p2pnet news view Freedom | P2P:- Yesterday (February 23) marked the deadline for Canadians to give the CRTC their thoughts on Net Neutrality.

Offically, that is.

But the shouting is far from over because the Canadian Internet Policy and Public Interest Clinic (CIPPIC) and Campaign for Democratic Media (CDM) are to make a joint formal submission to the CRTC traffic management hearing on behalf of Canadians everywhere.

You can still make your views known in a statement which includes testimony from network engineers showing ISPs have no technical need to unilaterally limit access to online services and content.

Internet experts Dr David Reed of MIT, Dr Andrew Odlyzko of the Minnesota Internet Traffic Studies (MINTS) project, and Bill S. Arnaud, chief research officer for CANARIE Inc, Canada’s Advanced Internet Development Organization, helped prepare the CIPPIC/CDM submission, says CIPPIC.

“Up until now, Canadians have enjoyed an open Internet, and we’ve thrived,” says CIPPIC acting director David Fewer, going on, “But Canadian ISPs are changing their networks, moving from an open system to a controlled system and this has implications for privacy, innovation, security, and creativity.  We felt we needed the expertise to match the importance of the issues.

“The experts who agreed to help us are at the top of their fields, and they really came through for us.”

Make sure you tell the commission what you think by visiting SaveOurNet.ca.

Until July 6, it’ll continue collecting citizen comments for use at the traffic management hearing, promises SaveOurNet.ca and CDM  co-founder Steve Anderson.

The CIPPIC/CDM submission – Campaign for Democratic Media Telecom Public Notice CRTC 2008-19: Review of the Internet Traffic Management Practices of Internet Service Providers – was prepared by former CIPPIC director Philippa Lawson, Fewer, and CIPPIC articled student Tamir Israel. Below is the executive summary »»»

Executive Summary

[1] The internet as we have known it has been an open internet, fundamentally characterized by an architecture that facilitates innovation, encourage freedom, and respects privacy. That architecture is changing.

[2] The traffic management practices scrutinized in this public hearing challenge these fundamental characteristics. These practices are changing the open architecture of the internet into one of control and interference.

[3] Traffic management is justifiable in the presence of network congestion, once that congestion is established by transparent metrics of widely accepted
tests.

[4] Traffic Interference invasive practices that interfere with end user traffic, such as application-based throttling is not necessary for ISPs to manage network congestion. Traffic Interference should be permissible only transparently, as a last resort, where finely tailored to target congestion, and where implemented in a manner that minimally impairs the user experience, and justified by Queuing Delays predicated on acceptable oversubscription ratios.

[5] It is neither necessary for ISPs to manage network congestion nor appropriate, given the many ways in which it is inconsistent with the Telecommunications Act and the fact that feasible alternatives exist.

[6] Preferable options to Traffic Interference should be exhausted before ISPs may justifiably turn to Traffic Interference. These options include:

a. upgrading network capacity this is the primary response that should be taken by ISPs; the emergence of Traffic Interference among Canadian ISPs is evidence of failure to invest in facilities;

b. demand-based pricing incentives marketplace structures that return traffic costs to users; and

c. Internet Engineering Task Force-approved traffic management methods.

[7] Internet Engineering Task Force-approved traffic management methods that should assist ISPs in addressing congestion issues include Differentiated Service Labels, Early Congestion Notification, Random Early Drops, Flow-based routing, and Traffic smoothing (or packet grooming). New traffic protocol initiatives such as fairness routing and the P4P Project also show promise as congestion management techniques.

[8] Common Traffic Interference practices include Deep Packet Inspection and RST Injections. These and other Traffic Interference practices should be permissible:

a. only transparently,

b. as a last resort,

c. where finely tailored to target congestion, and

d. where implemented in a manner that: minimally impairs the user experience, and is justified by Queuing Delays predicated on acceptable oversubscription ratios.

[9] CDM submits that transparency of ISP practices is also fundamental to the legality of traffic management practices. ISPs must be transparent as to:

a. the technical grounds supporting assertions of congestion, including timely and
public disclosure of oversubscription ratios and latency rates; and

b. communication of traffic management practices in a timely and clear fashion to both wholesale and retail customers, current and prospective.

[10] Traffic Interference violates the Telecommunications Act`s prohibition against “unjust discrimination” because there are other, less invasive/discriminatory ways of dealing with congestion problems.

[11] Traffic Interference violates the Telecommunications Act`s prohibition against controlling content or influencing the meaning and purpose of telecommunications by delaying it to such an extent as to render it unusable by users. Because content carried on throttled application communications is qualitatively distinct from other content, application-based throttling burdens such communications in violation of the Act.

[12] Traffic throttling is inconsistent with many of the objectives of the Telecommunications Act, including the protection of privacy, facilitating innovation, establishing a reliable system, and meeting user requirements.

[13] Other jurisdictions are grappling with this problem now as well. There is a growing consensus that traffic shaping is undesirable and should be only used as a last resort.

[14] This review of initiatives and approaches in other jurisdictions provides guidance for how to approach this issue in Canada:

a. Take a holistic approach Traffic management is best viewed as part of a long range view of the internet`s place in Canada.

b. Establish clear regulatory rules, not policy statements Clear, enforceable rules grounded in the Telecommunications Act, will provide Canadian ISPs,
consumers, application developers and content creators and distributors with a secure framework on which to create, innovate and invest.

c. Treat Traffic Interference as a last resort Create incentives for ISPs to invest in capacity rather than Traffic Interference.

d. Recognize that protocol-agnostic traffic management is possible Not all traffic management need amount to Traffic Interference. Canadian ISPs should be encouraged to adopt IETF-endorsed solutions.

e. Do not permit privacy-invasive traffic management techniques such as DPI There are better solutions.

f. Recognize that throttling undermines competition and choice.

g. Require public disclosure of ISP congestion and traffic management practices compulsory disclosure of baseline data levels the playing field, enhances consumer choice, permits ISPs to compete on service quality and creates incentives to invest in capacity.

h. Do not demonize P2P technology It is detrimental to Canadian distributors and creators to cripple this innovative form of distribution.

Click here for the CIPPIC/CDM submission

And stay tuned.

deadline – LAST DAY for Net Neutrality comments, February 23, 2009

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This entry was posted on Tuesday, February 24th, 2009 at 1:02 pm and is filed under Freedom, P2P. You can follow any responses to this entry through the RSS 2.0 feed. You can skip to the end and leave a response. Pinging is currently not allowed.

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