Our policy work on UBB

Last night marked the CRTC's deadline for initial interventions from parties for the usage-based billing proceeding (2011-77), and OpenMedia.ca's submission is now on the record.

Last night marked the CRTC's deadline for initial interventions from parties for the usage-based billing proceeding (2011-77), and OpenMedia.ca's submission is now on the record.

The Sameulson‐Glushko Canadian Internet Policy and Public Interest Clinic (CIPPIC), a law group based out of the University of Ottawa and an OpenMedia.ca Network Member, filed our comments in a 22-page document that covered issues from Internet traffic growth to Canada's place in the digital world.

Here are some highlights:

• Bandwidth thresholds or caps address only one narrow aspect of Internet traffic management. There is a very loose association (at best) between monthly usage and congestion.

• While proponents of UBB argue that it's a simple "you pay for what you use" concept, ‘usage’ only translates into ‘cost’, for all practical purposes, when it triggers a network investment action.
• ISPs that want to use traffic management practices, rather than investment in their networks, to address congestion are required to do so only as a last resort.
• Practices that are characterized as congestion‐management techniques often operate as simple pricing mechanisms; this serve only to deter legitimate Internet use and impose costs on Internet users in a manner that is both unfair and undesirable.

• Incumbents (Big Telecom) should be made to justify their monthly caps within this proceeding.
• While Bell cites a "dramatic increase in demand" for bandwidth, we point out that traffic is growing at a steady rate. In fact, rates of annual growth have been reduced in recent years. Meeting this traffic growth should cost no more than it ever has, especially as Big Telecom revenues continue to grow.

• The CRTC is mandated to ensure Canadians have access to “reliable and affordable telecommunications services of high quality.” Usage-based billing is contrary to this mandate insofar as it imposes disproportionate and non‐transparent penalties on consumers.

--
Read the full submission here: http://openmedia.ca/submission-crtc-initial-comments-ubb-proceeding