I’ve only just now had a chance to start to summarize my thoughts on documents related to CRTC Public Notice (PN) 2008-19; Review of the Internet traffic management practices of Internet service providers that have been filed since January 26th, 2009. Below are points of interest that come up – my hope is in the next few days to integrate and update the initial summary document that I prepared for ISP filings, so that a more complete picture of what has been filed exists.
January 26, 2009 ISP Filings
These filings, by major Canadian ISPs, were in response to the earlier inquiries made by non-ISP interrogatories for the public notice. I put together a summary document concerning those inquiries, and wrote a post that pulled together interesting comments that emerged from them.
Cogeco noted hat it was well known that there was a growth in Internet data traffic, though was not willing to disclose their actual growth numbers. Bell and MTS Allstream both supported the suggestion that the CRTC aggregate raw data traffic information that was provided by ISPs, so long as the information was anonymized and thus kept trade secrets relatively secret. Bell suggested that such aggregations could be divided according to ‘HTTP/streaming’, ‘P2P’, ‘UDP’, and ‘Other’ categories. MTS Allstream suggested that aggregated numbers be divided by ‘Telcos’ and ‘Cable providers’, or by ‘ISPs that throttle’ and ‘ISPs that don’t throttle traffic’. Read more…
Just a quick note about an interesting tidbit that was passed out by the Bell rep who gave a presentation on DPI today: A few years ago (no precise dates given) users were consuming, on average, 1GB of traffic; this has risen tenfold since that date. As Bell has repeatedly stated in CRTC submissions, they are not caching personally identifiable information as packets course through their DPI equipment, but still maintain that they are looking into the application layer of packets, but not the ‘content’ of the packet. It’s my hope that, over the next few months, more information about ISP uses of DPI emerges so that a more nuanced and productive discussion can take place.
In the next day or so, I’ll be putting up more thoughts and facts that emerged through the 10th annual security and privacy conference, “Life in a Digital Fishbowl“.
I’ve just completed a summary document that pulls together the requests for disclosure from the various advocacy groups currently involved in the CRTC’s PN 2008-19 (ISP Internet Management Techniques). A few things that I found of interest:
- TELUS is being used as a lever against the other ISPs; the common metric is “TELUS released all this information in public, so what justification can the rest of the ISPs have for filing in confidence?”
- Public Interest Advocacy Center (PAIC) really focused on Bell and Rogers, and noted repeatedly that Bell has filed items in confidence in this public notice that it had been forced to file in public previously. Also, where Bell could claim confidentiality last time (Canadian Association of Internet Providers [CAIP] v Bell), this isn’t the case now because all the major ISPs will be forced to show their hands at the same time.
- Without historical and projected growth, it is impossible for public groups to argue whether or not current managing practices are appropriate. This data needs to be released so that they can fully response to the CRTC’s public notice.
- The Campaign for Democratic Media (CDM) is willing to have all of the ISPs’ traffic aggregated, so long as it is disclosed publicly what the trends are.
- CDM notes that without information on the top 5% and 10% of users, that it is impossible to ascertain what their actual impact on total bandwidth has been.
- CAIP, PAIC, and the Canadian Film and Television Production Association (CFTPA) all argue that it is important for clear, technical, explanations of congestion be provided – without this, it is challenging to effectively interrogate what is, or isn’t, happening on ISPs’ networks.
- PIAC stands that, if Bell didn’t have a congestion metric in place prior to January 2007 then they should be obligated to disclose information in public on the basis that their definitions of congestion need to be examined more closely than others (unstated, but this is in part because they are such a major player in Canada).
- CFTPA holds that Bell’s networking diagram is good, because it offers specifics into their network. In light of Bell’s submission, other parties should submit similarly detailed diagrams, with devices clearly labeled, so that members of the public can meaningfully comment on whether the network components use by ISPs are adequate or not.
- CAIP, CDM, PAIC, and CFTPA all maintain that knowing what products are being used to manage Internet traffic is critical – without this information it is challenging to actually comment on how throttling is occurring. CDM raises the privacy issue with DPI.
I’ve recently put up a document that summarized most of the first round of filings for the CRTC’s investigation of Canadian ISP traffic management practices (PN 2008-19), and thought that I’d post a few things that I thought were most interesting (for me). Keep in mind that many of my interests revolve around deep packet inspection.
Network Use Averages
- Bell filed their specific data points in confidence, though from what they provided we can see that the top 5% of usage on the network has declined from 61.1% to 46.6%, and the top 10% of network usage has declined from 77.1% to 62.6%.
- In TELUS’ case, we find that their retail customers have decreased the amount of content they are uploading, though they are downloading more. Their wholesale customers are both downloading and uploading more than in 2006. Specific traffic data was filed in confidence to the CRTC.
- Bell finds that P2P and HTTP/Streaming traffic are the most commonly used end-user categories that contribute to bandwidth usage.
Canadian ISPs Admitting to Traffic Management
- Bell Wireline (excludes Bell Mobility and Bell Aliant Atlantic). DPI technology is used, though the vendor and products are filed in confidence.
- Cogeco uses DPI, but has filed the vendor and products in confidence.
- Rogers filed their comments in confidence, but from past information that has emerged we know that they are using DPI equipment.
- Shaw Communications Inc. uses Arbor-Ellacoya devices, though the particular products are filed in confidence.
- Barrett Xplore Inc. Uses VoIP prioritization, provisioning of modems, and DPI. Specifics are filed in confidence.
- While not explicitly stated, is appears as though Bragg Communications Ltd. also uses DPI. Read more…
