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Netflix Partner Says Comcast Setting Up Toll for Online Video Delivery

Submitted by mgeist on November 30, 2010 - 8:01am

Level 3 Communications, which delivers online movies to Netflix customers, says that ISP giant Comcast has set up a toolbooth around its broadband Internet services.

Liberals, NDP Support Net Neutrality Audits

Submitted by mgeist on October 13, 2010 - 9:21am

The SaveOurNet Coalition has released a new report on the three main political parties positions on net neutrality.  It finds that both the Liberals and NDP support mandatory net neutrality audits by the CRTC to ensure that ISPs are compliant with the Commission's traffic management guidelines.

Tuesday February 16, 2010
Canadian ISPs Fall Short In Meeting Net Neutrality Requirements
Last fall, the Canadian Radio-television and Telecommunications Commission issued its much-anticipated Internet traffic management ruling, better known as the net neutrality decision. The case attracted national interest as the CRTC established several key requirements for Canada’s Internet providers. These included new transparency obligations that forced ISPs to disclose their network management practices, such as why the practices were introduced, who will be affected, when it will occur, and how it will impact users' Internet experiences (down to the specific impact on speeds). The CRTC also opened the door to complaints about network management practices by establishing a test that any harm to users be as little as reasonably possible. Several months later, Canada's ISPs have had ample time to comply with the new requirements, yet my weekly technology law column (Toronto Star version, Ottawa Citizen version, homepage version) reviews the policies from the biggest ISPs - including Bell Canada, Rogers Communications Inc., Shaw Communications Inc., Telus, Cogeco Inc., and Groupe Vidéotron - and reveals a decidedly mixed bag.

Two of the six providers - Telus and Vidéotron - do not have explicit network management practice disclosures since neither currently uses throttling or traffic shaping technologies that limit the speeds of some applications.  Of the remaining four providers, no one makes it easy to find the disclosures and at least two may not be compliant with the CRTC requirements.

Bell features the most detailed disclosure, providing specific information about its policies and their impact.  While critics may object to the positive spin the company uses to describe limitations on its service, it has done precisely what the CRTC asked.  The Rogers policy is not quite as extensive, yet it also covers much the same terrain, including a description of the policy, the frequency of traffic shaping, and the resulting limitations in their service (including the specific impact on speed).

By contrast, neither Shaw nor Cogeco appear to meet the CRTC requirements.  Shaw's policy, which can be found within its terms of use, does not disclose the actual speeds users encounter when it throttles peer-to-peer activity.  Cogeco, which implausibly claims "customer experience is never affected by the application of [its] measures," similarly does not disclose the speeds that result from its throttling practices.

Not only are two providers arguably failing to meet the transparency requirements, but some traffic management practices may be ripe for complaint.

Telus and Vidéotron once again get a pass, since neither uses throttling technologies, opting instead for economic measures that add additional costs for heavy broadband users.  Shaw's policy also appears compliant with the CRTC minimal harm threshold, since it limits its throttling practices to actual instances of congestion on specific segments of its network.  

Meanwhile, Rogers and Cogeco continuously throttle all upstream P2P traffic. Both providers admit that the limits on their service occur on a 24 hour, 7-day basis, regardless of whether the network is actually experiencing any congestion.  For example, Cogeco claims "it is [our] experience that congestion created by P2P can occur at any time within a 24-hour period."  This may be true, but the failure to limit throttling activities to instances of actual congestion is surely grounds for a CRTC complaint.

While Bell limits its throttling practices to specified periods, its defined period is so broad that it too may be the target of a complaint. Bell discloses that its throttling practices, which target upload and download traffic, runs from 4:30 pm to 2:00 am.  By covering nearly half the day, the company could face questions about whether the policy limits harm as much as reasonably possible.

The CRTC's net neutrality guidelines garnered well-deserved plaudits last year, yet the true test will be whether the guidelines will be enforced effectively.  Last month, the CRTC sent letters to several ISPs - including Shaw, Rogers, Cogeco, and Bell - seeking action.  The ISPs have yet to respond.

Two of the six providers - Telus and Vidéotron - do not have explicit network management practice disclosures since neither currently uses throttling or traffic shaping technologies that limit the speeds of some applications.  Of the remaining four providers, no one makes it easy to find the disclosures and at least two may not be compliant with the CRTC requirements.

Bell features the most detailed disclosure, providing specific information about its policies and their impact.  While critics may object to the positive spin the company uses to describe limitations on its service, it has done precisely what the CRTC asked.  The Rogers policy is not quite as extensive, yet it also covers much the same terrain, including a description of the policy, the frequency of traffic shaping, and the resulting limitations in their service (including the specific impact on speed).

By contrast, neither Shaw nor Cogeco appear to meet the CRTC requirements.  Shaw's policy, which can be found within its terms of use, does not disclose the actual speeds users encounter when it throttles peer-to-peer activity.  Cogeco, which implausibly claims "customer experience is never affected by the application of [its] measures," similarly does not disclose the speeds that result from its throttling practices.

Not only are two providers arguably failing to meet the transparency requirements, but some traffic management practices may be ripe for complaint.

Telus and Vidéotron once again get a pass, since neither uses throttling technologies, opting instead for economic measures that add additional costs for heavy broadband users.  Shaw's policy also appears compliant with the CRTC minimal harm threshold, since it limits its throttling practices to actual instances of congestion on specific segments of its network.  

Meanwhile, Rogers and Cogeco continuously throttle all upstream P2P traffic. Both providers admit that the limits on their service occur on a 24 hour, 7-day basis, regardless of whether the network is actually experiencing any congestion.  For example, Cogeco claims "it is [our] experience that congestion created by P2P can occur at any time within a 24-hour period."  This may be true, but the failure to limit throttling activities to instances of actual congestion is surely grounds for a CRTC complaint.

While Bell limits its throttling practices to specified periods, its defined period is so broad that it too may be the target of a complaint. Bell discloses that its throttling practices, which target upload and download traffic, runs from 4:30 pm to 2:00 am.  By covering nearly half the day, the company could face questions about whether the policy limits harm as much as reasonably possible.

The CRTC's net neutrality guidelines garnered well-deserved plaudits last year, yet the true test will be whether the guidelines will be enforced effectively.  Last month, the CRTC sent letters to several ISPs - including Shaw, Rogers, Cogeco, and Bell - seeking action.  The ISPs have yet to respond.

net neutrality compliance column

Last fall, the Canadian Radio-television and Telecommunications Commission issued its much-anticipated Internet traffic management ruling, better known as the net neutrality decision. The case attracted national interest as the CRTC established several key requirements for Canada’s Internet providers.

These included new transparency obligations that forced ISPs to disclose their network management practices, such as why the practices were introduced, who will be affected, when it will occur, and how it will impact users' Internet experiences (down to the specific impact on speeds). The CRTC also opened the door to complaints about network management practices by establishing a test that any harm to users be as little as reasonably possible.

Several months later, Canada's ISPs have had ample time to comply with the new requirements, yet my weekly technology law column (Toronto Star version, Ottawa Citizen version, homepage version) reviews the policies from the biggest ISPs - including Bell Canada, Rogers Communications Inc., Shaw Communications Inc., Telus, Cogeco Inc., and Groupe Vidéotron - and reveals a decidedly mixed bag.

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Monday October 26, 2009
Net Neutrality in Canada Still a Work in Progress
The release last week of the Canadian Radio-television and Telecommunications Commission's report on Internet traffic management - known as the net neutrality decision - attracted national attention. Canadians, Internet service providers, and politicians debated whether the regulator had struck the right balance in addressing how ISPs manage Internet traffic. While some headlines seemed to suggest that the CRTC has given Canada's ISPs the green light to do as they please, my weekly technology law column (Toronto Star version, homepage version) argues the reality is that the decision establishes several notable requirements and restrictions, but leaves the door open for further action from the government.   First, the commission adopted a new test to determine reasonable traffic management practices.  Where a consumer complains, ISPs will be required to describe their practices, demonstrate their necessity, and establish that they discriminate as little as possible.  The CRTC added that targeting specific applications or protocols may warrant investigation and slowing down time-sensitive traffic likely violates current Canadian law. Second, the commission rejected arguments that the market would ensure ISPs provide adequate disclosure on how they manage their networks.  Instead, it mandated full disclosure of traffic management practices, including information on when they occur, which applications are affected, and their impact on Internet speeds. Third, the CRTC banned the use of personal information obtained through deep-packet inspection for anything other than traffic management purposes.  By also prohibiting the disclosure of such information, the commission ensured that inspecting user traffic cannot be parlayed into marketing opportunities. These conditions ensure that traffic management is not a free-for-all. The days of ISPs arguing they can do whatever they please on their networks - as some intimated during the summer hearing - are over.

With the CRTC framework in place, it now falls to Industry Minister Tony Clement to become more engaged on the issue.  Both the Liberals and NDP have expressed support for net neutrality and some groups have renewed their demands for new legislation.

Yet Clement can advance the issue in several meaningful ways without tabling a bill.  Critics of the CRTC approach rightly note that the onus falls to consumers to compile evidence of traffic management practices that run afoul of the commission's test and file complaints.  

When asked about the issue last week in the House of Commons, Clement stated that he is "watching those providers very closely and I do not want to see a situation where consumers are put at risk in terms of their access to the Internet."  He can go several steps further by asking the CRTC to conduct regular compliance audits of ISP traffic management practices and by providing financial support to consumer groups who wish to conduct their own investigations.

The federal government also can play a significant role in establishing neutrality for wireless Internet access.  The CRTC acknowledged that many of the same issues arise in the wireless context and that it expects wireless carriers to follow the same guidelines.  Within the next two years, the federal government will conduct another spectrum auction as part of the digital television transition.  Clement could incorporate net neutrality requirements directly into the bidding process, effectively mandating neutrality into new wireless services.

Finally, Clement should acknowledge that net neutrality concerns are largely a function of an uncompetitive marketplace that allows ISPs to leverage their positions without fear of losing customers.  The best way to address net neutrality is therefore to give priority to increased competition in the Canadian Internet marketplace.  

Multiple studies have concluded that Canadians pay higher prices for slower speeds as compared to many other countries.  If Clement can solve that problem, he'll likely go a long way to addressing net neutrality in the process.

With the CRTC framework in place, it now falls to Industry Minister Tony Clement to become more engaged on the issue.  Both the Liberals and NDP have expressed support for net neutrality and some groups have renewed their demands for new legislation.

Yet Clement can advance the issue in several meaningful ways without tabling a bill.  Critics of the CRTC approach rightly note that the onus falls to consumers to compile evidence of traffic management practices that run afoul of the commission's test and file complaints.  

When asked about the issue last week in the House of Commons, Clement stated that he is "watching those providers very closely and I do not want to see a situation where consumers are put at risk in terms of their access to the Internet."  He can go several steps further by asking the CRTC to conduct regular compliance audits of ISP traffic management practices and by providing financial support to consumer groups who wish to conduct their own investigations.

The federal government also can play a significant role in establishing neutrality for wireless Internet access.  The CRTC acknowledged that many of the same issues arise in the wireless context and that it expects wireless carriers to follow the same guidelines.  Within the next two years, the federal government will conduct another spectrum auction as part of the digital television transition.  Clement could incorporate net neutrality requirements directly into the bidding process, effectively mandating neutrality into new wireless services.

Finally, Clement should acknowledge that net neutrality concerns are largely a function of an uncompetitive marketplace that allows ISPs to leverage their positions without fear of losing customers.  The best way to address net neutrality is therefore to give priority to increased competition in the Canadian Internet marketplace.  

Multiple studies have concluded that Canadians pay higher prices for slower speeds as compared to many other countries.  If Clement can solve that problem, he'll likely go a long way to addressing net neutrality in the process.

net neutrality decision column

The release last week of the Canadian Radio-television and Telecommunications Commission's report on Internet traffic management - known as the net neutrality decision - attracted national attention. Canadians, Internet service providers, and politicians debated whether the regulator had struck the right balance in addressing how ISPs manage Internet traffic. While some headlines seemed to suggest that the CRTC has given Canada's ISPs the green light to do as they please, my weekly technology law column (Toronto Star version, homepage version) argues the reality is that the decision establishes several notable requirements and restrictions, but leaves the door open for further action from the government.  

First, the commission adopted a new test to determine reasonable traffic management practices.  Where a consumer complains, ISPs will be required to describe their practices, demonstrate their necessity, and establish that they discriminate as little as possible.  The CRTC added that targeting specific applications or protocols may warrant investigation and slowing down time-sensitive traffic likely violates current Canadian law.

Second, the commission rejected arguments that the market would ensure ISPs provide adequate disclosure on how they manage their networks.  Instead, it mandated full disclosure of traffic management practices, including information on when they occur, which applications are affected, and their impact on Internet speeds.

Third, the CRTC banned the use of personal information obtained through deep-packet inspection for anything other than traffic management purposes.  By also prohibiting the disclosure of such information, the commission ensured that inspecting user traffic cannot be parlayed into marketing opportunities.

These conditions ensure that traffic management is not a free-for-all. The days of ISPs arguing they can do whatever they please on their networks - as some intimated during the summer hearing - are over.

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Wednesday October 21, 2009
CRTC Sets Net Neutrality Framework But Leaves Guarantees More Complaints
The CRTC's net neutrality (aka traffic management) decision is out and though it does not go as far as some advocates might hope, it unquestionably advances the ball forward on several important fronts.  When considering the decision, it is important to remember that 12 months ago, there was virtually no ISP disclosure of traffic management practices and even an unwillingness to acknowledge that there was an issue.  Today's CRTC decision signifies that traffic management is not a free-for-all and the days of ISPs arguing that they can do whatever they please on their networks is over.  That said, it also guarantees that traffic management practices such as throttling will continue and it is going to take more complaints to concretely address the issue. The key elements of the decision on retail services:


1.   A new framework for considering traffic management.  Consumers can complain about traffic management practices or the Commission can bring an action on their own.  Where there is a credible complaint, the ISP will be required to:

  • Describe the ITMP being employed, as well as the need for it and its purpose and effect, and identify whether or not the ITMP results in discrimination or preference.
  • If there is any degree of discrimination or preference:
  • demonstrate that the ITMP is designed to address the need and achieve the purpose and effect in question, and nothing else;
  • establish that the ITMP results in discrimination or preference as little as reasonably possible;
  • demonstrate that any harm to a secondary ISP, end-user, or any other person is as little as reasonably possible; and
  • explain why, in the case of a technical ITMP, network investment or economic approaches alone would not reasonably address the need and effectively achieve the same purpose as the ITMP.

2.   There are two key additional considerations.  First, traffic management that degrades or prefers one application over another may warrant investigation under section 27(2) of the Act.  Second, economic traffic management practices (ie. bit caps) are generally viewed as ok. 

3.   The Commission has stepped into the throttling issue.  It has ruled that for time-sensitive Internet traffic (ie. real-time audio or video), where the throttling creates noticeable degredation, this "amounts to controlling the content and influencing the meaning and purpose of the telecommunications in question."  The Commission will require prior approval for such activities.  Even for non-sensitive traffic, the CRTC has ruled that it is possible to slow down to an extent that it amounts to blocking or controlling the content, therefore requiring prior approval.

4.   The Commission has mandated new disclosure requirements.  It is requiring ISPs to disclose their traffic management practices to customers, including:

  • why there are being introduced
  • who is affected
  • when it will occur
  • what Internet traffic is subject to the traffic management
  • how it will affect an Internet user's experience, including specific impact on speed

5.   New privacy requirements

The Commission has established new privacy requirements on the use of information obtained from deep-packet inspection.  It now mandates ISPs "not to use for other purposes personal information collected for the purposes of traffic management and not to disclose such information."

In addition to the retail side of the equation, the decision also addresses wholesale (ie. ISP to ISP).  In a nutshell, where incumbents treat independents in the same manner as their retail customers, the same complaints-based approach applies.  Where the approach is more restrictive, prior approval is required.

While this decision will undoubtedly leave many disappointed, a full prohibition on throttling was never in the cards.  Many consumer groups and net neutrality advocates got some of what they asked for - a test that looks a lot like what they recommended, an acknowledgement of the problems with application-specific measures, new disclosure requirements, new privacy safeguards, and agreement that throttling can violate the law in certain circumstances.  That isn't bad as an overall framework. 

The big question is how to enforce these rules. The larger ISPs may well view the decision as a green light to continue doing what they are doing with a bit more communications.  Indeed, by placing the onus squarely on consumers, the CRTC has virtually guaranteed continued throttling and a steady stream of cases.  There is now more guidance and guidelines but it will take more than just this decision to provide Canadians with the neutral network so many crave.


1.   A new framework for considering traffic management.  Consumers can complain about traffic management practices or the Commission can bring an action on their own.  Where there is a credible complaint, the ISP will be required to:

  • Describe the ITMP being employed, as well as the need for it and its purpose and effect, and identify whether or not the ITMP results in discrimination or preference.
  • If there is any degree of discrimination or preference:
  • demonstrate that the ITMP is designed to address the need and achieve the purpose and effect in question, and nothing else;
  • establish that the ITMP results in discrimination or preference as little as reasonably possible;
  • demonstrate that any harm to a secondary ISP, end-user, or any other person is as little as reasonably possible; and
  • explain why, in the case of a technical ITMP, network investment or economic approaches alone would not reasonably address the need and effectively achieve the same purpose as the ITMP.

2.   There are two key additional considerations.  First, traffic management that degrades or prefers one application over another may warrant investigation under section 27(2) of the Act.  Second, economic traffic management practices (ie. bit caps) are generally viewed as ok. 

3.   The Commission has stepped into the throttling issue.  It has ruled that for time-sensitive Internet traffic (ie. real-time audio or video), where the throttling creates noticeable degredation, this "amounts to controlling the content and influencing the meaning and purpose of the telecommunications in question."  The Commission will require prior approval for such activities.  Even for non-sensitive traffic, the CRTC has ruled that it is possible to slow down to an extent that it amounts to blocking or controlling the content, therefore requiring prior approval.

4.   The Commission has mandated new disclosure requirements.  It is requiring ISPs to disclose their traffic management practices to customers, including:

  • why there are being introduced
  • who is affected
  • when it will occur
  • what Internet traffic is subject to the traffic management
  • how it will affect an Internet user's experience, including specific impact on speed

5.   New privacy requirements

The Commission has established new privacy requirements on the use of information obtained from deep-packet inspection.  It now mandates ISPs "not to use for other purposes personal information collected for the purposes of traffic management and not to disclose such information."

In addition to the retail side of the equation, the decision also addresses wholesale (ie. ISP to ISP).  In a nutshell, where incumbents treat independents in the same manner as their retail customers, the same complaints-based approach applies.  Where the approach is more restrictive, prior approval is required.

While this decision will undoubtedly leave many disappointed, a full prohibition on throttling was never in the cards.  Many consumer groups and net neutrality advocates got some of what they asked for - a test that looks a lot like what they recommended, an acknowledgement of the problems with application-specific measures, new disclosure requirements, new privacy safeguards, and agreement that throttling can violate the law in certain circumstances.  That isn't bad as an overall framework. 

The big question is how to enforce these rules. The larger ISPs may well view the decision as a green light to continue doing what they are doing with a bit more communications.  Indeed, by placing the onus squarely on consumers, the CRTC has virtually guaranteed continued throttling and a steady stream of cases.  There is now more guidance and guidelines but it will take more than just this decision to provide Canadians with the neutral network so many crave.

net neutrality decision

The CRTC's net neutrality (aka traffic management) decision is out and though it does not go as far as some advocates might hope, it unquestionably advances the ball forward on several important fronts.  When considering the decision, it is important to remember that 12 months ago, there was virtually no ISP disclosure of traffic management practices and even an unwillingness to acknowledge that there was an issue.  Today's CRTC decision signifies that traffic management is not a free-for-all and the days of ISPs arguing that they can do whatever they please on their networks is over.  That said, it also guarantees that traffic management practices such as throttling will continue and it is going to take more complaints to concretely address the issue.

The key elements of the decision on retail services:

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Monday July 20, 2009
CRTC Net Neutrality Hearing Open Door To Regulatory Action
Regulatory hearings on Internet traffic management practices held in windowless rooms in Gatineau, Quebec in the middle of summer are not likely candidates to attract much attention.  Yet, as my weekly technology column notes (Toronto Star version, homepage version) for seven days this month, hundreds of Canadians listened to webcasts of Internet service providers defend their previously secret practices while engaging in a robust debate on net neutrality. The interest in the Canadian Radio-television and Telecommunications Commission hearing may have caught the regulator off-guard (the webcast traffic was, by a wide margin, its most ever for a hearing), but it was the testimony itself that was the greatest source of surprise.

The seven-day hearing was billed as a debate over whether rules are needed to govern ISP network management practices. While many Internet users remain unaware of the issue, behind the scenes ISPs employ a variety of mechanisms to control the flow of traffic on their networks, with some restricting or throttling the speeds for some applications.

Those practices have proven highly contentious, with creator interests, technology companies, privacy rights organizations, and consumer groups all expressing fears that they may curtail innovation, invade user privacy, stifle competition, and create an uneven playing field for content distribution.  ISPs argue that such measures are essential to provide their subscribers with a good experience at an affordable price.

Days of testimony revealed the issue is far more complicated than the rhetoric might suggest. First, there is a wide variation in the use of traffic management tools with a different approach for pretty much every major ISP.  Some throttle all the time (Cogeco), some during large chunks of the day (Bell), some only during congested periods (Shaw), and some not at all (Telus, Videotron).

Second, ISP disclosures are woefully inadequate. For example, Rogers admitted that it charges tiered pricing for faster upload speeds but that all tiers are throttled to the same speed when using peer-to-peer applications.  In other words, subscribers to the Extreme service pay $59.99 per month and are promised fast upload speeds (1 Mbps) but actually get the same upload speed as Express subscribers who pay $46.99 per month and are promised upload speeds at half that rate.

Third, notwithstanding the perception that network traffic is growing dramatically, the reality is that the rate of growth is actually slowing. ISPs acknowledged the could cope with the growing demand through reasonable new investment in their networks.

Given all the competing evidence, what is the Commission likely to do? A four-pronged approach is possible.

First, it could adopt a test advocated by the Open Internet Coalition, a group of technology companies that includes Google, that permits traffic management practices so long as they further a pressing and substantial objective, are narrowly tailored to the objective, and are the least restrictive means of achieving the objective. This test would give useful guidance to ISPs and ensure that there are appropriate limits on traffic management practices that have no clear correlation with network congestion.

Second, it can affirm the role of current law against leveraging network management for unfair advantage. Third, the Commission can establish minimum disclosure requirements including information on traffic management practices such as time, targets, and the actual speeds consumers are likely to experience. Fourth, it can dictate limits on the use of personal data that ISPs obtain from traffic management.

Alternatively, the Commission could decide to do nothing and simply retain the power to address complaints as they arise. If so, significant political pushback is likely with political parties lining up in the fall in support of net neutrality legislation.

Regulatory hearings on Internet traffic management practices held in windowless rooms in Gatineau, Quebec in the middle of summer are not likely candidates to attract much attention.  Yet, as my weekly technology column notes (Toronto Star version, homepage version) for seven days this month, hundreds of Canadians listened to webcasts of Internet service providers defend their previously secret practices while engaging in a robust debate on net neutrality. The interest in the Canadian Radio-television and Telecommunications Commission hearing may have caught the regulator off-guard (the webcast traffic was, by a wide margin, its most ever for a hearing), but it was the testimony itself that was the greatest source of surprise.

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An Act to Amend the Telecommunications Act (Internet Neutrality), Bill C-552

Submitted by administrator on July 14, 2009 - 4:01pm
Type: 
Regulations/Regulatory
Publishers
Publisher 1 - Date: 
(May 28, 2009)
Publisher 1 - URL: 
http://www2.parl.gc.ca/HousePublications/Publication.aspx?DocId=3524372&Language...
Authors
Author 1 - First Name: 
Charlie Angus
Author 1 - Last Name: 
NDP MP
Monday July 13, 2009
Questions for Bell
CRTC Chair Konrad von Finckenstein closed today's session of the network management hearing by noting that the "Bell interrogation" will begin tomorrow morning. With Bell the final party to appear, the previous six days have raised many questions in need of answers.  I've posted some below.  Readers should feel free to add here or post to Twitter (#q4bell). Traffic management Your disclosure statement indicates that you shape from 4:30 pm to 2:00 am?  Why not more specifically during periods of congestion? Your online disclosure does not specify the reduction in speeds due to shaping.  What are they? Rogers claims that P2P causes congestion at all times.  Do you have a different experience? Many major carriers from both DSL and cable do not traffic shape at all.  Why the difference? Do you traffic shape upload and download or just upload? What are the minimum speeds for upload (Shaw's are 80 kilobits/sec)? What percentage of bandwidth is reserved for P2P traffic (Shaw is 30%)? What percentage of your users are active P2P users? Is the shaping the same for all customers regardless of the tiered service? Do you shape wireless data services? Have you tried economic approaches (ie. Videotron's caps) to address congestion? What would be your costs to adopt the Comcast approach? Have you considered the Juniper technology of customer controlled prioritization? How do you address the privacy concerns associated with DPI? Do you have any information on the throttling experience raised by the CFTPA presentation?

Wholesale and Managed Internet services

  • Does wholesale traffic affect your retail traffic?
  • If it does, why (MTS does not)?
  • Can you identify wholesale traffic?
  • Do you reserve space for wholesale traffic?
  • Can the wholesale traffic exceed its cap?
  • Does your managed Internet services such as online video affect your public Internet services? If so, why doesn't this raise competition concerns?

Peering and Network Growth

  • The hearing was told that Bell is the only major Canadian ISP that does not actively peer in Canada. Is this true?  If so, why not?
  • Does the decision not to peer affect your customer experience? Does it raise your network costs?
  • Many ISPs have indicated that growth is slowing and that they can handle growth through reasonable augmentation of their networks.  Is that your experience?

Guidelines and Tests

  • Do you agree with the OIC/CIPPIC Oakes-style test?
  • If not, what would you propose as an alternative?
  • Should there be mandated disclosure requirements? For retail? Wholesale?

Finally, in a shoutout to Rogers, "If an application which could cure cancer acted like P2P, would it also be subject to traffic management on your network?"

questions for bell

CRTC Chair Konrad von Finckenstein closed today's session of the network management hearing by noting that the "Bell interrogation" will begin tomorrow morning. With Bell the final party to appear, the previous six days have raised many questions in need of answers.  I've posted some below.  Readers should feel free to add here or post to Twitter (#q4bell).

Traffic management

  • Your disclosure statement indicates that you shape from 4:30 pm to 2:00 am?  Why not more specifically during periods of congestion?
  • Your online disclosure does not specify the reduction in speeds due to shaping.  What are they?
  • Rogers claims that P2P causes congestion at all times.  Do you have a different experience?
  • Many major carriers from both DSL and cable do not traffic shape at all.  Why the difference?
  • Do you traffic shape upload and download or just upload?
  • What are the minimum speeds for upload (Shaw's are 80 kilobits/sec)?
  • What percentage of bandwidth is reserved for P2P traffic (Shaw is 30%)?
  • What percentage of your users are active P2P users?
  • Is the shaping the same for all customers regardless of the tiered service?
  • Do you shape wireless data services?
  • Have you tried economic approaches (ie. Videotron's caps) to address congestion?
  • What would be your costs to adopt the Comcast approach?
  • Have you considered the Juniper technology of customer controlled prioritization?
  • How do you address the privacy concerns associated with DPI?
  • Do you have any information on the throttling experience raised by the CFTPA presentation?

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