Interventions Phase 2: Intervenor 740

Document Name: 2015-134.227276.2536924.Interventions Phase 2(1$d$401!).html

Issues surrounding the supply of internet access by ISP’s in Canada.Comment to Notice: 2015-134.Supply of Access to the Internet via Internet Service Providers (ISP’s)The ISP is allowed to promote a specific speed as being available. The advertising for this speed alludes to the fact it is the speed you will have access too while using the network. Once you get access to the network via the ISP - it is normal -now- that this speed “might” occur, you are typically within a range where the average download speed is roughly 59%** of the maximum value. This needs to be addressed. Would any of the members on the CRTC committee go to a gas station to obtain fuel for their auto, and while the price could show for example 1.00/litre - if you put in what you thought was 20 litres, but only received 12 litres, would you not be upset? Further if you still had to pay for 20 litres would that also not also be upsetting if not illegal? This example is no different from obtaining internet access. We are forced to accept that the “maximum” we can get is the speed offered in a package - and we are to further accept that we will not likely have that ongoing. All reasonable people know that if offered for example 25 mbps down speed, that it is likely to be less at some point. However what we ask the committee to consider is that for any offered package download and upload speeds, that the range must be maintained within a specified margin and this needs to be stipulated within the advertisement for the package. A reasonable range would be 75% of the advertised speed as a minimum, and only at the minimum of that range for 20% of the time. As an example, for a 25 mbps down package, the range would be between 18 - 25 mb/s. The monthly provided service should be maintained within this range with an average of 21 mb/s for each day of the month.There are days where the download speed is quite good, there are days where it is well below the 5 mb/s mandated by the CRTC for download speed after November 2015. To get this corrected required many hours of dealing with the ISP customer service (9 hours on the phone over several days - a very time consuming, costly and demeaning approach to a customer with a problem.)It is not acceptable and no reasonable person could disagree - that to pay for something and not have it provided, is acceptable.** This value is calculated based on data collected over 50 days, with 500 data points.Traffic Management Policy (Colloquial - “Throttling”)The CRTC allows ISP’s to control the “speed” or available data throughput to be able to manage the supply of bandwidth for all users. At times there are instances where the use outstrips the currently available bandwidth. Quite frankly, this is not a problem for the end user - it is a problem of insufficient supply. Why should all users who have been offered the use of the service providers bandwidth, summarily be prevented from access simply because the available bandwidth has been over sold? The requirement of a “Traffic Management Policy” seems to support the ISP to over sell their available bandwidth since they don’t have to maintain the full volume of bandwidth sold. Further, the controlling of band width to prevent over usage is a real requirement - ISP’s need to ensure that there is access available for all users. If there is a user who is over using the available band width,then quite rightly they should be penalized. However that should not apply to all users within the usage area. There needs to be a more equitable approach to this issue. Simply allowing the ISP to post a “Traffic Management policy” is not acceptable. This has been used in a manner tantamount to a “club” on those complaining of slow speeds - when it is not valid for the particular end user. It is used to justify the actions or inactions of the ISP to clear up issues. If a “Traffic Management” method is to be maintained, it must be more realistic. A suggestion is that the minimum level to which the ISP can slow traffic for any user would be 5 mbps. For chronic over users, then other actions need to be taken - with for example a warning first and if no change occurs allow the ISP to remove service to protect their other customers. Simply being able to stipulate that we can take the service to - for example - to 300 kbps, is not realistic in this day and age. The application of these policies - in an arbitrary manner such as is being done now, means that we cannot access the new Canadian Entertainment content from Shomi and Crave as examples. Unless we can be assured that our access will be uninterrupted, why pay for these. Again, if you can’t get it and maintain when you do have it, then why bother in the first place.ISP’s - Issues of Access:As a user of the internet - wishing to avail ourselves of the new technology for entertainment, a more robust approach needs to be taken. For those in areas where only 1 provider is available, there needs to be more control over their approach to basically a monopoly on supply. There are many areas within Canada that have only 1 service provider. For example - in the Queensville area of Ontario - if you look up the — TOWN of Queensville - it will show that there are several providers. However the “TOWN” encompasses a significantly large rural area - where these providers do not have service. In our instance, while the actual town has Rogers; Bell; plus others - we in the rural area have only access via one source - Xplornet. It is important that those who only have access via one source should be protected via a “Code of Conduct” - from the CRTC that outlines the basic service that must be maintained. We know that the CRTC does not involve itself in the day to day running of a business, but within the Code should it be constructed - be a stipulation on access to the ISP. The comment here is that since the ISP functions primarily like a monopoly - they then make it difficult to deal with them. For example waiting for a Customer Service person for anywhere up to 50 minutes - when you have an issue - is just blatantly unacceptable. There are methods of dealing with high demand, that don’t include having you wait on the other end of a phone for that long. In the overall presented above, we are suggesting that ISP’s have:Advertising that is realistic - and not suggestive of things that really won’t be available as an ongoing availability;What is advertised as an available access speed - be specifically outlined for the min/max and average per day; this would make the choosing of a provider much more realistic to the public;Traffic Management be more for those who overuse - and not used as a business model to allow for over selling of the available band width;More accountability for ISP’s who have what is tantamount to a monopoly in certain areas; to remove the take it or leave it attitude.More sustainability - to allow Canadians to be able to utilize the present and future electronic media - to make Canada number 1.