Intervention: Intervenor 49

Document Name: 2015-134.221930.2315028.Intervention(1dm@c01!).pdf

Essentially all of my content comes from online videos and video games. I also work from home (software engineer), attend meetings remotely, and use VPN access where I have to sometimes transfer GBs of data each day. The internet is as important to me as roads are for delivery trucks. Due to the nature of what I do I require significant amounts of bandwidth, data usage and low latency (playing games, real-time video chat).

Latency Requirements:

Currently, there isn’t a single ISP which provides any level of assurance on latency. In fact, I could be offered 1GBps up/down but if I have a 800ms ping, it basically is meaningless for some applications.

Interestingly, latency is hit and misses in some areas of cities with a variety of ISPs and if you are outside of the major cities it is generally awful.

It would be wonderful if ISPs had to ensure a certain level of latency (say <100ms to servers in California, etc.), just like they do with their bandwidth. It would be good if it was clearly indicated in order to allow consumers to make more informed decisions about which ISP meets their data demands. Those who play video games would enjoy a better online experience with others. People who use the internet to connect to families in other countries via video chat would benefit from reduced latency.

Bandwidth and Data Limits:

For those who get most of their video content online, like myself, having high speed internet is absolutely required for quality viewing. With the rise of 4k resolution and the fact it will be mainstream in about 5 years, if I can’t get 1Mbps then watching 720p videos requires buffering, 2Mbps required for 1080p video, and 4K will require significantly more.

Moreover, if someone watches videos roughly equal to the number of hours we watched TV 5-10 years ago (roughly 100 hours/mo). For a single person (usually more than 1 person shares the internet) to watch videos at 720p would require roughly 50GB/mo (on the low end) if they didn’t use the internet for anything else. Some of the smallest plans from some popular ISPs are capped at 100GB but offer 30Mbps download, it means yes they could watch their videos at good qualities, but with that data cap, it would barely be sufficient for a second person.

Most people who watch videos on their phones use the Wi-Fi at home instead of the mobile networks for this exact reason. What mobile network in Canada offers a 100GB plan? Therefore, they are going to end up using their home networks instead.

The CRTC currently requires ISPs provide a minimum of 5Mbps down/1Mbps up by the end of 2015.

Given the above numbers that seems to target 1-2 people per household watching 1080p videos, it won’t cover a 4K video. Moreover online game services, such as Steam, are selling the new AAA games which are 35-50GB each. A 50GB game at 5Mbps will take almost 24 hours to download! Keep in mind that is for today’s games. How big will they be in 5 years from now?

The US has recently declared the internet to be a basic utility in the US. Canada should be no different, internet should be as accessible in Canada as electricity is. I would expect 10Mbps download and 2Mbps upload to be the absolute minimum for a household. Data should be targeting at around 500GB/mo for a household. I would also expect to be able to get <200ms latency for connecting to any server or computer in Canada or US. These numbers are not crazy, look at countries in the EU for reference.

Germany for instance (1&1 DSL) has minimum plans offering 16Mbps with 300GB/mo, with the normal plan offering 50Mbps and unlimited data for only €10/mo more. They offer 100Mbps for €34.99/mo ($47/mo) with unlimited data. That kind of plan can’t even be matched in Canada.

How do these recommendations stand up against ISPs across the globe?

The mean speed for G8 countries is 30.8Mbps, and 22.91Mbps for the entire world. I also noticed a 100 person user study was being used to consider the 5Mbps down and 1Mbps upload rates. Why did the CRTC not use a highly respectable online source like Ookla ( They provide a large amount of data and could have been significantly more representative of the Canadian internet?

However, what about data limits? I don’t see any regulations on data limits, this is a huge short sight as it will become a major player in how ISPs handle the internet for consumers. This is going to become more apparent with 4K videos starting to enter the market in the next few years. The numbers I provided earlier are a pretty good starting point, but the CRTC needs to think about revisiting the numbers ever few years to ensure they are keeping up with technology.

Availability of IPv6

IPv4 is an old and outdated technology, the fact we have exhausted the pool of addresses in recent years is reinforcing the idea of migrating to IPv6. Currently, the major ISPs in Canada do not even offer IPv6 connectivity; this is a major issue that needs to be resolved sooner than later. Even if the ISPs are not selling IPv6 internet services today, they need to be offering it sooner than later. Not only does IPv6 offer higher quality internet services, it provides the groundwork for future internet services and helps reduce a number of issues created by IPv4.

The CRTC should be making IPv6 mandatory in the next few years, and have ISPs offer 4to6 services for users which cannot or do not want to upgrade. Some do not want to upgrade due to software incompatibilities which is understandable. However, since IPv6 isn’t even being offered this not providing any motivation for businesses to upgrade.

Intervention: Intervenor 49

Document Name: 2015-134.221930.2315029.Intervention(1dm@d01!).html

Copie envoyée au demandeur et à tout autre intimé si applicable / Copy sent to applicant and to any respondent if applicable: Non/No