and Storage Networking Symposium concludes today. As typical for manysuch conferences, it ended at noon, so that people can catch airline flights.
TS1120 Tape Encryption - Customer Experiences
Jonathan Barney had implemented many deployments of tape encryption, and shared hisexperiences at two customer locations.
The first company had decided to implement their EKM servers on dedicated 64-bitWindows servers. They had three sites, one in Chicago, Alphareta, and New York City,each with two EKM servers. Each library had a single TS3500 tape library, and pointedto four EKM servers, two local, and two remote.
The clever trick was managing the keystore. They decided that EKM-1 was their trustedsource, made all changes to that, and then copied it to the other five EKM servers.His team deployed one site at a time, which turned out to be ok, but he would notrecommend it. Better to design your complete solution, and make sure that all librariescan access all EKM servers.
This company decided to have a single key-label/key-pair for all three locations, but change it every 6 months. You have to keep the old keys for as long as you have tapesencrypted with those keys, perhaps 10-20 years.The customer found the IBM encryption implementation "elegant" and it can be easily replicated to a fourth site if needed.
The second company had both z/OS and Sun Solaris. Initially they planned to have botha hardware-based keystore on System z, and software-based keystore on Sun, but they realized that System z version was so much more secure and reliable, that it made nosense to have anything on the Sun Solaris platform.
On System z, they had two EKM images, and used VIPA to ensure load balancing fromthe library. Tapes written from z/OS used DFSMS Data Class to determine which tapesare encrypted and which aren't. All Tapes written from Sun Solaris were encryptied, written to a separate logical library partition of the TS3500, which in turn contactedthe System z for the EKM management to provide the keys to use for the encryption.
The "gotcha" for this case was that when they tested Disaster Recovery, they had torecover the two EKM servers first, before any other restores could take place, and thistook way too long. Instead, they developed a scaled-down 10-volume "rescue recovery" z/OS image that would contain the RACF database and all EKM related software to actas the keystore during a disaster recovery. Anytime they make updates, they only haveto dump 10 volumes to tape. Restore time is down to only 2 hours.
He gave this advice to deploy tape encryption:
Some third party z/OS security products, like Computer Associates Top Secret orACF2, require some PTFs to work with the EKM. The latest IBM RACF is good to go.
Getting IP support from IOS to OMVS requires IPL.
At one customer, an OMVS monitor software program killed the EKM because it wasn'tin their list of "acceptable Java programs". They updated the list and EKM ran fine.
DO not update EKM properties file while EKM is running. EKM keeps a lot of stuffin memory, and when it is recycled, copies this back to the EKM properties file, reversing any changes you may have done. It is best to shut down EKM, update theproperties file, then start up EKM back up again. This is why you should always haveat least two EKM servers for redundancy.
TSM for Linux on System z
Randy Larson from our Tivoli group presented this session.There is a lot of interest in deploying IBM Tivoli Storage Manager backup and archivesoftware on Linux for System z. Many customers are already invested in a mainframeinfrastructure, may have TSM for z/OS or z/VM, and want the newer features and functions that are available for TSM on Linux.
TSM has special support for Lotus Domino, Oracle, DB2 and WebSphere Application Servers.TSM clients can send backup data to a TSM server internally via Hipersockets, a virtualLAN feature on the System z platform that uses shared memory to emulate TCP/IP stack.
One of the big questions is whether to run Linux as guests under z/VM, or natively onLPAR. The general deployment is to carve an LPAR and run Linux natively untilyour server and storage administration staff have taken z/VM training classes. Oncetrained, they can easily move native LPAR images to z/VM guests. Unlike VMware that takesa hefty 40% overhead on x86 platforms to manage guests, z/VM only takes 5-10% overhead.
For the TSM database and disk storage pools, Randy recommends FC/SCSI disk, with ext3 file system, combined with LVM2 into logical volumes. ECKD disk and reiserfsworks too. Avoid use of z/VM minidisks. Under LVM2, consider 32KB stripes for the TSM database, and 256KB stripes for the disk storage pools. For multipathing, usefailover rather than multibus method. Read IC45459 before you activate "directio".
The TSM for Linux on z is very much like the TSM on AIX or Windows, and not like theTSM for z/OS. For tape, TSM for Linux on z does not support ESCON/FICON attached tape,you need to use FC/SCSI attached tape and tape libraries. TSM owns the library anddrives it uses, so give it a logical library partition separate from z/OS. ForSun/StorageTek customers, TSM works with or without the Gersham Enterprise Distrbu-Tape(EDT) software. Use the IBM-provided drivers for IBM tape. For non-IBM tape, TSM providessome drivers that you can use instead.
That wraps up my week. This was a great conference! If you missed it, look for the one in Montpelier, France this October. Check out the list of IBM Technical Conferencesto find others that might interest you.
The IBM Storage and Storage Networking Symposium continues ...
DS8300 Benchmark for Global Mirror
Phil Allison of Fidelity National Information Services presented his success switching from competition over to IBM DS8300 disk systems for use with Global Mirror. They had usedPerformance Associates famous PAIO driver to help to the benchmarktesting. They ran the benchmars at 2x and 3x their current workloads to see how well the DS8000 performed,measuring IOPS, MB/sec, and millisecond response time (msec). They were very impressed with their results,staying below their target 0.8 msec for most of their runs.
For the Global Mirror, the did a performance "bake-off" between Ciena CN2000 versus Cisco 9216i. These areimplemented differently. Ciena uses a Layer-2 approach, encapsulating the Fibre Channel packets directlyto transport as SDH/SONET or Gigabit Ethernet (GigE), which required dedicated circuits between JacksonvilleFlorida and Little Rock, Arkansas. By contrast, Cisco uses a Layer-3 approach, encapsulating Fibre Channelpackets within an IP packet, which can leverage existing datacenter-to-datacenter backbone.
To add stress to the benchmarks, they used a "Network Impairment" emulator. These artificially inject errors,lose packets, and other signal loss conditions. Running both Cisco and Ciena under these tests help them decide which to purchase, but also enforced that idea that they made the right choice choosing IBM for theirremote distance mirroring solution.
Comparison of Bare Machine Recovery Techniques
"Bare machine recovery" is the phrase used to restore a machine that has no operating system installed (or thewrong operating system). Dave Canan from IBM Advanced Technical Support did a great job reviewing the variousproducts and techniques available, and the pros and cons of each approach. The ones he covered were:
Tivoli Storage Manager - install fresh Windows Operating System, TSM client, and then follow certain steps
Automated System Recovery(ASR) - a new feature of Windows XP and Windows 2003 works with TSM client
Symantec Ghost - formerly callled PowerQuest Drive Image, there are now two versions: Ghost Home Edition and Ghost Corporate Solution Suite
Cristie Bare Machine Recovery(CBMR) - This is an IBM partner that provides both Linux and Windows PE versions. Cristie includes a license for Windows PE, so no need to use the alternative Bart PE method.
SAN Volume Controller - Customer Experience
Bill Giles of Catholic Medical Center, a hospital in New Hampshire, presented his experienceswith IBM System Storage SAN Volume Controller. They have a mix of IBM System x, System p, andSystem i servers, as well as machines from HP, Sun, and Dell. For applications, they havePicture Archiving and Communicatiion System (PACS) for cardiology and radiology, HL7 Interface engine, Clinical Information System, TSM for backup, and Microsoft Exchange fore-mail.
They deployed SVC on AIX, Solaris, Windows 2000 and 2003. They were very delightedwith the results:
Centralized Storage Provisioning
Consolidating disparate storage into a universal platform
Enables non-disruptive data migration
Increased utilization of existing disk resources
Improved disaster recovery with FlashCopy and Metro Mirror
Birds of a Feather (BOF) sessions
We had two BOFs, one for storage attached to System z operating systems, and another for storage attached to Linux, UNIX and Windows systems. This distinctionmade sense when mainframes could only attach to CKD disks and ESCON/FICON tape,and distributed systems could only do FCP/SCSI, but these days, there are all kindsof convergence going on.
Linux on System z can now attach via FCP to LTO tape and SAN Volume Controller, allowing now a wide range of storage options for that platform. z/OS, z/VM, z/VSEand Linux on System z can all access IBM System Storage N series via NFS.
The format was traditional Q&A panel, we had experts at the front of the room,handling the questions and discussion topics brought up by the audience. I'll spareyou the individual questions and answers.
The IBM Storage and Storage Networking Symposium in Las Vegas continues ...
N series and VMware
Jeff Barnett presented how VMware manages disk image files in its VMfs repository, and how N series offersa better alternative. Virtual machines can access N series volumes directly.
Business Continuity with System i
Allison Pate presented the various Business Continuity options for System i. Many customersuse internal storage for System i, but this then hampers Business Continuity efforts. Instead,you can have IBM System Storage DS8000 or DS6000 series disk systems provide disk mirroringbetween clustered systems.
There was a lot of interest in DR550, one of our many compliance storage solutions. Ron Henkhauspresented an overview of our DR550 and DR550 Express offerings. Unlike the competitive disk-onlysolutions, such as the EMC Centera, the DR550 allows you to attach an automated tape library, managing large amounts of fixed content data at a much lower cost point. It also has encryption, for both diskand tape data.
Open Systems Disk Management
Siebo Friesenborg presented the various steps needed to troubleshoot performance problemswith open systems, including the use of "iostat" on AIX systems as an example, and the stepsyou can take to make formal Service Level Agreements (SLA) between the IT department and thevarious lines of business.
IBM Encryption - TS1120 and LTO-4 encryption comparison
Tony Abete presented TS1120 and LTO-4 encryption techniques. Deploying encryption is more thanjust choosing a tape drive. There are a variety of factors involved, such as whether to managethe keys from the application, the operating system, or the library manager. You need policiesto decided when to encrypt tapes and when not to, generating your keys, storing them, and sharingthem with your business partners, suppliers and service providers with which you send tapes.
I can tell that many people are feeling like they are "drinking from a firehose".IBM's success in storage reaches out to so many different aspects of information management,a variety of industries, and disciplines as varied as regulatory compliance and medical imaging.
Registration is now open for our next "Meet the Storage Experts" event in Second Life. All IBMers, clients and IBM Business Partners are welcome to attend. We will focus this time on DS3000 and N series disk systems, tape systems,and IBM storage networking gear.
The blog team is working on re-directs for those who don't see this in time. Depending on which RSS feed reader you use, you may need to unsubscribe/re-subscribe to re-activate. You can updatethe URL for the feed to one of these:
Continuing this week in Las Vegas, we had a great set of sessions today.
Fibre Channel Overview
I like the manner in whichJim Robinson presented this "basics" session on how Fibre Channel works, why it is spelled "Fibre" not "Fiber", and how all the different layers work in the protocol.
IBM Virtualization Engine TS7700 series
Jim Fisher from the IBM Tucson lab presented the TS7700 series, which replaces our Virtual Tape Server (VTS). Hehad performance numbers to show that it was faster in various measurements against the B20 model of the VTS. Itis supported on the z/OS, z/VM, z/VSE, TPF and z/TPF operating systems.
IBM E-mail Archiving and Storage solution
Ron Henkhaus provided an overview of IBM's E-mail Archive and Storage appliance. The solution combines IBM BladeCenter server blade, DS4200 serieswith SATA disk, and pre-installed software: IBM Content Manager, IBM Records Manager, IBM CommonStore for Lotus Domino and Microsoft Exchange, and IBM System Storage Archive Manager. Services are included to get it connected toyour e-mail environment.
Lee La Frese from our Tucson performance lab presented various performance featuresof the IBM System Storage DS8000 series, and how they compare to competition.
First, some interesting statistics.
Back in 2002, the average high-end EnterpriseStorage Server (ESS) model F20 was configured only for 4 Terabytes (TB). In 2004,the average ESS was up to 12 TB. Today, the average DS8100 is 17.4 TB and the averageDS8300 is 41.5 TB.
51 percent of DS8000 series are configured for FCP only (Linux, UNIX, Windows, i5/OS),35 percent FICON only (System z mainframe), and 14% have both mixed.
Average I/O density has stabilized to about 0.6 IOPS per GB. This means that for everyTB of business data, you can expect most applications to issue 600 Input/Output requestsper second.
While IBM SAN Volume Controller has the fastest SPC-1 and SPC-2 benchmarks, the DS8000also has good results. Looking at just the monolithic "scale-up" systems, DS8000 hasthe fastest SPC-1, and second place for SPC-2.
Compared against the EMC DMX-3, the IBM DS8000 series has superior performance.For example, comparing 2Gbps port performance on each, DMX-3 is able to do 20 IOPS perport, compared to DS8000 with 38 IOPS per port.Compared against HDS USP, the response time for 60,000 IOPS for HDS averaged 10.5 milliseconds (msec), compared to IBM DS8000 less than 6.5 msec.
There are some unique features of the DS8000 to optimize performance. Two areAdaptive Multi-stream Prefetching (AMP) which helps improve processing of databasequeries, and HyperPAV which helps on mainframe workloads.
For FATA disks, performance of sequential reads and writes is only 20 percent less than15K RPM FC disks, but a whopping 50 percent less for random access. Consider using FATAfor audio/video streaming, surveillance data, seismic recordings, and medical imaging.
Comparing 146GB 10K versus 300GB 15K from a capacity perspective was interesting.37TB of 300GB 15K had 20 percent better response time, but 25 percent less maximum throughput,than 37TB of 146GB drives. Depending on your workload, this can help decided which youchoose.
Lee also covered RAID rebuild performance. When an individual HDD fails that is part of a RAIDgroup, the DS8000 performs a rebuild onto a spare drive. A RAID-5 rebuild is processedat 52 MB/sec, compared to RAID-10 at 56 MB/sec. Rebuild processing is low priority,so any other workload will take higher priority to avoid impacting application performance.Compared to EMC, the IBM DS8000 can rebuild RAID-5 73GB 15K RPM drive in only 24 minutes, but it takes 37 minutes to do this on a DMX-3. That is 13 minutes of additional exposure where a second drive failure might cause you to lose all your data in that RAID group!
N series ILM and Business Continuity
James Goodwin from our Advanced Technical Support team presented IBM System Storage N series featuresthat relate to ILM and Business Continuity. He covered features like SnapShot, SnapLock,SnapVault and LockVault.
I have arrived safely in Las Vegas for the IBM System Storage and Storage Networking Symposium. This eventis held once every year. The gold sponsors were: Brocade, Cisco, Finisar, Servergraph, and VMware. Our silversponsor was Qlogic.
I presented IBM's System Storage strategy and an overview of our product line. For those who missed it,our strategy is focused on helping customers in four key areas:
Optimize IT - to simplify and automate your IT operations and optimize performance and functionality, through server/storage synergies, storage virtualization, and intergrated storage infrastructure management.
Leverage Information - to enable a single view of trusted business information through data sharing, and to get the most value from information through Information Lifecycle Management (ILM).
Mitigate Risk - to comply with security and regulatory requirements, and keep your business running with a complete set of business continuity solutions. IBM offers a range of non-erasable, non-rewriteable storage, encryption on disk and tape, and support for IT Infrastructure Library (ITIL) service management disciplines.
Enable Business Flexibility - to provide scalable solutions and protect your IT investment through the use of open industry standards like Storage Networking Industry Association (SNIA) Storage Management Initiative Specification (SMI-S). IBM offers scalability in three dimensions: Scale-up, Scale-out, and Scale-within.
IBM has a broad storage portfolio, in seven offering categories:
Disk Systems, including our SAN Volume Controller, DS family, and N series.
Tape Systems, including tape drives, libraries and virtualization.
Storage Networking, a complete set of switches, directors and routes
Infrastructure Management, featuring the IBM TotalStorage Productivity Center software
Business Continuity, advanced copy services and the software to manage them
Lifecycle and Retention, our non-erasable, non-rewriteable storage including DR550, N series with SnapLock, and WORM tape support, Grid Archive Manager and our Grid Medical Archive Solution (GMAS)
Storage Services, everything from consulting, design and deployment to outsourcing and hosting.
I could talk all day on this, but given that the room was packed, every seat taken and the rest of the audience standing along the walls, I had to keep it down to one hour.
SAN Volume Controller Overview
I presented an overview of the IBM System Storage SAN Volume Controller (SVC), IBM's flagship disk virtualizationproduct. Rather than giving a long laundry list of features and benefits,I focused on the five that matter most:
Reduces the cost and complexity of managing storage, especially for mixed storage environments
Simplifies Business Continuity through non-disruptive data migration and advanced copy services
Improves storage utilization, getting more value from the storage hardware you already have
Enhances personnel productivity, empowering storage administrators to get their job done
Delivers high availability and performance
SAN Volume Controller - Customer Success Stories
A good part of this conference are presented by non-IBMers, which include Business Partners and clientssharing their experiences. In this session, we had two speakers share their experiences with SVC.
David Snyder keeps over 80 web sites online and available. His digital media technologiesteam uses SVC to make their storage administration easier, and ensure high availability for web site content creation and publishing.
Mark Prybylski manages storage at his company, a financial bank. His storage management team uses SVC Global Mirror which provides asynchronous disk mirroring between different types of disk, as part oftheir Business Continuity/Disaster Recovery plan.
The last session I attended was "Storage .. to Optimize your ECM depoloyments" by Jerry Bower, now working for IBM as part of our recent acquisition of the Filenet company. ECM stands for Enterprise Content Management, and IBM is the market leader in this space. Jerry gave a great overview of IBM Content Manager software suite, our newly acquired Filenet portfolio, and the storage supported.
After the sessions was a reception at the Solution Center with dozens of exhibitor booths. For example,Optica Technologies had their PRIZM productswhich are able to connect FICON servers to ESCON storage devices.
I am back at "the Office" for a single day today. This happens often enough I need a name for it.Air Force pilots that practice landing and take-offs call them "Touch and Go", but I think I needsomething better. If you can think of a better phrase, let me know.
This week, I was in Hartford, CT, Somers, NY and our Corporate Headquarters in Armonk, in a varietyof meetings, some with editors of magazines, others with IBMers I have only spoken to over the phone andfinally got a chance to meet face to face.
I got back to Tucson last night, had meetings this morning in Second Life, then presented "InformationLifecycle Management" in Spanish to a group of customers from Mexico, Chile, and Brazil. We have a great Tucson Executive Briefing Center, and plenty of foreign-language speakers to draw from our localemployees here at the lab site.
Sunday, I leave for Las Vegas for our upcoming IBM Storage and Storage Networking Symposium. We will cover the latest in our disk, tape, storage networking and related software.Do you have your tickets? If you plan to attend, and want to meet up with me, let me know.
Last week, a writer for a magazine contacted us at IBM to confirm a quote that writing a Terabyte (TB) on disk saves 50,000 trees. I explained that this was cited from UC Berkeley's famousHow Much Information? 2003 study.
To be fair, the USA Today article explains that AT&T also offers "summary billing" as well as "on-line billing", but apparently neither of these are the default choice. I can understand that phone companies send out bills on paper because not everyone who has a phone has internet access, but in the case of its iPhone customers, internet access is in the palm of your hands! Since all iPhone customers have internet access, and AT&T knows which customers are using an iPhone, it would make sense for either on-line billing or summary billing to be the default choice, and let only those that hate trees explicitly request the full billing option.
Sending a box of 300 pages of printed paper is expensive, both for the sender and the recipient. This informationcould have been shipped less expensively on computer media, a single floppy diskette or CDrom for example. Forthose who prefer getting this level of detail, a searchable digitized version might be more useful to the consumer.
Which brings me to the concept of Information Lifecycle Management (ILM). You can read my recent posts on ILM byclicking the Lifecycle tab on the right panel, or my now infamous post from last year about ILM for my iPod.
His recollection of the history and evolution of ILM fairly matches mine:
The phrase "Information Lifecycle Management" was originally coined by StorageTek in early 1990s as a way to sell its tape systems into mainframe environments. Automated tape libraries eliminated most if not all of the concerns that disk-only vendors tout as the problem with manual tape. I began my IBM career in a product now called DFSMShsm which specifically moved data from disk to tape when it no longer needed the service level of disk. IBM had been delivering ILM offerings since the 1970s, so while StorageTek can't claim inventing the concept, we give them credit for giving it a catchy phrase.
EMC then started using the phrase four years ago in its marketing to sell its disk systems, including slower less-expensive SATA disk. The ILM concept helped EMC provide context for the many acquisitions of smaller companies that filled gaps in the EMC portfolio. Question: Why did EMC acquire company X? Answer: To be more like IBM and broaden its ILM solution portfolio.
Information Lifecycle Management is comprised of the policies, processes,practices, and tools used to align the business value of information with the mostappropriate and cost effective IT infrastructure from the time information isconceived through its final disposition. Information is aligned with businessrequirements through management policies and service levels associated withapplications, metadata, and data.
Whitepapers and other materials you might read from IBM, EMC, Sun/StorageTek, HP and others will all pretty much tell you what ILM is, consistent with this SNIA definition, why it is good for most companies, and how it is not just about buying disk and tape hardware. Software, services, and some discipline are needed to complete the implementation.
While the SNIA definition provides a vendor-independent platform to start the conversation, it can be intimidatingto some, and is difficult to memorize word for word.When I am briefing clients, especially high-level executives, they often ask for ILM to be explained in simpler terms. My simplified version is:
Information starts its life captured or entered as an "asset" ...
This asset can sometimes provide competitive advantage, or is just something needed for daily operations. Digital assets vary in business value in much the same way that other physical assets for a company might. Some assets might be declared a "necessary evil" like laptops, but are tracked to the n'th degree to ensure they are not lost, stolen or taken out of the building. Other assetsare declared "strategically important" but are readily discarded, or at least allowed to walk out the door each evening.
... then transitions into becoming just an "expense" ...
After 30-60 days, many of the pieces of information are kept around for a variety of reasons. However, if it isn'tneeded for daily operations, you might save some money moving it to less expensive storage media, throughless expensive SAN or LAN network gear, via less expensive host application servers. If you don't need instantaccess, then perhaps the 30 seconds or so to fetch it from much-less-expensive tape in an automated tape librarycould be a reasonable business trade-off.
... and ends up as a "liability".
Keeping data around too long can be a problem. In some cases, incriminating, and in other cases, just having toomuch data clogs up your datacenter arteries. If not handled properly within privacy guidelines, data potentially exposes sensitive personal or financial information of your employees and clients. Most regulations require certain data to be kept, in a manner protected against unexpected loss, unethical tampering, and unauthorized access, for a specific amount of time, after which it can be destroyed, deleted or shredded.
So ILM is not just a good idea to save a company money, it can keep them out of the court room, as well as help save the environment and not kill so many trees. Now that 100 percent of iPhone customers have internet access, and a goodnumber of non-iPhone customers have internet access at home, work, school or public library, it makes sense for companies to ask people to "opt-in" to getting their statements on paper, rather than forcing them to "opt-out".