my last-minute CRTC submission on net neutrality

Mon Feb 23 16:53:54 UTC 2009

On Mon, Feb 23, 2009 at 02:00:29AM -0500, D. Hugh Redelmeier wrote:
> The CRTC is accepting comments from the public until today.
> 
> The request for comments is here:
>   http://www.crtc.gc.ca/eng/archive/2008/pt2008-19.htm
> 
> To respond, go here:
>   http://support.crtc.gc.ca/rapidscin/default.aspx?lang=en
> go to the bottom of the pages and click on the button labelled
>   pt2008-19-2
> 
> You can type in a comment or upload a an HTML, MS Word, of MS Excel 
> document
> 
> I've attached my proposed submission.  I welcome suggestions, preferably 
> before, say, noon.
> 
> PS: I don't really know HTML.  One problem that I've inherited from the 
> original document is that I use <UL> for indentation (dumb, I 
> think).  I've not used <LI> which is wrong.  But if I add <LI> I get 
> bullets where I want nothing.  CSS can fix this but I don't know how to 
> use CSS.
> <!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0 Transitional//EN">
> <HTML>
> <HEAD>
> 	<META HTTP-EQUIV="CONTENT-TYPE" CONTENT="text/html; charset=utf-8">
> 	<TITLE>D. Hugh Redelmeier's Response to Telecom Public Notice CRTC 2008-19</TITLE>
> </HEAD>
> <BODY LANG="en-CA" DIR="LTR">
> <P STYLE="margin-bottom: 0in">
> </P>
> <HR>
> <H1>Recommendation and Rationale</H1>
> <P>
> There are two practical means of providing broadband internet
> connectivity for the vast majority of Canadian households: cable and phone line.
> In fact a significant number of households have only one of these available.
> 
> <P>
> This fact give the owners of the cable and telephone plant effective monopoly control over broadband.
> Someday a third mechanism might become widely deployed but that isn't the case now.
> Perhaps the correct term is duopoly, but it is simpler to use the word monopoly.
> 
> <P>
> Technical reasons dictate that these monopolies cannot be eliminated.
> But it hardly needs explanation that monopolies must be carefully constrained.
> In particular, monopolies stifle the vibrant creativity of the marketplace.
> 
> <P>
> One constraint that is necessary comes under the imprecise term network neutrality.
> In particular, network implementations must not privilege in any way applications, providers, or goals
> chosen by the monopoly providers.
> 
> <P>
> This is especially the case when the monopoly provider also
> provides a service for which it has competitors.
> 
> <P>
> A microcosm of this is the traffic shaping by Bell of the traffic of its customers' customers.
> The last mile that Bell provides has no contention (they've told me this in a series of ads)
> so this portion cannot justify traffic management.
> If there is contention, it must be in the back-haul from the central office to the ISP.
> After all, the connection from the ISP to the internet cloud is provided by the ISP and not Bell.
> If the back-haul traffic is to be shaped, the policies for shaping surely ought to be provided by
> the actual customer (ISP), not the provider.

Well there are quite a few connections involved.

1:The ADSL line from the end customer to the Bell CO.  This line isn't
shared and hence has no problem.

2:The line from the Bell CO to other parts of Bell for carrying the traffic
between the CO and where the ISP connects to Bell.  After all the ISP
doesn't connect to Bell at the CO.

3:The line from Bell to the ISP.  This one only affects the ISP's customers,
and hence shouldn't be any of Bell's business.

4:The connection from the ISP to the rest of the internet.  This one is
certainly none of Bell's business.

The traffic shaping Bell does is on number 2, the internal Bell network
used to carry traffic between the COs and the ISPs (including Bell's
own internet connections).  This is the one Bell claims is getting
overloaded.  I find it ammusing that Bell advertises having a "next
generation fiber optic network" while at the same time whining about
too much traffic overloading their network.

I guess the question is: What is the ISP paying Bell to provide when a DSL
customer has a Bell phone line and gets DSL service through a given ISP?

Certainly there is the connection to a DSLAM and providing the actual
DSL connection.  Then there is carrying the traffic from the CO to
somewhere that the ISP has a connection to Bell.  Is there any limits
or promisses on the amount or speed of data that Bell is going to carry?

I am sure that like all other phone companies, Bell is used to
oversubscribing their system since that's how circuit switched systems
were done.  Now that suddenly everything could be used at the same
time, and some people really are running close to 24/7 use of their line
(after all they advertise it as always on), their system is suddenly
not keeping up.  Now rather than expanding to meet demand, they seem to
have decided that they can just reduce usage on their lines by whatever
means they want, since they apparently don't think they ever promised
any particular level of service.

-- 
Len Sorensen
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