An Open Letter to the CRTC

Re: CRTC 2008-19 (Review of the Internet traffic management practices of Internet service providers)

Dear Commissioners:

As a Canadian who depends on the Internet for my livelihood, I would like to share with you the consequences of your impending review of the Internet traffic management practices of ISPs.

My business, and most of the businesses I service, rely on the internet to provide content to end-users. In many cases this content takes the form of a written website, but in other cases it is video or downloadable files.

If you permit ISPs to use traffic management practices such as Deep Packet Inspection, or allow ISPs to give priority to traffic that is coming from or going to certain destinations, (for example, Google, or the Government of Canada), then you are allowing ISPs to unfairly discriminate against the traffic, (and by proxy, the end users of that traffic), that does not receive this priority treatment. If this priority is established by paying a fee, you are creating a potentially huge financial barrier to competition that small businesses like mine, and those of my clients will likely not be able to overcome. For me to compete against CanWest, BCE, and other major media companies, when my content is transmitted to end-users would be a near impossibility in a priority-based internet. If ISPs in Canada are permitted to decide whose data is transferred first, and whose data is throttled, Canada will not be an attractive place for any company that relies on the Internet to invest, or for an entrepreneur such as I to start a new Internet-based company.

Suppose the priority system is turned around, and it is the end-users that pay a premium for priority on the internet. In these tough times, should a laid-off autoworker be penalized for doing Google searches for jobs, or for visiting a job site such as Monster or MontrĂ©al-based StandoutJobs? I’m sure that I don’t have to answer that for you.

Yes, there has been a huge growth in traffic on the Internet, and it will continue to grow as more and more services move online, but the solution is not for ISPs to slow down the traffic on the internet or to limit how much information end-users can access, after all, they are in the business of selling internet access. To throttle internet traffic would be like a busy gas station only allowing you to depress the handle halfway when you are filling your car! The way to deal with more traffic on the internet is to build more capacity. According to the Public Notice that I am writing this letter in response to, 6% more households were high-speed internet subscribers in 2007 than in 2006. Would it not be reasonable to expect that with a 6% growth in subscribers, ISPs would add 6% more capacity to their network? It is quite apparent that as we reach 70% or 80% broadband penetration, ISPs’ existing networks will not be able to handle all of the new traffic, but this is exactly what it seems that ISPs want to have happen.

I am not suggesting that ISPs should bankrupt themselves building new networks, but if ISPs were able to make money in the early days of broadband without traffic management then, with today’s advances in networking technology and lower prices of computer and networking equipment, it should be even easier for them to make money today, still without traffic management.


John Beales

Note: Today is the last day to comment on the CRTC’s net-neutrality hearings. You can Read the full text of the CRTC notice and comment on the issue by going to this page, finding the button that says “pt2008-19-2” (at the bottom, or do a ctrl/cmf-f and search on that text), then clicking the button and using the form provided.