Canadian regulation on Net Neutrality (Applicable to Mobile too)

Previously I've talked about net neutrality in Singapore here and the COP in UK here. Today I came across the net neutrality regulation framework in canada. The pressrelease and info can be found here

The surprising part is the date of release in in 2009 which means Canadians have the regulation developed almost a good one and half year back. In summary,

* ITMP (Internet traffic management practices) should be transparent when employed
* Overall ISP's should invest in network to avoid congestion. However they can implement certain ITMP to manage at certain points.
* When they are employed they MUST be designed to address a DEFINED need and nothing more.
* Applicable to Mobile broadband.

If I've to compare this to our current situation in Singapore, I've very little positive words to mention. Today we've very 'generic' definitions on what will be controlled/blocked/throttled and at what times. Also the impact to individual customer is not clearly communicated (ISP's say that they throttle to certain % out of their capacity. So if one customer is just downloading a legal linux distro, his connection may be throttled to few kbps if the ISP sees a specific threshold met based on cumulative P2P usage).

Hope IDA will look in to this ( I wish together with IPv6) in the near future.

UK ISP's & TELCO's release a CoP for industry.

Just realized that the service providers released a Code of Practice (CoP) on traffic management transparency of broadband services. The full paper can be downloaded from here.

I've mentioned about net neutrality in Singapore & Operator responses  here. This is after IDA request them for information/submissions. The UK CoP is voluntary and supported by service providers; BSkyB, BT, O2, TalkTalk, Three, Virgin Media and Vodafone – these service providers account for 90% of all fixed-line broadband customers and 60% of all mobile customers in the UK. The group's first priority is to publish a common Key Factor Indicator table (KFI), summarizing the traffic management practices by June 2011.

The mobile operators T-Mobile & Orange didn't participate and I believe they'll share their policy on traffic management soon.

The principles of CoP are below.


*Firstly an  explicit  commitment  to  provide  more  information  to  consumers  about  what practices are used in networks to (a) help maximise capacity for everyone’s benefit and (b) to support adherence by customers to terms and conditions


* Secondly, an agreed set of good practice principles that will inform how ISPs communicate 
that  information  to  consumers.    Signatories  agree  that  the  information  they  provide  about 
traffic management to their current and prospective customers will be: 
Understandable, Appropriate , Accessible , Current , Comparable , Verifiable 

* Thirdly,  to  deliver  on  the  comparability  principle,  signatories  commit  to  publishing  a 
consistent  Key  Facts  Indicator  (KFI)  table,  summarising  the  traffic  management  practices 
they use for each broadband product they currently market. 

CoP on implementing Traffic management.

* To manage the overall network  - Prioritize/deprioritize time-critical applications (e.g. video streaming)
* In relation to Customer's contract - Data Caps, or As per T&C's of the contract

The actual means of implementation is not shared but I am sure it's by using DPI (Deep Packet Inspection) tools (e.g. Cisco-SCE8000, Allot, Sandvine, Arbor, Procera, & lot more Mobile vendors). However DPI tools does have their own limitation and tend to generate lot of false positives. For example a simple SSL tunnel (If you use HTTPS instead of HTTP) cannot be inspected, so if P2P uses tunneling or VPN or TOR kind of networks, the DPI's are not very useful.

Net neutrality in Singapore

CNA published that local telco's are not in support to publish the "average speeds" but prefer to use "max speeds".  While I tend to agree with the argument that it's quite difficult to provide average speeds in an objective manner I am surprised to see the replies from our three telco's. The way they responded gives me a very bad impression on them.

They say the market is highly competitive, they are transparent, they don't block or discriminate unwanted traffic & IDA should spend tax payers money to educate Customers so they won't complain (then result in more profits to TELCO's because even 100Mbps plan can give 1Kbps and Customer is 'educated' to accept it).

The new entrant Super internet reply is not that detailed by they shared the fact that the international bandwidth for 100Mbps costs $3,000+ and residential charges by ISP's are less than 100 so there is no way end customer can get 100Mbps from US. This answer is quite straight forward.

Anyways there are multitude of factors that an end customer cannot get the speed he/she is subscribed to. If it's wired broadband,

* PC/Notebook issues
* Home wi-fi coverage issues
* Home wiring issues (like powerline etc)
* Last mile cabling issues
* ISP Servers/Routers congestion
* ISP uplink congestion
* International issues (e.g. submarine cable failure etc)

Wireless broadband or Mobile broadband the issues are similar but on top of it being a shared network,

* Number of people using the specific base station.

But all of the issues does have a solution. This is to invest more in the network. Today our TELCO's margins are in very healthy ranges (here). If they want to accept lower margins they can invest in the network. Also they can invest in removing process wastage so they can reduce their operating costs. Anyway i'll wait for IDA decision and meanwhile, I've pasted the replies from our three telco's + super internet (because these guys are the first one's in NG-NBN)


SingTel
Furthermore, SingTel submits that bespoke regulation in the Internet services market in Singapore is necessary for the following reason:

- The Internet services market is highly competitive in Singapore;
- Existing  levels  of  regulation  are  sufficient  to  address  potential  anti-competitive conduct;
- Services  providers  should  be  free  to  manage  the  efficiency  of  their  networks, improve customer experience and innovate to facilitate high-quality applications;
- SingTel  complies  with  prevailing  to  publish  service  information  and  network management practices; and
- SingTel  already  complies  with  minimum  QoS  standards  and  is  transparent  in terms of its network management techniques;
- The publication of average or expected speeds is counter-productive and likely to confuse consumers.

StarHub

StarHub submits that developments in the local internet access service market have been healthy and that concerns over blocking or discriminatory treatment of internet traffic and content are unfounded

StarHub is concerned over IDA's proposal to provide added transparency to end-users by requiring ISPs and telecom network operators to publish an "expected average internet access speed" indicator. The inclusion of an expected average internet access speed is very subjective and cannot be estimated with a fair degree of accuracy. We would instead propose the continuation of IDA's residential broadband speed tests.

M1

In summary, M1 proposes:
* No change to existing policy position or approach on net neutrality;
* No  publication  of  misleading  information  such  as  “average  Internet  access  speed”  or “expected Internet access speed”; and
* Improve public education on broadband internet  services, thereby  raising the level of understanding on factors affecting the provision such telecommunication services. 


Super Internet

International IP Transit pricing today for 1Gbps out of Singapore is approximately US$20/Mbps/mth. Furthermore, trunk link pricing works out to S$4.10/Mbps/mth. With consumer pricing for “100Mbps” services at a level far below $3,110/mth, it is undeniable that there is oversubscription and therefore potential, if not actual, congestion in all networks. It therefore remains to be considered what measures ought to be allowable for management of this congestion.

Source: http://www.ida.gov.sg/Policies%20and%20Regulation/20070612111424.aspx