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MisawaGQ
Divi Filius
Premium
join:2002-12-19
Mississauga
1 edit | reply to oh LOOK
Re: Bells NEW July 11th CRTC Submission
It's hard to believe a multi-billion dollar corporation would be so lax and sloppy in dealing with the government. But, I guess this document is legitimate, and the proof is in the pudding. Do they seriously believe such blatant lies and half-truths are going to be taken at face value? The CAIP is going to have no trouble at all totally debunking this nonsense. It really is puzzling, but also hilarious.
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"Let them hate, so long as they fear" -- Lucius Accius | |
Maynard G Krebs
@teksavvy.com
| reply to oh LOOK
ES12 comments
Bell says in ES12,
"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. As the Company is applying the same treatment to traffic of its own retail Internet access service end-users and GAS end-users, the Commission cannot find that the Company is conferring unto itself a preference, let alone an undue preference."
1) Bell is conflating "GAS end users" with Sympatico users. GAS end users are in fact CAIP customers, who have no business relationship with Bell. CAIP members sell access to GAS indirectly under different T&C's than Bell does to Sympatico customers. Bell has no knowledge of CAIP 'end users'. This has ALWAYS been the intent of the CRTC wrt GAS services.
2) GAS service is a tariffed service, whereas Sympatico retail service is not, and as such the constant reference to Sympatico users is irrelevant. Again another misdirection by Bell.
3) Were retail internet services in fact tariffed, then no CAIP member could have EVER offered something different than something identical to those services and T&C's as Sympatico's. The CRTC clearly intended that independent ISP's were free to set their own T&C's when using tariffed GAS when they set forth the GAS service tariff in the first place.
4) Bell continually misdirects and misunderstands that CAIP is not reselling Sympatico services, otherwise we'd all be required to suffer the indignities of Sympatico Hotmail and other such garbage provided by Bell with their Sympatico service (connection managers, BLnnn numbers, etc....).
5) Bell has no 'ownership' of the activities, nor 'interest' in the data of any CAIP customer who uses GAS services provided by CAIP members as *their* ISP.
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What Bell is trying to assert is analogous to a trucking company hired to deliver a washing machine to a Futureshop customer stating that it has has the unilateral right to use a Smart car to deliver the washing machine to the end user in disassembled form, in multiple deliveries, and to lose pieces of the washing machine along the way, and to not be responsible for any damages or loses incurred. Any reputable common carrier company, should they be unable to deliver in accordance with their agreement with Futureshop, would 'buy' additional capacity in order to deliver on-time as contracted. Not so Bell.
Another absurd but effective way to look at it is an office analogy. Bell owns an office building and leases a floor to Teksavvy under contract. During the term of the contract Bell unilaterally decides that not only does Teksavvy have to force its employees to wear suits and ties (and not play baskeketball in the office) but that Teksavvy's customers also have to wear suits and ties between the hours of 4:30pm and 2am (because Bell employees and customers are forced to do so by Bell).
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The CRTC has to be made to understand that I, as a Teksavvy customer, have NO contractual arrangement with Bell Canada in any way, shape, or form, and as such cannot be forced to comply with any demands of Bell Canada with respect to my use of the internet service I purchase from Teksavvy, nor can any T&C's be forced upon me by Bell.
Any attempt by Bell to force any T&C's on me is abusive, coercive, and is most likely an offence under the Criminal Code of Canada - Part IX Offences Against Rights of Property, S.322, S.326, S.342
Section 326 is the section famously added to the Criminal Code years ago when telephone 'phreaking' was first beginning.
Theft of Telecommunication Service
326. (1) Every one commits theft who fraudulently, maliciously, or without colour of right,
(a) abstracts, consumes or uses electricity or gas or causes it to be wasted or diverted;
Throttling, by definition, causes the waste of electricity by each person upon each occurrence of throttling. Bell is by definition liable under S.326(1)(a) for billions of instances of theft.
Don't think that S326(1)(a) is toothless - there have been convictions under this.
Also,
Unauthorized use of computer
342.1 (1) Every one who, fraudulently and without colour of right,
(b) by means of an electro-magnetic, acoustic, mechanical or other device, intercepts or causes to be intercepted, directly or indirectly, any function of a computer system, [DPI anyone?]
(c) uses or causes to be used, directly or indirectly, a computer system with intent to commit an offence under paragraph (a) or (b) or an offence under section 430 in relation to data or a computer system, | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC | Oh man, Bell has certaintly given us a LOT to chew on.
We'll get very fat dining on all those arguments against Bell.
I am up to paragraph 50 and it isn't even midway though. | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
 ·ELECTRONICBOX
| reply to oh LOOK
Re: Bells NEW July 11th CRTC Submission
##
7. It must be noted that the Company, as a Canadian Carrier, is in control of its own network and is free to implement the standards and specifications of its choice within its network
##
Once implemented and regulated by CRTC, changes to the above require CRTC discussion and approval. Bell argues that it can change anything at whim and decide whether it has any impact on customers or not. This must not be tolerated.
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##
10. In order for readers to fully understand the issues, the Company will follow with a description of the technologies involved including: a description of how traffic is routed on the Internet, how devices and applications on the Internet handle congestion followed by a description of peer-to-peer (P2P) technology.
##
This is about GAS/5410, not IP or TCPIP or about the internet.
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##
21. The incorrect premises lead to invalid calculations and comparisons, which only serves to confuse the relevant issues. At the outset, because of the nature of DSL services, it is impossible for the Company to promise a specific bandwidth to high-speed service end-users (retail or wholesale GAS). Therefore, these services are marketed with an "up to" speed (such as 5 Mbps in the case of GAS). This is a fact that all ISPs are aware of, including CAIP:
##
This is about the copper loop line quality which does not garantee the actual sync speeds capable of being achieved, But once sync has been achieved at a speed of up to 5mbps, there is every expectation of being able to use that speed due to the dedicated nature of each ADSL loop.
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22. Furthermore, the traffic shaping that Bell applies is limited to P2P file sharing applications during peak periods, and does not impact the speed for other applications such as web browsing or video streaming such that simultaneous use of other non P2P file sharing applications is not affected.
##
GAS is not sold as a web browsing or video streaming service. It is to be a transparent logical path between an end user and its service provider and Bell Canada has no business deciding what type of data flows at what speed. It is not correct for it to state that some data is time sensitive and others is not. A doctor expecting to receive a large animated 3D cat-scan via BitTorrent would not be happy to be throttled at 30KB/s when a patient is awaiting diagnosis.
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25 ...
Competitors will likely continue to select an AHSSPI based on the lower tariff rates for GigE links and use the peak utilization as an additional factor in their decision process irrespective of fluctuations in traffic.
##
Competitors will adjust the amount of AHSSPI capacity the buy from Bell based also on the average utilisation of their customers. As internet usage patterns change, they will purchase more AHSSPI bandwidth per customer. Bell attributes increase in purchased AHSSPI only to grown in number of customers, when increased AHSSPI is the result of both increased number of customers, AND increased average use.
So competitors fully pay for the bandwidth generated by their customers and Bell must be made to provide this bandwidth without any discrimination on data type.
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26. In addition, CAIP notes that its "members typically plan for additional capacity when peak AHSSPI utilisation rates hover between 50 and 60 percent of the total capacity of the AHSSPI". The table shows that even after shaping the utilization level surpasses the level where additional capacity should be planned for.
##
Bell's current limited AHSSPI load balancing technology may result in individual links to an ISP to have high utilisation rates for a period of time while the other links to the same ISP are lower. Bell cannot look at individual events of indiviudual links, it must look at a big picture of what an ISP pays versus what is being used on average for the combination of all purchased links.)
aka: 1 of 2 links at 100% while the second one is at 0% means an average of 50% which should be achieved over time as disconnected PPPoE sessions reconnect to the second link.
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GENERAL
Bell makes multiple allusions that HSA is to provided a fixed IP. This is not the case. HSA is just a permanent virtual circuit between the end user and the ISP while GAS is a switched virtual circuit using different protocol.
The types of IP assigned (fixed or dynamic) is irrespecive of whether it is on GAS or HSA and both types can be provisioned by the service provider on either services. This is beyond the scope of GAS/5410 which deals with PPPoE service. (HSA deals with transport of ethernet frames).
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Bell Canada also estimated that in Ontario and Québec, 95% of the SMB customers were in the footprint of a cable operator
##
Cable wholesalers are not allowed to have customers run servers due to the sensitive nature of the upload on shared cable. (as per the tariff with videotron, don't remember the exact number, but I send a private DSLR-IM to ebox on that).
Therefore, for SMBs, cable is not really a viable alternative unless they just use the srevice to browse the web.
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29...
HSA is an alternative to business end-users
Because HSA has an artificially inflated price and lack of modern management software to make its management simpler, Bell clearly does not wish HSA to become popular (whereas HSA is standard in Telus territory)
If the majority of customers moved to HSA, would Bell install DPI equipment on HSA links as well to prevent use of whatever applications Bell has decided take up too much bandwidth ?
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32...
Internet applications use well defined protocols to communicate between parties. In order to get data (i.e., content) to another party on the Internet, the application will first format the data and header information (e.g. the recipient’s email address in the case of an email application) will be added
For email (SMTP), the application protocol, RFC 821, and the email headers, RFC822 are all fully within the DATA (payload) portion of packets. The email destination is NOT inside the envelope of the TCPIP packets.
RFC821 does not define an application "header". It defines a dialogue between 2 hosts to negotiate delivery of data. This dialogue happens 100% within the data portion of packets, defines SMTP server, the sender and recipient email addresses and is followed by the a stream of bytes that contain textual representation of the message structure (RFC822) and textual contents of the message.
THERE IS NO SUCH THING AS APPLICATION HEADER
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34...
These application specific protocols are described via a set of protocol headers that are typically transferred at the initial setup phase of the communication between the two end-points.
False.
Applications define how they work. The analogy would be close to record formats than to "application headers" since a whole record may have a series of protocol bytes followed by a number of data bytes, or it may have on large control structure in a specific location in the record that defines where the data is on that record.
This is no different than an ATM transation record layout which defined in which bytes the card number, pin, transaction type and transaction amount should be placed and how large each field is. This is very private information of the payload and Bell Canada has absolutely no business knowing about this for in links such as GAS.
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First part of paragraph 36 is correct. However, having over 20% packet loss over a 9.5 hour period is way above network congestion handling. The TCP congestion handling was designed to handle short period of congestion, and in the case of ISPs, if a transit provider has significant and consistent periods of congested links, the ISP will choose another transit provider.
ISPs do not have the choice of selecting another ADSL access provider, so Bell must be made to manage its network to keep dropped packest to a minumum.
And since this is a PPPoE network, Bell Canada must have no knowledge of what their contents are. Since PPPoE packets can contains data which does not handle loss of packets gracefully (such as IP-UDP or other protocols), Bell Canada has no right to unilaterally decided to drop 20% of certain packets because it muct not have the right to inspect the payload of the PPPoE packet.
Paragraph 36 again: Discussion of jitter. It is muy experience that the jitter on the link between end user and ISP was less than 1ms and was pretty stable. Bell has not made public any numbers that show jitter to be a significant and pervasive problem throughout its network.
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37. Therefore, different web applications have, by necessity, different Quality of Service (QoS) requirements.
##
"web" implies HTTP application protocol. Shows that Bell doesn't quite understand what it is talking about. This is an important issue and Bell should be using precise terminology.
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38: Bell provides a PPPoE service. It has no business deciding what applications are time sensitive and which are not. As stated before, there are time sensitive P2P applications being crippled by Bell.
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And even for a file transfer, Bell's crippling makes a 1 hour file transfer can take over 11 hours. Not everyone has the luxury of waiting until 02:00 to get a file transfer started.
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##
39. ... But what happens when applications behave differently, such as P2P?
##
BitTorrent uses no special TCP techniques. It uses the same TCP throughput management as any other TCP application. The Bittorrent protocol definition clearly states that. In fact, BitTorrent uses additional techniques to detect congested links, declare them as "choked" and focus on using uncongested links instead.
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GENERAL:
If Bell Canada can pronounce Skype and Joost and HTTP protocols, why can't it define its throttling be limited to BitTorrent ?
Because if it were to use "BitTorrent", it would be accused and sued by BitTorrent corp. of discrimination and causing harm to a competitor. BitTorrent is not only a protocol, but it is also a commercial operation that competes against the Bell Video Store.
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42: It is not up to Bell to decide which files are "time sensitive" or which one should be throttled to day days to transfer. Data is data and whether it is coming from the Bell Video Store or some Bittorrent Peers makes no difference at the PPPoE level: the same number of packets are being transmitted.
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##
44.
Chief Strategist, Mike Lee, P2P is "actually designed to overwhelm other traffic." A P2P application, rather than opening up only one stream or session, will open up 40 to 100 TCP sessions in an effort to transfer data as fast as possible using multiple sources and can therefore grab dozens to 100s times more bandwidth than a traditional single-stream application such as email or Internet banking applications (see Figure 4 below).
##
THIS IS FALSE. First and foremost, GAS deals at the PPPoE level. It is fully unaware of the number of TCP sessions currently opened.
Secondly, at the ISP and transit provider level, the number of outstanding TCP sessions is not known. They deal with routing of packets at the IP level and do not follow how many "opened sesssions" at the TCP level exist.
Third, the big difference resides at the customer premise equipment, notably the computer which maintains the data structures to remember the multiple sessions, as well as the NAT router which must remember how each TCP session is mapped between the internet side and the LAN side.
Fourth, whether you have 1 , 2 or 100 TCP sesions running, THE PIPE REMAINS THE SAME SIZE AND YOU CANNOT USE MORE SPEED THAN THE PIPE ALLOWS NO MATTER HOW MANY TCP SESSIONS YOU HAVE.
The TCP "session" is a virtual concept that exists between 2 computers and is not maintained nor managed by an internet network provider in any way.
Rogers has proxy servers used to insert content in HTTP transactions, and those servers would be aware of TCP connections since they need to fake connectivity so that the inserted packets can appear to be "native" to the data stream.
##
By initiating more and more P2P applications on powerful computers, the user will continue to expand the number of active streams eventually consuming all available bandwidth.
##
If you have one peer giving you 4.5mbps of data, it is no different than 10 peers giving you 450kbps each, or 100 peers giving you 45kbps. They will all give you data as fast as the slowest link between them and you allows.
THERE IS NOTHING WRONG WITH USING A PIPE'S CAPACITY. ALL APPLICATIONS TRY TO DO THAT. BitTorrent simply distributes the load between many peers instead of focusing on a mega central server. But at each end point, there is no difference.
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##
45. Second, once all the available bandwidth is being consumed, TCP, through its windowing technique mentioned above will use a queuing technique for additional requests until more bandwidth becomes available
##
This is false. TCP allows the sender to send a certain amount of data that is not yet acknowledged by the receiver. (window size). If there is a lost packet, the recipient will stop acknowledging at the last byte in the packet preceding the lost packet. The sender will eventually stop once it has sent "window size" bytes after that last acknoledged byte and realise it needs to resend the lost packet again. This introduces a gap between packets which reduces throughput.
There is no "queueing until more bandwidth becomes available".
The windowing exists to cope with the fact that it can take a signifiacnt amount of time for packets to reach destination and an equal amount of time for their acknoledgement to reach the sender.
##
In addition, P2P applications typically have slots for the total number of downloads. Once the total number of slots is consumed, the P2P application will use a queuing technique for additional file downloads until additional slots become available.
##
This is correct.
##
The P2P application queuing of multiple requests combined with TCP windowing and the inherent application persistence of P2P enable it to 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.
##
The queueing is done purely at the application level and is irrelevant to the network. What counts in the context of GAS is how much data goes through the ADSL modem and how the application on a computer processes that data is absolutely irrelevant to this service.
The TCP protocol was designed to allow continuous sending of data over long links by having an appropriately sized window. If Bell Canada is unhappy with the design of TCP and IP, it should get out of the business. A network oprovider is expected to HELP customers carry data from point A to point B as fast as possible instead of HINDER the use of the service.
-=---------------------------------------------------------
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46. Finally, it is not enough to simply manage the traffic of the network's users. Some P2P file sharing applications constantly 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
##
NEVER does BitTorrent or any application exceed the speed which was assigned to the link. With whom a BitTorrent user exchanges data is none of Bell Canada business. If BitTorrent connects to a remote peer that has spare bandwidth, it makes absolutely no difference to Bell. Bell is given the responsibility of providing the ADSL link and carry PPPoE packets between the end user and the ISP and there is absolutely no knowledge at the PPPoE level of what is going on inside the packets or with whom an end user has connected. This is private data. Bell connects the user to his ISP. It does not connect users to users.
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##
47. Thus, P2P file sharing applications not only generate considerably more traffic volume in the long run because it runs for a lengthy amount of time,
##
DOWNLOADING A MOVIE VIA UNTHROTTLED BITTORRENT WILL TAKE THE SAME AMOUNT OF TIME AS DOWNLOADING IT FROM BELL'S VIDEO STORE.
THE ABOVE STATEMENT IS PATENTLY FALSE.
##
it also uses up the major share of the available bandwidth at any given point in time because it uses so many concurrent TCP sessions
##
This is patently FALSE. It will use as much bandwidth as is available, just like any other application. And at the Bell Canada (GAS/5410) level, this is ABSOLUTELY inconsequential since Bell just carries PPPOE packet and is unaware of whether the user is using IP, IP_TCP, IP-UDP or whatever protocols.
The issue of multiple TCP sessions has been debunked already.
##
Therefore, hundreds of TCP sessions generated by a single user, or users from other networks, will negatively impact the experience of many others
##
THIS IS ABSOLUTELY FALSE. It will use the same amount of bandwdith that is available, namely the speed of the ADSL link and no more. This is no different from the amount of data/bandwidth generated when downloading a movie from the Bell Video Store.
##
This is compounded by the fact that P2P file sharing users tend to initiate multiple large file downloads and simply leave the application downloading and/or uploading pieces of content.
##
This is lore unsupported by any facts or statistics. People dowload what they need, and they purchase a service that provides for monthly download limits that they need. In return, the ISP buys sufficient bandwithd to support its customers' type of usage.
BitTorrent can be used to transfer small or large files. Just because it *can* be used to transfer multiple large files at the same time (taking a longer time to complete) does not mean that this is what people do in practice.
However, since Bell has begun to cripple BitTorrent, many transfers are now measured in days instead of hours, but this is because one is unable to achieve speeds during the periods of time when the data is most available.
OUF ! that was a long paragraph to comment !
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48...
P2P file sharing does not diminish costs, rather it offloads the hosting and server costs from a content provider to the ISP's network
No. It moves costs to each peer on the network. Since each peers pays his ISP to use the network to a certain amount, then it is the peer which pays for it.
This allows the information provider to be more competitive since its own bandwidth costs are much lower since purchasers of the products end up paying for the bandwdith.
This is not different from the NNTP protocol as originally envisaged where it was also in a peer-to-peer exchange of posts and each NNTP server was expected to serve other servers, thus distributing the tramnsmission costs of all of the worldwide content.
##
In other words, P2P file sharing creates a negative externality for facilities based ISPs.
##
These ISPs buy more bandwdith from internet transit providers, as well as more AHSSPI/GAS bandwidth to support this type of activity and Bell shoudl just provide the purchased bandwdith. The ISP is the one who decides how much to charge each of its customers and how much data each customer can exchange each month.
##
One could argue that content providers need to be motivated to develop a more efficient method of distribution that takes into account network operator concerns.
##
The developpers of BitTorrent adhered to the IP and TCP protocols to the letter and designed their application to make the most efficient use of these protocols.
If Bell Canada sets Sympatico users to 7mbps ADSL speeds but has not upgraded its underlying access capacity, then the fault lies with Bell Canada and only with Bell Canada.
Bell Canada advertises a 5mbps product to the indepedant ISPs. The independant ISPs are perfectly capable and willing to handle the load at their end, and have paid Bell Canada to handle that load. It is Bell Canada which in unable to provide the service which it advertises and which was paid for by the ISPs. Bell Canada has nobody but itself to blame.
BELL CANADA MUST ONLY ADVERTISE SPEEDS WHICH IT CAN SUPPORT. It cannot blame any one application that makes legitimate use of purchased bandwidth.
And there is no definition within the GAS/5410 tariff of what "acceptable speed" is. Bell Cannot pull some random number out of a hat and unilaterallly declate that anything above 30kb/s is considered "abuse" when it continue to advertise 7mbps speeds to the public. (while only giving 5mbps to competitors)
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Paragraph 49:
***ALL*** applications are designed to use all of the available bandwidth.
BitTorrent is no different. The advent of high speed internet access has enabled new applications which have seen the need to transfer much larger files than before. It has also seen richer HTML content with web pages filled with unnecessary images, and megabytes of unnecessary javascript to please the marketing departments.
There is no question that demand on networks is increasing as more and more people start to consume richer media files. Internet transit networks are coping quite well and are happy with the extra business. Bell Canada should be happy to see ISPs purchase more AHSSPI bandwidth and shoudl strive to be ahead of demand. Bell is now admitting that they have fallen behind the demand, despite ISPs having been paying for the bandwidth.
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(continued in next email)
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Bellundo
@teksavvy.com
| reply to oh LOOK
Traffic shaping is not a notifiable change??!! I hope bell gets sued to the bull's tits over this one. The small claims court of Ontario apparently is as clueless as the general public when it comes to the internet or they'd award the subscribers the maximum under Ontario law over bell's illegal 100 dollar fee. I think the maximum is something like 50,000 dollars in Ontario. If such a thing like this happened in America the FCC would have slapped any isp with a fine the very same day. | |
Ikarasu
join:2004-01-09
Port Coquitlam, BC | It did happen... with Comcast, and theyre not being charged a fee :P
Either way... wow, a lot of useless, inacurate facts from bell. I was worried how CRTC would decide, but after this... it should be a clear choice for them. | |
davidbrown
join:2005-05-31
Toronto, ON
·Bell Sympatico
1 edit | reply to oh LOOK
Don't be certain the crtc is going to side with us on this because of the paper.
Whats needed is a public display were they get caught lieing or a highly regarded expert who can publicly and professional tear this bs apart.
If it can't be kept hidden and the proof is undeniable the crtc is going to have little choice but side against bell.
If the laymen knows he getting hosed and in a way that he can understand bell is toast.
If bell gets its wish and keeps this out of the public there is little chance the crtc is going to side against bell in any meaningful way. | |
HoboJ
join:2008-03-27
Trenton, ON
·TekSavvy Solutions..
 ·voip.ms
 ·Cogeco Cable
| reply to oh LOOK
It definitely wouldn't surprise me if Bell hasn't greased some influential palms in the CRTC. Unless Bells bullshit gets refuted in the mainstream media I have little faith the CRTC will side with us; regardless of the overwhelming evidence in support of our cause. | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to oh LOOK
Damned this is long !
Re: paragraphs 50 to 57.
YEP, the internet is growing. If this is news to Bell, then Bell is incompetant, and it has no excuse to not have been proactive and updated its infrastructure at greater pace.
The current GA/5410 tariffs alrteady provide for revenus based on usage since ISPs must purchase sufficient AHSSPI capacity to cope with user demand. As usage increases, ISPs buy more capacity from Bell and Bell should upgrade its network accordingly. Period.
Internet transit providers are more than happy to sell more bandwidth to their customers. Why isn't Bell ?
Paragraph 58: Mobile data usage is inconsequential to GAS/5410 and the amounts transfered are microscopic due to high data package costs in Canada.
RFID is not related to the internet. This is just filler to make document longer.
Paragraph 59 is filler. Web based applications are just data abeing transfered over the wire.
Paragraph 60: Yes, remote backup is to be another big user of data transfer. Will Bell throttle it when data rates exceed 30kbps ?
Paragraph 62: If congestion happens only at the Bell network, and ISPs have been able to upgrade their own facilities and internet connection capacity, then shoudln't Bell be blaming itself instead of blaming others ?
In recent years, Bell has upper the default ADSL speed from 1.3 to 7 mbps. This represents a 530% speed increase. Did Bell Canada also increase its backbone capacity by 530%. For every ADSL speed increase Bell Canada wants to be able to advertise against Cable, Bell must also increase backbone capacity to be able to deliver those speeds.
Paragraph 67: Yep, dropped packets force retransmissions and end up reducing network throughput. So why is Bell dropping over 20% of BitTorrent packets in its PPPoE service ?
Paragraph 71: Bell does not mention ethernet links. Since the GAS/AHSSPI is moving towards Gigabit Ethernet, this is the primary consideration for the future. One should not look at antique links that are scheduled to be replaced in the near term to determine whether long term DPI equipment should be allowed.
Paragraph 79 (congestion).
Of the congested links, what percentage were ATM based versus Gigabit ethernet based ? AKA: if congestion happens only on legacy equipment scheduled to be replaced, then the push would be to acceleratethe replacement instead of installing DPI.
And if they thottle BitTorrent, then they already admit other applications will also cause problems. The solution is to match access network capacity to the ADSL speeds that end users are given and let ISPs buy what they need.
Paragraph 87: Only increasing capacity applies to GAS/AHSSPI. The rest of the elements mentioned in paragrpah 87 are Sympatico's jurisdiction.
Paragraph 88: How much of the 3 billion was invested in the GAS/AHSSPI network versus Bell's backbone vs Bell's Internet network (AS577). And how much of that did Bell spend to hire Microsoft to run Sympatico's mail and web sites ?
Figure 14 is interesting. Does backbone refer to AHSSPI, or to some other network (such as its internet AS577 network which is not connected to GAS/AHSSPI) ?
estimated numbers based on figure 14:
DSLAM AGGREGATION BACKBONE
2003 215 110 x
2004 277 117 115
2005 317 140 170
2006 380 150 260
2007 425 165 530
DSLAM capacity grew by 97.6%, or average of 24.4% per year
Aggregation grew by 50% or average of 12.5% per year
backbone grew by 415% or average of 138.3% per year
It is VERY VERY clear that Bell has not invested in the aggregation network as it should have.
Looking at another way:
2003: DSLAM was 195% of aggregation.
2004: DSLAM was 236% of aggregation. BACKBONE was 95% of aggregation
2005: DSLAM was 226% of aggregation. backbone was 121% of aggregation
2006: DSLAM was 253% of aggregation. backbone was 173% of aggregation
2007: DSLAM was 257% of aggregation. backbone was 321% of aggregation
Since we don't know what "backbone" means, we can't judge it except to say that it grew by 415% and this is where Bell evidently put more of the money.
No matter whether the DSLAM capacity represents actual capacity (number of users * average speed given to users), or whether it represents max capacity (theoretical ADSL-1 limit of 8mbps down and 1mbps up * number of installed ports), it is clear that the aggregation network did not get an investment that is commisurate with the DSLAM and backbone networks.
So during this time, Bell increased its DSLAM speeds from 1.7 to 5.0mbps (nearly 200% increase in speed, and thus potential capacity requirement), and did not match the aggregation speed.
One would have to ask wehther the very modest investment in aggregation capacity even matched the increase in number of users.
It is also very clear that Bell has allowed the disparity between aggregation and DSLAM/backbone to get worse, creating an even greater inability to deliver the services that are being sold.
THEORETICALLY, aggregation should have same capacity as DSLAMS.
In practice, Bell can get away with less by studying usage patterns, BUT when usage patterns change, Bell MUST adapt and not complain.
Up to now, Bell got away with an underprovisionned aggregation network. Now, it is failing to deliver advertised services which are also regulated by the CRTC.
The installation of DPI equipment is making things even worse since Bell delivers even less capacity at the aggregation point.
Paragraph 91: IMPORTANT: Why is this technique of network management not acceptable ? (increase capacity when they see links that are close to congestion).
Paragraph 95: Bell should be made to provide % of DSLAMS that are on ethernet vs those that are on legacy ATM, and provide year by year estimate of progression of conversion to GigE links. This should be a high priority since aggregation is clearly underprovisioned compared to DSLAM.
Paragraphs 101: why is Bell increasing ADSL speeds at a faster rate than it can upgrade DSLAMs and the links to support them ?
Patagraph 102: it is the cost of mobile text which is exhorbitant and far more expensive than Bell's old Datapac network. The comparison is meaningless. Rocky can probably provide internet transit costs as a base reference to what todays "wireline" costs really are.
Paragraph 103: This would have to be Sympatico and totally irrelevant to GAS/AHSSPI.
Paragraph 104: As a result, in addition to expanding capacity, Bell Canada uses pricing-based mechanisms to manage network traffic such as bandwidth caps and usage-based pricing. This type of differential pricing is beneficial to both consumers and carriers because it matches prices to use, which provides the appropriate incentives for optimal network use and expansion.
This is not applicable to GAS/AHSSPI tariff since 5410 is based on a flat fee per user for the ADSL link, and the AHSSPI bandwidth purchases to cover the conveyance of packets from ADSL line to the ISP's premises.
If users consume more bandwidth, ISPs have to purchase more AHSSPI from Bell so Bell should not try to prevent delivery of this purchased bandwidth.
Bell has not stated (so far) that the GAS/AHSSPI rates are insufficient to pay for the network upgrades necessary to provide the purchased services.
Paragrpah 105: again the mention of usage based billing. Not applicable to GAS/5410.
Paragraph 110: The Company has observed that non P2P traffic has significantly increased since it deployed traffic shaping during peak periods. This increase is likely a result of two main events: 1) non P2P traffic is now able to use up and flow more freely using the bandwidth previously occupied by P2P traffic,
This is absolutely BOGUS. With BitTorrent uncrippled, people were still accessing the web unhindred and not aware for the extreme vast majority of any congestion. Crippling BitTorrent did not magically allow people to use aopplications that they could not use in the past.
##
A full year of data would be needed to better understand the benefits to non P2P file sharing traffic that are directly associated with the implementation of traffic shaping.
##
Don't let Bell get away with this one. We don't want the CRTC to allow the DPI equipment to stay in place for a full year. That is tantamount to accepting it permanently.
114: 114. Before the introduction of DPI, network equipment or routers only looked at the destination IP addresses to determine where to send data, and in order to preserve network integrity (such as protecting the network against viruses).
BELL CANADA HAS NO BUSINESS LOOKING AT IP ADDRESSES SINCE IT THIS IS A PPPOE SERVICE. It does not IP routing of user packets.
Paragraph 115: Since Bell Canada will not divuilge the extact filters that they apply, the CRTC is not in a position to judge exactly what Bell is doing to what sort of private data, and neither are the independant ISPs who cannot define what service they are really offering to their customers.
One important question to ask: Since BiTtorrent has the ability to use encrypted links which means that Bell may not see a "signature" in the data, how does Bell find out that an encrypted link is BitTorrent and not something else ? (conclusion, it is likely that bell is throttling anythng that is encrypted unless it is on a specific well known port for certain types of VPN)
paragraph 117: this is why more and more consumer grade routers support QoS sertvice where the customer can give priority to packets coming from a certain device or using a certain port. This is the customer responsability to define which applications have priority for the bandwidth. It is none of Bell's business.
More in part 2 cont2  | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to oh LOOK
Man, this document is long.
Reading is makes you lose focus. I can see Bell's tactics now. They "sort of" tackle all aspects and give an imporession that they have dealt and won each issue. And you tend to forget the original arguments.
Damned, and I thought my documeht was long at 29 pages ! At least I had a few pretty pictures
BTW, a lot of the bell document is a rehash of previous documents.
CAIP's people will be pretty busy in the next few days. | |
tertech
join:2008-04-12
Ottawa, ON
| said by jfmezei  :Man, this document is long. Reading is makes you lose focus. I can see Bell's tactics now. They "sort of" tackle all aspects and give an imporession that they have dealt and won each issue. And you tend to forget the original arguments. Damned, and I thought my documeht was long at 29 pages ! At least I had a few pretty pictures BTW, a lot of the bell document is a rehash of previous documents. CAIP's people will be pretty busy in the next few days. Did you see the part where they called one of your statements "ridiculous"? I nearly fell off the chair. | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| >Did you see the part where they called one of your statements "ridiculous"? I nearly fell off the chair.
Hey, you should have prexied it with "SPOILER ALERT"... It ruins the entertainment value of this 86 page ordeal !
I am only up to page 73. I suspect any comments about my submission would be todards the end since Bell obviously had aboilerplate of this document long ago. It includes much previously released material. | |
Omr
join:2004-01-10
M1S-1B3
| reply to oh LOOK
quote:
20.Based on these premises, parties throughout their submissions compare the theoretical speed of the GAS service with the reduced speed applicable to a single type of application (i.e., P2P file sharing applications) during peak periods when traffic shaping takes place. These parties then draw the ridiculous conclusion that Bell “cripples the ADSL by approximately 90%”14 or “Since Bell throttles downstream speeds to 30 KB/s (or 240 kbps)15, this represents only 4.8% of the Basic - Residence downstream speed of 5 Mbps referenced in Bell’s GAS tariff.”16
WTF is that supposed to mean? Is it me or is that just a play on word designed to spin? How ridiculous we don't cripple by 90% but rather cripple you to 5% (in other words by 95%). Bell has lost it they are all a bunch of fucking sleazeball assholes. A boardroom full of douches so out of touch with reality that they need to feel a corporate bitch slap. If you smell what the Rocky is cooking  . | |
tertech
join:2008-04-12
Ottawa, ON
1 edit | reply to jfmezei
19.According to CAIP and Vaxination: i) “The purpose of GAS is to create a pipe or pathway that runs from the premises of each end-user customer through Bell’s central offices (COs) and then on to a physical interface point in Bell’s local network where competitors must interconnect in order to gain access to their customer’s traffic”12, and ii) “A service provider pays a GAS/HSA for each individual ADSL line. The service provider should have full and unqualified access to the bandwidth of each ADSL line the service provider pays for. A service provider also buys sufficient capacity in the “Aggregated High-Speed Service Provider Interface” (AHSSPI) to support the link between itself and the Bell ADSL cloud. Bell is therefore already compensated on the number of customers as well as the total bandwidth generated by those customers.”13
20.Based on these premises, parties throughout their submissions compare the theoretical speed of the GAS service with the reduced speed applicable to a single type of application (i.e., P2P file sharing applications) during peak periods when traffic shaping takes place. These parties then draw the ridiculous conclusion that Bell “cripples the ADSL by approximately 90%”14 or “Since Bell throttles downstream speeds to 30 KB/s (or 240 kbps)15, this represents only 4.8% of the Basic - Residence downstream speed of 5 Mbps referenced in Bell’s GAS tariff.”16
21.The incorrect premises lead to invalid calculations and comparisons, which only serves to confuse the relevant issues. | |
mazhurg
Premium
join:2004-05-02
Portage La Prairie, MB
·TekSavvy Solutions..
·MTS
| reply to oh LOOK
What really bothers me throughout this is that it really never touches the issue at hand; namely that this is not about IP but a dispute about PPPoE management.
For anyone with a modicum of understanding, this document is so full of mistake that it almost scares me that our telecommunications are managed by such gents. Makes one really confident. Heck, so much so that one should really read this »ARRGH! False 911 Calls as a perfect example of the level of knowledge and expertise herein...  | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to tertech
Oh yeah that !
Heck, I was pleased that there even refered to me ! The word "cripples" is mine... not CAIP
Well let see, you get between 25 and 30 KB/s instead of a max of roughly 520.
So you are right, 10% is ridiculous... I apologize,. It really needs to be 95.2% because you are only getting 4.8% of the speed you're paying for.
| |
Vomio
join:2008-04-01
·odynet
| reply to oh LOOK
I like Bell's graphs and traffic projections.
It would be interesting to see them taken back to 199x or whenever Bell started the HighSpeed offering and then look at the curve in that context.
The other thing that strikes me is if they are blocking p2p now on a relatively flat portion of the graph and assuming the projections are accurate, what the (expletive deleted) are they going to block when the (expletive deleted) hits the fan and the graph goes vertical in four years time.
To reach this projected rate I think the Teachers are going to have to quickly drag fibre to the porch or get the (expletive deleted) out of the business and let someone else provide the connectivity required to keep Canada relevant in this century. The connected world won't wait for us.
Vomio | |
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to oh LOOK
continuation from previous email, statying at about paragraph 124
paragraph 125: 125. Very surprisingly, in response to the interrogatory, CAIP has relied solely on anecdotal evidence without any reference to hard evidence
This is significant. The nature of a PPPoE service meanst that there is no expectation of any manipulation of the packets while in transit through a Point to Point Link. Regular IP based tools are therefore not applicable nor usable because this is not an IP link.
It is therefore next to impossible whithout resorting to sphisticated network tracing tools AND with full understanding of how Bell's DPI equipment works (which we can only deduce since Bell won't release details) to analyse this situation.
And because Bell cripples packets after they have left the ISP, the ISP cannot analyse the problems from its end.
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Paragraph 126 : A serious test program would include placing test equipment at the end-user's premises.
Does SYMPATICO ever do that to retail customers ????????
Paragraphs 135 (legal issues):
It is one thing to have temporary network congestion a few minutes a day, but another to see certain types of customer data discriminated and crippled 9.5 hours of EVERY DAY OF THE YEAR.
136: The reasons for giving Cable that ability and not ADSL is that Cable has a shared liast mile and the CRTC ruling was focused on teh alst mile aspect. So it doesn't apply to Bell's underprovisioned aggregation network.
-------------------------
Appendix 2 – Internet Use Policies
1. Rules While using the Service, you may not … or otherwise use the Service in a manner which is contrary to law or would serve to restrict or inhibit any other user from using or enjoying the Service or the Internet;
Since GAS/5410 is not an internet service, this should be rules inapplicable.
And of the problems is caused by Bell undprovisioning links while ISPs are paying in full for a service that exceeds Bell's capacity, then Bell Canada is knoingly selling a service which it knows it cannot provide and this would be considered theft.
Bell uses "fair and proportionate". Unless Bell
Bell defines this, independant ISPs cannot know how to "police" Bell's undefined policies. When an ISP buys X amount of bandwith to serve its customers, it expects that usiong up to X would be considered fair and proportionate.
re: paragraph 140: I wasted much time on this stupid thing. Some unemployed guy kept calling a governmen'ts 800 number. The GOVERNMENT (novascotia) asked Bell if it was possible to prevent this guy from calling them constantly BECAUSE HE WAS COSTING THE GOVERNMENT MONEY (not because he was blocking service).
paragraph 141: again, this is because Cable companies have assigned very very little bandwidth for upstream, so it becomes very to get the uplink for a whole neighbourhood congested with a single person doing a long of uploading. Servers tend to move a lot of data upstream, which is why CRTC agreed that ISps uising Cable would have to have a "no servers" policy to please the cable operator.
paragraphs 143: crippling EVERYONE's internet is far worse than finding the couple of abusers. And unless Bell defines exactly what is "fair" use, ISPs cannot be expected to find out who the abusers are.
Paragraph 146:
Item A- Bell's action are akin to only allowing a person to speak one work per minute on a voice converstiona. This doesn't technically prevent the person from using the phone, but cripples the service to a point where it is useless.
Item B- Since Bell gives itself the freedom to change its configs and not tell anyone, it becomes very very difficult for ISPs to find out exactly what changes from day to day. The fact that there is a lot fo confision already on what exactly is throttled and what isn't throttled will only get worse and Bell "fine tunes" its DPI equipment and start to implement additional policies.
re: discrimination: It isn't a discrimination between ISPs and Sympatic, it discriminates based on what private data is being exchanged by end users.
Order 2000-789 that:
There is a VERY important distinction between cable and ADSL servce providers.
ADSL uses PPPOE to transparently carry whatever packets between the end user and his service provider.
CABLE provides IP connectivity, and DHCP services ( the cable company is the one that gives the end user an IP address, from a pool that the independnat IS has given). As a result, the traffic sent by the end user to his ISP is treated as an IP packet and managed as such while in transit through the cable company's network on its way to the independant ISP.
A reminder here that ADSL consists of a dedicated line for the last mine, and purchased bandwidth to carry PPPoE packets to the ISP. If the ISP buys sufficient bandwidth, there is no excuse for Bell not providing it. 1-It will not affect other usres if Bell has a aggregation/backbone that has been upgraded to suppport the amount of bandwitdh pourchased by the independnt providers.
Paragrah 168 (bottleneck):
The healthy competition exists because until now, a large numebr of service providers were fully able to define their won service and buy bandwitdh from bell without Bell trying to manage their service. However, without the GAS infrastructure, the competition would be non-existant with a duopoly of cable and Sympatico.
Maintaining the ability of of servoice providers to fully define their service and buy and get the bandwdith necessarty for delivery of the service is essential for a competitive environment.
Bell's DPI prevents this. Bell's refusal to make public its exact filters for its DPI equipment also prevent independant providers from defining what service they are offering today or tomorrow.
ISPs that were advertising themselves as "we do not throttle" are now at risk of being accused of false advertising because Bell has unilaterally decided to impose service management policies on competitors to Sympatico.
ALSO: in the earlier CRTC decisions that did conclude there was competition, the competition came from the dial-up services. Those services are no longer competitive because they are too slow to access modern media-rich internet.
Ok, paragraphs 176 (the need to notify).
What Bell is doing is not network management, they are doing service or application management and they are defining services which the independnat ISPs can and cannot provide and thus can or cannot advertise.
While it is true that ISPs need not change equipment or update their software because the interface between Bell and ISPs remains the same, the service itself has been changed and ISPs have lost the freedom to define their own service because Bell Canada has decided to drop a large number of packets associated with certain applictaion signatures contained in the data.
GENERAL:
Bell claims the DPI equipment does not store data. This is technically correct. IT SENDS IT TO THE CENTRAL MANAGEMENT CONSOLE WHERE IT IS STORED.
paragraphs 194: The IP addresses are part of data poayload which is private on the Bell network because Bell's envelope stops at the PPPoE header.
paragraph 197: looking for user data would take exactly the same amount of resources since the "application header" that Bell talks about is user data.
paragraph 199: CAIP must ask the CRTC to consider the implication of application based accounting on independant service providers who buy a point to point transparent link. There are serious privacy implicatiosn of Bell canada spying on its competitors usage patterns.
If Bell Canada was unwilling to divulge Sympatico customers average bandwidth usage numbers, why should Bell canada have access to the equivelent information of its competitors broken down to different applications used by individuals ?
200. For the purpose of understanding aggregate trends in Internet usage, the DPI is capable of sampling HTTP packets for URLs. The DPI then logs and counts the "hits" in order to generate a read-only "top URL" report which shows the most popular URLs by access for all of the HTTP traffic in aggregate, but never for a single session, individual user or specific group of users.
The Ellacoya docs say otherwise. It can be done on a per user basis. And again, sampling URLs in HTTP transaction implicitely and explicitely requires looking into the payload of a packet.
Furthermore, and more importantly, the HTTP request contains extremely private information contained in the transaction such as username, passwords etc.
The use of DPI on a network requires all customers use HTTPS (encripted HTTP) transactions ONLY.
Furthermore, What gives Bell Canada the right to spy on comeptitor's HTTP transactions to compile statistics or do whatever Bell really intends to do ?
If Sympatico wants to see main usage patterns it can log IP addresses of transactiosn destined to port 80 and make statistics of what web sites are being visited. DPI goes much deeper by going down to provcate data in a URL.
201. However, under certain circumstances, such as legal intercept of traffic pursuant to a court order or for network testing diagnostics, the DPI may be configured to copy specific application or user traffic to an "auxiliary" interface where an external capture device can be connected.
This contradicts an earlier statementr that these boxes have no ability to copy user data. (I think it was in my first message).
##
Furthermore, many free software-based tools, such as WireShark, are available to capture network data.
##
Wireshark can be used by the end user to debug his own network, or by the ISP to debug their network, The iSP has a relationship with the end user and if capturing specific user information, the ISP can contact the end user for permission (usually the reverse happens with end user calling ISP to help debug a problem).
In the case of Bell Canada, there is no relationship between end user and Bell cannot obtain permission to examine one's private bits. Firthermore, because the user's IP address belongs to the ISP and not to Bell, law enforcement would be contacting the ISP should there need to be a wiretap on the line.
203: GAS/AHSSPI does not connect users to the Internet. It connects them via PPPoE to their ISP.
##
Therefore, the DPI can identify either the IP address of a sender or a receiver when they are on the Bell Canada access network, but not when they are on the Internet.
##
Bell Canada has no business looking beyond the PPPoE header in a PPPoE service. And the IP addreses do not change while in trasit thorugh the GAS service because GAS service is a PPPoE service and Bell is not allowed to look at the PPPoE packet contents.
paragraph 204: This is definitely an example of service management. Bell Canada has no right to impose such service management on its competitors.
papagraphs 205: gobledeegook. Of note is the ellacoya document that clearly states that the DPI box is fully capable of implementing user-specific filters by querying a RADIUS authentication server.
Thsi contradicst what Bell probably was trying to say.
paragraph 206: Bell Canada does not assign IP addresses to customers of ISPs. But it does need to look at the initial authentification packet to determine to which ISP this users wishes to connect. So Bell does have the userid and ISP name of each user available to it.
paragraph 207: the userid captured by Bell contains a user/id and ISP name (for instance john_doe@teksavvy.com ) It is not specific to a specific phone line, but Bell can obtain that information because the BAS must be able to send packets to the specific DSLAM port associated to a specific phone line.
paragraphs 208: Since Bell Canada argues that it need not tell anyone of changes it makes, Bell promises of what it does not currently doe are totally meaningless and without any trust.
paragraph 211: There is no such thing as "application header". It is part of usert data. In fact in the context of PPPoE , the IP and TCP headers are part of the payload and Bell Canada has no business knowong what IP addresses users have and to what IP address they are connecting.
Secondly, even if Bell Canada does not look for "names, birth days or other personally identifiable information it does not grant it any more the right to look and discriminate based on the data than it has the right to listen to telephone conversations where correspondants do not exchange any names/birthdates.
paragraph 212: Bell Canada has repeatedly confirmed that it does access the IP address in this very document.
Paragraph 213: this is CRITICAL.
##
Thus the headers of the application are part of the IP payload just as the IP header forms part of the TCP/UDP payload. Therefore, looking beyond the PPPoE header to headers of other layers does not equate to looking at the end-user data or content
##
This MUST be destroyed. The payload of the PPPOE packet is private and sacred. Bell has no business looking into it. period. This has to be a inviolable principle in telecom.
##
Furthermore, the GAS Tariff states that GAS supports PPPoE across the Company's backbone network. The word "supports" in no way means that Bell will limit its network management at the PPPoE level.
##
If Bell can go beyond PPPoE header on this service, does this mean that it can start to manage links used by Banks by going beyond the protocol header for that service and looking into the payload for other headers including looking for application data ?
217:The shaping technique is content and content provider agnostic.
Ask BitTorrent Corp or Vuze if they feel it is provider agnostic. Bell has repeatedly stated that it has decided that certain types of large files need to be slowed down. This means that transfering many small files using HTTP protocol is not treated the same as stransfering one large file of equal size as the combination of all the small files using a different protcool.
##
As a common carrier, Bell does not look at the content of P2P file sharing packets.
##
YES IT DOES ! At least Bell admits it is a common carrier.
223: For GAS/5410, Bell Canada acts as a common carrier, not an internet service provider, so the debate on whether to regulate ISPs does not apply here. However, the CRTC must not let a common carrier unilaterally regulate competiting ISPs. market forces lose strength if you allow a monipoly such as Bell Canada to limit/discate service features of independnat service providers.
231:
As the Commission has stated: "a carrier should be free to implement the standards and specifications of its choice within its network. To require otherwise could be costly and inefficient to some carriers, while possibly decreasing opportunities for product differentiation."
Interesting closing statement because Bell's imposition of service features on all ISPs is in fact reducing the ability for product differentiation.
Yippeee ! I've gone through 86 pages of Bell Lies. | |
Vomio
join:2008-04-01 | Good work once again JF.
Your eyeballs must be dried out from looking at the monitor so its time to step away from the console and get yourself a drink.
Cheers,
Vomio
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Candoo3
join:2005-01-24
·TekSavvy Solutions..
| 
JF Formulating Bell Rebuttal |
said by Vomio :Good work once again JF. Your eyeballs must be dried out from looking at the monitor so its time to step away from the console and get yourself a drink. Definitely .. but he's on a roll !!
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