p2pnet news view Freedom | P2P:- It’s a day late —- Bell asked for, and was granted, an extension —- and considerably more than a dollar short, p2pnet reported on Saturday, referring to Bell Canada’s latest CRTC (Canadian Radio-Television and Telecommunications Commission) submission.

Our post, the first on the subject and carrying the document in full, follows the efforts of Bell and other major ISPs here and across the border in the US to control what their users do with the accounts they’ve bought and paid for.

Click here for p2pnet’s digest of what’s become a saga.

Bell, et al, call it ‘traffic management,’ claiming it’s necessary to prevent a small number of P2P users from ruining things for everyone else.

Fronting for Bell was, and still is, Mirko ‘Mr 5%‘ Bibic.

Bell admits it’s also in receipt of 25 comments from such as Google and Per Vices, the company which also provided a way for people to get around Bell’s bandwidth throttling ‘traffic management’ actions, our story said.

Among the submissions was one from Jean-François Mezei.

In a Reader’s Write to Saturday’s post, “I went through Bell’s fantastic work of fiction yesterday and commented on it,” Mezei says, pointing to his post on dslreports which, not at all incidentally, also has a number of other observations on Bell’s statements and efforts justification.

He goes on >>>

“Al Gore may have invented the Internet, but Mirko Bibic has now invented ‘application headers’.

Better yet, Bibic states that the IP header is part of the TCP packet ! Great work of fiction !

86 pages designed to confuse people, waste their time , in the hopes that after reading it, they will just decide to belive whatever Bell has been saying withough chceking for facts.

I would greatly hope that the CRTC would charge Bell canada with contempt of court for knowingly having submitted lies in its documents. You can’t have a serious decision process when Bell lies in its submissions and expects the CRTC to just sit down , take it and believe everything Bell has stated.

“Since the letter was posted on the p2pnet.net web site, it is now public document. (even if not on the CRTC web site yet)” and, “I assume someone within your group got a copy and sent it to the p2pnet folks),” says Jean-François.

Nope, J-F, our source isn’t anything to do with dslreports or any of its members or posters. But I promise you it’s 100% reliable.

Here are Mezei’s thoughts as he posted them on dslreports in what we believe is the first, but certainly not the last critique, of the Bell submission in any kind of detail >>>

Some comments:

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a. Since 2001, the Company has invested over $3 billion in capital investments on its high-speed Internet service.

##In an interview on CBC’s Spark (.MP/ available on the spark web site), Bibic mention the “3 billion invested”, but was asked “was that all on the internet” and he had to say “hundreds of millions on internet”.

Not sure if this is all for the same timeframe as the current Bell document. Something to check.

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As Bell upgrades links to ethernet, it should be able to use legacy ATM equipment freed on those links to tempoeraily upgrade remaining ATM links, so the argument of continued purchase of expensive ATM equipment shows bad management on Bell’s part. If it is cheaper to upgrade to ethernet, the Bell should simply be accelerating upgrades to ethernet.

And Bell has not demonstrated in its statistics whether congestion occurs only at ATM links or both ATM and ethernet. If congestion is only at ATM links, this should be viewed as a temporary problem to be solved by accelerated upgrade programme.

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a. The Company initiated the transition to usage-based billing in December 2006 when it ceased offering its unlimited traffic plan to any new subscribers. However, the transition to usage-based pricing cannot be the sole solution to network congestion, nor is it an instant “fix” for three principal reasons:

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We are talking about GAS/5410 CRTC regulated tariff, and not about Sympatico’s retail pricing. GAS$5410 is NOT usage based and there has not been any process initiated by Bell to change that tariff.

Usage based pricing is easily accomplished with normal existing routers, and thus do not need DPI equipment. Independant ISPs already accomplish this with their routers and Bell does not need to put any equipment between them and their customers to do that job.

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i. terminating or managing the service of users who consistently breach the Company’s Acceptable Use Policy; and

Bell Canada has no right to decide to terminate customers of its competitors. This is not a submission about Sympatico, it is a submission about GAS/5410.

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The Company does not block any form of P2P file sharing applications nor does it shape non P2P file sharing applications.

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The speed at which Bell cripples certain communicatiosn makes them unusable during the hours where they are crippled and thuse this is similar to blocking them even if technically they still run.

Putting a 5km/h speed limit on the 401 in Toronto between 16:30 and 02:00 would not close it, but would make it ususable and force people to use other routes.

MORE IMPORTANTLY: SINCE BELL REFUSES TO DEFINE EXACTLY WHAT IT DOES THROTTLE’ PEOPLE CAN’T KNOW WHAT WILL AND WILL NOT BE THOTTLES AND SERVICE PROVIDERS CANNOT ADJUST THEIR SERVICE OFFERING TO REFLECT THIS SERVICE DEGRADATION.

EVEN MORE IMPORTANTLY: SINCE BELL RESERVES THE RIGHT TO CHANGE ITS CONFIGS ANYIME IT WANTS WITHOUT WARNING ANYONE: SERVICE PRODIDERS ARE IN EVEN WORSE SITUATION SINCE THEIR SERVICE OFFERING CAN BE CHANGED BY BELL WITHOUT WARNING. THIS IS A **VERY** VISIBLE CHANGE THAT MATERIALLY EFFECTS END USERS AND ISPs.

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i) P2P file sharing traffic is designed to open several sessions in an effort to transfer data as fast as possible, thus overwhelming other forms of traffic.

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FALSE. A single PPPoE session exists between end users and their service providers and the number or IP/TCP/UDP links is totally irrelevant to Bell in the GAS/AHSSPI service since Bell only sees PPPoE packets.

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ii) Because of the possibility of queuing file requests, P2P file sharing can sustain a continuous maximum network traffic load, 24 hours a day, 7 days a week and 365 days a year, as long as there are queued requests.

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Solved by monthly download limits which many ISPs have had for many years. And for those who still provide unlimited, then they simply need to buy sufficient bandwdith from bell to support those activities.

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iii) Some P2P file sharing applications look for the fastest node available, and thus any increase in capacity to one network node will attract increased P2P file sharing upload requests from other P2P file sharing applications resident on other networks.

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BitTorrent/P2P cannot exceed the speeds of the ADSL links. They cannot abuse those links. They operate at whatever speed the link is, just as any other bandwidth intensive application including the Bell Video store.

And from GAS’ point of view, it only manages a single PPPoE session between the user and the ISP. Whatever *internet* networks may be used beyond the ISP is totally irrelevant to the GAS service.

(remind CRTC that this is about GAS/5410 and not Sympatico service)

Remind CRTC that ADSL is not like Cable (re: Roger’s comments). ADSL provides *DEDICATED* bandwidth (leased lines) on the “last mile” and full use of the 800kbps give on ADSL lines does not impact neighbours, contrary to Cable. and 800kbps is very small speed for upload and shouldn’t be a problem for Bell to handle in its backbone.

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ES8. As P2P file sharing applications are designed to use all of the bandwidth that is available, additional capacity cannot, on its own, resolve this issue.

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The ADSL last mile speed is the real bottle neck. No application can exceed that speed. It is a given that increasing the ADSL speed will increase the load on the backbone, but this happens with any application whereher it be viewing you tube, downloading from Bell Video Store etc.

ALL applications will use maximum speed of the slowest portion of a network (aka: the ADSL link).

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Because P2P file sharing applications are non time-sensitive, these can be “slowed down” during peak hours of traffic without interrupting service

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Who decided they were not time sesnitive ? And why is the Bell Video Store considered time sensitive and given full access to the ADSL line while BitTOrrent isn’t ?

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” allow them to suspend or terminate service where a customer uses or permits others to use services so as to prevent fair and proportionate use by others.”

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In this case, since the GAS customer is an ISP, Bell is refereing to suspending an ISP and not an ISP’s customers. In the case of GAS, the end users are not Bell Customers. (remind CRTC again that we are not talking about Sympatico)

Another point of view on this issue: What happens if Bell Canada mismanages a service such that fair use by customers negatively impacts other customers ? Would Bell then be allowed to terminate those customers who, despite having made fair use of facilities, have cause’s Bell’s mismanaged network to be congested ?

AKA: just because Bell delayed upgrade of its legacy ATM stuff doesn’t mean that customers are to be blamed for any small congestion issues.

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re: QoS issue with Cybersurf/Shaw:

Again, check with your expert Mr Gabe, but this would normally be implemented in the customer premise equipment which would priorituze which packets go over the link first. The involvment of the ISP or carrier would be less important. (and in the case of Bell, since this is a PPPoE service, there is no concept of prioriity of packets since this is to be a transparent Point to Point service, not a managed IP network.

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248. The Commission considers it appropriate that each cable carrier be provided the ability to manage the potential negative outcome of high-consuming bandwidth end-users in a manner that does not degrade the Q of S to all end-users, whether it is the cable carrier’s end-user or the competitor’s end-user. The Commission considers, however, that regardless of

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Cable is a shared medium on the coax compared to the dedicated links on ADSL for the last mile. And here the use of “Q of S” refers to a generic quality of the service, as opposed to the technical QoS packet prioritisation capabilities at the IP level.

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GAS service is not offered over a separate and distinct network. The GAS service offered to wholesale ISPs and the retail Sympatico Internet service offered by the Company share and have always shared the same access network and therefore will experience the same benefits and the same problems

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While the business relationship between Sympatico and Bell is unknown, it si known that independant ISPS, through GAS/AHSSPI fully pay for the bandwidth that their customers use and as such Bell must be made to provide it.

Secondly, Bell’s own graphics in its first intervention in April clearly showed AHSSPI as a separate snetwork from that used by Sympatico.

The fact that Bell underprivisioned the DSLAMBAS links because it underestimated average use is Bell’s problem and Bell should be made to solve it by providing adequate bandwidth on those links.

Secondly, if GAS customers were given equal treatment to Sympatico, how come Bell doesn’t raise ADSL profiles for GAS end users to 7mbps and give them equal access to remote ADSL ports ?

And what if GAS customer end up paying more per end user and end up buying more bandwidth for aggregation than Sympatico ? Shouldn’t they get better service than Sympatico ?

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ES14. Finally, there is no ulterior motive attached to the Company’s management of network congestion; it was not launched in order to i) launch usage-based billing,

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Contradiction with their May 15th filing where they stated the exact opposite. And Bell even mentions in this very docunment they want to use DPI for usage based billing.

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ES15. Despite the many claims by CAIP and other parties, the evidence clearly demonstrates that there is no ulterior motive or any basis for a claim of unjust discrimination.

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The evidence clearly shows that Bell is not being honest, is refusing to divulge the exact nature of what it thorttles and how it does it, so Bell is in no position to claim that speculation about its true intentions are unwarranted.

This is especially true since Bell has categorically stated that it feels no obligation to inform GAS customers of any changes it makes to its DPI equipment.

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If there is, indeed, any gatekeeping activity on the Internet, which is questionable, the gatekeeping is being performed by the Internet search engines, which are typically the users` window to the near-infinite content available worldwide.

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Google doesn’t prevent anyone from starting a competing search engine with new features which could eventually overthow Google. Google’s arguments are about the need to NOT prevent any new application from emerging.

-Google is not a network, it is an application/service provider. -Bell Canada is a network.

-We can use any search engine. We have no choice for ADSL.

-Bell is in no position to decide what apps we can and cannot use.

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First, the Notification Requirements do not apply to GAS service (as it is not a bottleneck service); second, traffic management is not a notifiable change because it does not require ISPs to make adjustments in their network.

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“Not a bottleneck service”. Interesting terminology. Could this mean that if it is not a bottleneck service, Bell has no right to treat it as such by managing packets to prevent bottlenecks ?

Secondly, ISPs must be able to fully define to their customer what service they provide. If Bell blocks certain applications (making them so slow as to be unusable is equal to blocking them), then this is definitely impacting ISPs and theur customers and ISPs need to be aware of the full details of the throttling in order to have an honest description of what service they can and cannot offer.

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ES17. The Company’s use of DPI technology as part of its traffic management practices is such that the actual contents of the communication exchange are not examined. Rather, only the protocol headers are examined and the DPI equipment does not retain the information reviewed in the packet headers.

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My submission has proven this to be wrong. From a network popint of view, anything in tye packet payload is to be considered user data, even control bytes used by an application.

A PPPoE network has no business knowing whether a packet transports email, BitTorrent, raw UDP, DNS requests or web traffic.

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- use any personal identification information of an individual user;

- store or log any personally identifiable information;

- have specific knowledge of a user’s real identity;

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If Bell wants to use this for usage based accounting, collection of this data would be required in order to be able to send usage data to the billing system.

- have knowledge of a user’s content;

- have knowledge of a user’s URL browsing history;

- have knowledge of a user’s Internet search activity;

By definition, DPI equipment looks at this. And the DPI equipment capabilities list prominently the ability to turn on a feature that will capture browsing history and associate it on a per user basis, as well as provide user-specific throttling profiles.

Since serach activity is transmistted as part of HTTP requests, then collecting URL browsing history implicitely includes search requests.

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- capture and playback any communications exchange; or

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The Ellacoya equipment is capable of doing this. As per CAELA requirements.

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First, slowing the delivery of content does not amount to “controlling” it.

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Deciding whether a packet should be transmitted to destination or discartded based on what application it is associated with is defrinitely controlling it.

ANALOGY: Bell is dictating what subjects one can discuss on a telephone conversation. Implementing it requires Bell listen to phone conversations to ensure we only speak of subjects Bell has approved.

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Bell cannot influence the meaning or purpose of the telecommunications because Bell has no knowledge of the content itself.

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Knowledge of what application is being use explicitely requires knowledge of the content. I have proven that Bell must look beyond the PPPoE, IP and TCP headers to decided which packets are associated with an application.

Analogy: If Bell listens for a female “Oh My God” on a telephone conversation to decided whether to “Throttle” that conversation or not, Bell may claim that “Oh My God” may not contain personal information such as birth date, social insurance number etc, but this is still part of a personal and private conversation and Bell legally requires a warrant to listen to any part of this conversation.

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Unwarranted policymaking and/or regulatory measures could hurt innovation, impede competition and decrease the efficiency of Canadian telecommunications

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Allowing a monopoly to unilaterally decide what regulatiosn it should implement, what packets it should let through and which it should cripple is abuse of power. GAS/5410 is regulated by CRTC to prevent abuse of power.

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The Company is confident, however, that competition and market forces will encourage, as it has already done, the development of new, better and fairer P2P file sharing applications.

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Any application designed to avoid being throttled will end up making use of available bandwidth and Bell can then unilaterally decide to throttle it without telling anyone since it has stated it doesn’t need to tell anyone about its throttling.

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Until that time, the Company has endeavoured to limit its traffic shaping

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Limit to what ? Since Bell won’t fully define exactly what it is crippling, the use of the word “limit” is wrong since those limits are not defined, and Bell reserves the right to change those limits without warning.

Secondly, crippling traffic down to below 30KB/s is not traffic shaping, it is crippling of applications at a speed so slow that it makes them ususable for 9.5 hours per day.

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Outside of that one concern, the Company submits it is not for the regulator to second guess the Company’s engineering decisions.

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DPI is not a network management solution, it is a service management solution which defines what types of uses of internet are to be allowed and what parts are not allowed. This is not an “engineering” decision, it is a management decision.

If congestion were a problem, Bell Canada would have delayed Sympatico 40% speed increases from 5 to 7mbps until the backbone was able to support it. That would have been an engineering solution to manage the network. The ADSL speed is the only variable that Bell can control under GAS tariffs. ISPs control how much AHSSPI capacity they purchase to support the type of uses their customers make at the speeds Bell as decided to supply on the ADSL loops.

Management at the application level is not network management, it is service management.

Stay tuned.

Jon Newton – p2pnet

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This entry was posted on Monday, July 14th, 2008 at 8:57 am and is filed under Freedom, P2P. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.

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